Privacy Policy

The controller for everything described here is Whimbel, Eva Barel, c/o COCENTER, Koppoldstr. 1, 86551 Aichach, Germany. Write to support@whimbel.com about anything on this page and it reaches the person responsible.

We are based in Germany, so European data protection law (the GDPR) governs everything we do with your data. That is true for every customer, wherever you live. The rights described below are yours whether you order from Munich, Manchester or Minnesota.

• •Your account, your books, previews, orders and the emails that go with them. This is simply doing what you asked us to do, so the basis is our contract with you (Art. 6(1)(b) GDPR).
• •Turning your photos into illustrations. That includes finding where the faces are in a group photo so each person is assigned to the right character, and comparing the finished illustrations with each other so the same person looks the same on every page. The face in your photo is never measured or run through face-matching. Without it there is no book, so the basis is again our contract with you (Art. 6(1)(b) GDPR). No face template or faceprint is created or kept.
• •The other people in your book. A grandparent, a friend, a sibling or a child whose parent is not the one ordering has no contract with us. For their photos and the details about them, the basis is the legitimate interest, yours and ours, in making the book you ordered (Art. 6(1)(f) GDPR). We weighed that against their interests: what we hold about them is used for that one book and nothing else, kept in private storage, never sold, never used for training, and deleted with the book, and a personal family keepsake is the kind of use people in a family can reasonably expect. They can object at any time and have it removed (section 11).
• •Sensitive details you choose to share. Health (a disability, medical equipment, a hospital birth, an illness) and religion (a baptism, a bar mitzvah) are special categories of data. If you tell us about them so they can be in the book, you are giving us your explicit consent to use them for that alone (Art. 9(2)(a) GDPR). You never have to tell us, and we use what you tell us for nothing but the book you asked for. If the detail is about someone else, only share it if that person has agreed, or if you are the parent or legal guardian of the child it concerns; that person can also ask us to take it out at any time. You can take that consent back at any time by writing to support@whimbel.com: we take the detail out of your book and out of our records. You do not have to delete the book to do it.
• •Book ideas and offers by email, and the launch email to the waitlist. Only if you tick the box (and, for the waitlist, confirm it with the link we email you). The basis is your consent (Art. 6(1)(a) GDPR and section 7(2) no. 2 UWG), and one click on the unsubscribe link withdraws it. That same consent covers our measuring whether those emails arrive, are opened and are clicked, so we can tell whether what we send is worth sending.
• •Analytics. Only after you accept the cookie banner. The basis is your consent (Art. 6(1)(a) GDPR and section 25(1) TDDDG). You can withdraw it at any time under Cookie settings in the footer.
• •Order, invoice and payment records. German tax law tells us to keep these, so we must (Art. 6(1)(c) GDPR, section 147 AO and section 14b UStG).
• •Withdrawal declarations. We record them to act on your withdrawal (Art. 6(1)(b) GDPR) and to be able to prove what reached us and when (Art. 6(1)(c) and 6(1)(f) GDPR).
• •Keeping the service safe and working. Limiting how many requests one IP address may make, crash reports, protecting sign-in, checking discount codes and referral links, counting page views on our own servers, watching hosting metrics, and looking at generated books and chat logs when we are chasing a quality problem. Our interest is a service that works and is not abused (Art. 6(1)(f) GDPR). You can object — see the section on your right to object.

Quality checks are done on the real books and the real chats, not on anonymised copies. We do not make any automated decision about you that has a legal or similarly significant effect.

When you upload a photo with several people in it, we find where each face is, so that the right person becomes the right character. Finding a face tells us where it is in the picture, not who it is. Once the illustrations exist, we compare the drawn faces with each other so that a person looks like themselves from page to page. That face-matching is between illustrations only: the face in your original photo is never measured or run through face-matching. The AI services that draw the book do look at your photos, the way an illustrator would, to draw each person and to check that a drawing shows the right person, but no faceprint comes out of that.

This is how the book gets made. It is necessary to deliver what you ordered, so the legal basis is our contract with you (Art. 6(1)(b) GDPR). No face template or faceprint is created or kept. We do not build a database of faces, and we never use a face to recognise anyone anywhere outside the book you asked for.

