Die deutsche Übersetzung dieser Datenschutzerklärung finden Sie hier: [German]Privacy Policy
Parker, Elvetia - Ranganath-Schulz, Chandni GbR
Effective date: 9 March 2026
Version 1.0
1. Data Controller
The data controller responsible for the processing of personal data on this website and in connection with our customer discovery survey is:
Parker, Elvetia - Ranganath-Schulz, Chandni GbR
Kaiserswerther Str. 135
40474 Düsseldorf
Germany
Email: privacy@therealsparrow.com
2. Overview of Data We Collect
We collect personal data in the following contexts:
Customer discovery survey — hair characteristics, routine and lifestyle information, language use, length of residence in Germany, shopping behaviour, and optionally your email address.
Newsletter — your email address and consent record if you choose to subscribe.
Website — technical data collected automatically when you visit our website, including IP address and browser information.
3. Customer Discovery Survey
We conduct a voluntary customer discovery survey to better understand the experiences, challenges, and needs of people with textured hair living in Germany. The insights collected through this survey help us understand product availability and shopping experiences, identify unmet needs in the market, and design and improve the sparrow platform and its community resources.
The survey may collect information relating to hair texture, hair care routines, scalp concerns, hair goals, product preferences, purchasing behaviour, and shopping experiences in Germany. It may also include questions about language use and length of residence in Germany, as well as optional open-text responses where participants may share personal experiences. Participation in the survey is entirely voluntary, and participants may skip any question they prefer not to answer.
Survey responses themselves do not require identifying information. However, the survey platform may process certain technical metadata—such as IP address, device information, or timestamps—in order to provide and secure the service. This data is processed by the survey provider as part of the technical delivery of the survey.
Some survey questions may indirectly relate to cultural or ethnic background through information about hair characteristics or identity. Where such information is processed, the legal basis for processing is your explicit consent under Article 9(2)(a) GDPR, which is provided through the consent checkbox before starting the survey.
At the end of the survey, participants may optionally provide an email address if they wish to receive updates and newsletters from sparrow. Providing an email address is completely optional.
The survey is hosted by Typeform, operated by Typeform S.L., Barcelona, Spain. Typeform acts as a data processor on our behalf under Article 28 GDPR and processes data solely in accordance with our instructions. More information about Typeform’s data protection practices can be found at https://www.typeform.com/help/gdpr-compliance/
4. Newsletter
If you subscribe to the sparrow newsletter, your email address will be stored and used exclusively to send you sparrow updates, community news, and launch information. We will never use your email address for any other purpose or share it with third parties.
You can unsubscribe from the newsletter at any time by clicking the unsubscribe link in any email we send. You may also request deletion of your email address by contacting privacy@therealsparrow.com.
Our newsletter emails are sent from hello@therealsparrow.com using Kit (formerly ConvertKit), operated by ConvertKit LLC, 750 W Bannock St, Boise, Idaho 83702, USA. Kit acts as a data processor on our behalf. Data is transferred to Kit's servers in the United States on the basis of Standard Contractual Clauses approved by the European Commission. You can find Kit's privacy policy at kit.com/privacy and their data processing agreement at kit.com/dpa.
5. Website
Hosting
This website is hosted by Squarespace, operated in the European Union by Squarespace Ireland Ltd., Le Pole House, Ship Street Great, Dublin 8, Ireland. Certain technical processing may involve Squarespace Inc., 225 Varick Street, New York, NY 10014, USA.When you visit our website your browser automatically transmits technical data to our server including your IP address, browser type, operating system, and the pages you visit. This data is processed for the purpose of providing the website and ensuring its security, on the basis of our legitimate interest under Article 6(1)(f) GDPR. Data is transferred to Squarespace's servers in the United States on the basis of Standard Contractual Clauses approved by the European Commission.
You can find Squarespace's privacy policy at squarespace.com/privacy and their data processing addendum at https://www.squarespace.com/dpa
Cookies
This website uses cookies. A cookie is a small text file stored on your device when you visit a website. We use the following types of cookies:
Essential cookies — necessary for the website to function. These cannot be disabled. Legal basis: Article 6(1)(f) GDPR.
Analytics cookies — we use Google Analytics to understand how visitors use our website. Google Analytics places cookies on your device and transmits data including your IP address to Google servers. Before any analytics cookies are placed we will ask for your explicit consent via our cookie banner. You can withdraw this consent at any time by adjusting your cookie preferences. Legal basis: Article 6(1)(a) GDPR.
Google Analytics data is transferred to Google servers which may be located in the United States. This transfer is made on the basis of Standard Contractual Clauses approved by the European Commission. You can find Google's privacy policy at policies.google.com/privacy.
You can prevent Google Analytics from collecting your data by installing the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.
6. Your Rights Under GDPR
As a data subject under the GDPR you have the following rights:
Right of access — you have the right to request a copy of the personal data we hold about you under Article 15 GDPR.
Right to rectification — you have the right to request correction of inaccurate personal data under Article 16 GDPR.
Right to erasure — you have the right to request deletion of your personal data under Article 17 GDPR, where applicable. Please note that because survey responses are not linked to individual identities we are unable to identify or delete individual survey responses. We can delete your email address upon request.
Right to restriction — you have the right to request that we restrict processing of your personal data under Article 18 GDPR.
Right to data portability — you have the right to receive your personal data in a structured, commonly used format under Article 20 GDPR, where processing is based on consent or contract.
Right to object — you have the right to object to processing based on legitimate interest under Article 21 GDPR.
Right to withdraw consent — where processing is based on your consent you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
To exercise any of these rights please contact us at privacy@therealsparrow.com. We will respond within 30 days.
7. Right to Lodge a Complaint
You have the right to lodge a complaint with a data protection supervisory authority if you believe we have processed your personal data unlawfully.
The supervisory authority responsible is:
State Commissioner for Data Protection and Freedom of Information
North Rhine-Westphalia,
Kavalleriestraße 2-4,
40213 Düsseldorf
Email: poststelle@ldi.nrw.de
Website: https://www.ldi.nrw.de
8. Data Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or destruction. Data transmitted via the internet cannot be guaranteed to be completely secure. We cannot accept responsibility for data transmitted to us over the internet.
Day-to-day email communications are handled via Proton Mail, operated by Proton AG, Route de la Galaise 32, 1228 Plan-les-Ouates, Geneva, Switzerland. Switzerland is recognised by the European Commission as providing an adequate level of data protection. You can find Proton's privacy