Because there is no version of the book without it, there is nothing to switch off. What you can do is delete the photo, delete the book (see section 9), or delete your account. That removes the faces with them.

We do not sell your personal information to anyone. We use a small number of outside services to run Whimbel, and each one gets only what it needs:

• •Hosting and the database (European Union) — where your account, your books, your photos and your illustrations live.
• •The server that builds your book (United States) — it takes your photos and story from the database while the book is being made, sends them to the services below, and puts the finished pages back. It keeps nothing permanently.
• •The services that write the story and draw the illustrations (the United States and other countries outside Europe) — they receive your photos, the details you shared and the chat with the assistant, for as long as it takes to produce the text and the pictures.
• •The service that finds faces in group photos (United States) — it receives the group photo, only to find where the faces are.
• •The service that compares faces (United States) — it receives illustrations only, never your photos.
• •The service that turns speech into text and reads replies aloud (United States) — only if you use the microphone, and only for that recording.
• •The payment service (Ireland and the United States) — it takes your card details directly and confirms the payment to us.
• •The email delivery service (United States) — it receives your email address and the message we send you.
• •The printing and shipping service (Norway, printing in or near the country you ship to) — it receives the delivery name, address, phone number and email address, and the print file itself, which contains the name of the person the book is about, the story, the dedication, the illustrations and the photos that are printed in the book (the photo on the opening page and any memory photos you added). Photos you uploaded only so a person could be drawn do not go to the printer.
• •The delivery carrier (the parcel service the printer hands the book to, usually in the country it ships to) — it receives the delivery name, address, phone number and email address from the printing service, and may use the email address and phone number to contact you about the delivery, for example by email or text message with tracking or a delivery time.
• •The analytics and site-performance services (United States) — only if you accept analytics cookies, and only page and device information, never your photos or your story.

We may also pass data to a tax adviser, an accountant or an authority where the law requires it.

The current list of the companies behind these services, where they sit and which safeguard applies to each is available from support@whimbel.com. Just ask.

We are a German business. Our website and the database sit inside the European Union, in the Frankfurt region. The server that builds your book runs in the United States, several of the services listed above run there too, the service that writes the story may run in other countries outside Europe as well, the payment service sits in Ireland and in the United States, and the printing service is Norwegian, with printing done in or near the country your book ships to and a carrier there delivering it.

Except for the delivery carrier, every transfer outside the European Economic Area relies on a safeguard: the EU-US Data Privacy Framework where the service is certified under it, and otherwise the European Commission's standard contractual clauses, with the UK addendum added for data coming from the United Kingdom. Where the service that writes the story hands the work to another company to run it, we rely on the safeguard our provider passes on to the companies it routes to, and we can show you which one applied to your book.

The delivery carrier usually works in the country your book ships to. When that country is outside the European Economic Area, the carrier there receives the delivery name, address, phone number and email address from the printing service, because the parcel cannot reach you without them. Unless the European Commission has recognised that country as protecting data adequately, this transfer rests on its being necessary to deliver the order you placed (Art. 49(1)(b) GDPR).

You can ask us for a copy of the clauses that cover your data at any time, at support@whimbel.com.

• •Your account and profile: until you delete it.
• •Books, drafts, the chat with the assistant, photos and illustrations: until you delete the book, or delete your account.
• •Generation and quality logs (what was made, whether it worked): until you delete the book, or delete your account.
• •Crash reports: kept while we investigate a fault. One that belongs to your book or your account goes when you delete that book or your account.
• •Rate-limit records (how many requests came from a connection): cleared the next time that connection is seen; they are never used for anything after the hour they cover.
• •Order, invoice and payment records: 8 years, because German tax law says so (section 147 AO, section 14b UStG). These survive account deletion, but we cut the link to your account so they sit on their own as accounting documents.
• •Withdrawal declarations: kept for the same 8 years as the order records they relate to, so that what you declared and when it reached us can still be shown. They are not deleted when you delete your account; they are deleted when those 8 years are up.
• •A printed book still being made or still on its way when you delete your account: the delivery name, address, phone number and email address on that one order, and the print file the printer collects, stay so the parcel can still reach you. See section 9.
• •Unsubscribed email addresses: kept on a suppression list, so that we never email you again by accident. That is the only reason we keep them.
• •Your waitlist address: if you never click the confirmation link, we delete it, together with our record of the confirmation emails we sent it, 30 days after the last one we sent. Once you have confirmed, we keep it, with when you asked and when you confirmed, until you unsubscribe, delete an account made with the same address, or ask us at support@whimbel.com to remove it — whichever comes first. Unsubscribing stops the emails at once (section 13).

You can delete a single photo or a whole book from your library at any time — the one wait is a printed book we are still making or still posting to you: we can delete that one once it has arrived, or sooner if you write to us. You can also ask us to delete your account, from your settings or by writing to support@whimbel.com.

Within 30 days of the request, your account, your books, your drafts, your photos, your chat with the assistant and everything generated from them are deleted. Not hidden, not archived — deleted.

Three things stay behind, and nothing else does:

• •The order, invoice and payment records described above. German tax law forbids us to delete those early, so they stay for 8 years with the link to your account removed.
• •Any withdrawal you declared to us. It is the record that your withdrawal reached us and when, so it stays for the same 8 years as the order records it relates to (section 8), and is then deleted.
• •A printed book still being made or still on its way to you. We keep the delivery name, address, phone number and email address on that one order, and the print file the printer collects, so the parcel can still reach you. Everything else about the book goes.

To make a book at all we need:

• •an email address, so you can sign in and we can send you the book;
• •the name of the person the book is about;
• •the story details you want in it;
• •at least one photo of every person who is to appear, because without a photo that person cannot be illustrated;
• •for a printed book, a delivery name, address and phone number.

Everything else is optional. If you do not give us the items above we cannot make or ship the book, but nothing else happens — there is no penalty and no consequence beyond that.

Sometimes the person in the book is not the person who ordered it: a grandmother in a tribute, a child in a book made by a parent, a friend in a birthday story. If that is you, here is where your data came from and what happens to it.

The customer gave us your photo and the details about you. We use them for that one book: to draw you, to write the story, and to print and ship it. We have no contract with you, so the basis is the legitimate interest, the customer's and ours, in making the book they ordered (Art. 6(1)(f) GDPR), weighed against yours as section 3 explains; you can object at any time. The categories are the ones in section 2 — photos, a name, a month and year of birth, memories, and anything the customer chose to tell us. Nothing about you is used for anything else, and nothing about you is sold.

You have exactly the same rights as the customer does, listed below: to see what we hold, to correct it, to have it deleted, and to object. Write to support@whimbel.com and tell us which book, and we will handle it.

Some of these are needed for the site to work at all, and some are there because of something you did — a choice you made, or the link you followed to get here. The analytics cookies are the only ones that wait for your answer (section 25(1) TDDDG): nothing measures how you use the site until you accept.

• •Sign-in cookie — keeps you signed in. Essential; the site cannot work without it.
• •Currency cookie — remembers which currency to show prices in, for 180 days.
• •Your book draft — saved in your browser so you can close the tab mid-story and pick up where you left off. It stays on your device until you start another book, or until you clear your browser data.
• •Your cookie choice — stored so we do not ask you again on every page.
• •Where you came from — the name of the website that sent you here (for example a search engine) and the page you landed on, kept in your browser for this visit only, so we can tell which pages and which outside sites bring people to us. It holds nothing that identifies you and is gone when you close the tab.
• •Referral cookie (30 days) and partner cookie (90 days) — set only if you arrive through a referral or a partner link, so the person who sent you gets credited.
• •Analytics cookies — up to 2 years, and only after you accept the banner.

To change your mind, open Cookie settings in the footer, or reopen the cookie choice here. Declining analytics costs you nothing: the site works the same either way.

• •Order and account emails — your confirmation, your preview being ready, shipping news, a password reset. These are part of the service you bought, so they cannot be switched off while you have an account or an open order.
• •Book ideas and offers — only if you ticked the box. Every one of them carries an unsubscribe link, and one click ends it.
• •The launch waitlist — if you tick the box on our coming-soon page, we first send you a single email with a confirmation link (double opt-in). Until you click it you are not on the list and we send you nothing else; the link works for 7 days, we send at most three of these emails to one address in a day, and an address nobody confirms is deleted after 30 days. Once you confirm, we email you when Whimbel launches and now and then with book ideas and offers, never more than a couple a month. The basis is your consent (Art. 6(1)(a) GDPR and section 7(2) no. 2 UWG). The confirmation email, and our record of when you asked and when you confirmed, rest on our legitimate interest in being able to show that the request really came from you (Art. 6(1)(f) GDPR, read with Art. 7(1) GDPR). If you leave the box unticked, we keep nothing and never email you; nor do we email an address left before the box existed. Each email carries an unsubscribe link: one click ends them at once, deletes your place on the waitlist and puts the address on the suppression list. Writing to support@whimbel.com also gets the address deleted. If you later make an account, the choice you make there takes over.

For the emails you ticked the box for, the email delivery service also records whether you opened them and which links in them you clicked, so we can see whether what we send is worth sending. For order and account emails we keep no opens and no clicks — only whether the message was delivered, bounced or was reported as spam, so that we can stop mailing an address that no longer works. If you unsubscribe, your address goes on a suppression list and stays there — that is what stops us from ever emailing you again.

Whimbel is for adults. Accounts, orders and payments are made by grown-ups, and we do not knowingly collect anything directly from a child. When you upload a child's photo and details, you do it as their parent or legal guardian, or with that parent's permission, and the child's data is treated exactly like everyone else's in this policy. A parent or guardian can ask us at any time to show, correct or delete everything we hold about their child. Our Terms of Service say the same.

Whoever you are and wherever you live, you can ask us to:

• •Show you what we hold about you, and a copy of it (Art. 15 GDPR)
• •Correct anything that is wrong or incomplete (Art. 16 GDPR)
• •Delete it (Art. 17 GDPR)
• •Freeze it instead of deleting, while something is being sorted out (Art. 18 GDPR)
• •Hand it over in a machine-readable file, or send it straight to another provider (Art. 20 GDPR)
• •Object to processing we base on our legitimate interests, and to marketing (Art. 21 GDPR — see the next section)
• •Not be subject to a decision made purely by machine that has a legal or similarly significant effect on you (Art. 22 GDPR). We make no such decisions.
• •Withdraw a consent you gave us, at any time, without giving a reason. That does not make the processing before the withdrawal unlawful.

Write to support@whimbel.com. We answer within one month, and we tell you if we need longer. It is free, and we tell you when a request has been dealt with. We may ask you something to be sure it is really you.

Marketing. If you no longer want book ideas and offers from us, say so and we stop. No reason needed, no exceptions, and it takes effect immediately (Art. 21(2) GDPR). The unsubscribe link in every such email does the same thing.

Everything we base on legitimate interests. You can object to the processing described in the last bullet of section 3 — security, abuse prevention, our own usage counts, hosting metrics and quality review — on grounds relating to your particular situation (Art. 21(1) GDPR). Tell us what those grounds are and we stop, unless we can show compelling reasons that override your interests, or we need the data to defend a legal claim.

Everything travels over an encrypted connection, and photos and illustrations are stored encrypted. Access is limited to the people who need it to run the service, sign-in is protected against guessing, and each account can only reach its own books. We review the setup regularly. No system is perfect, and if a breach ever put your rights at risk we would tell you and the supervisory authority, as the law requires.

Please try us first — support@whimbel.com — because most things are quickest to fix directly. But you never have to.

Our supervisory authority is the Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Promenade 18, 91522 Ansbach, Germany. You may also complain to the data protection authority of the country you live or work in, or where you think something went wrong.

If you live in the United Kingdom, that authority is the Information Commissioner's Office (ICO).

We update this policy when what we do changes. If a change matters to you, we email registered customers at least 14 days before it takes effect, and the date at the top of this page always tells you which version you are reading.

Controller (Verantwortlicher): Whimbel, Eva Barel, c/o COCENTER, Koppoldstr. 1, 86551 Aichach, Germany.

For any question about your data, to use one of the rights above, to ask for the list of our service providers, or to have everything deleted, write to support@whimbel.com.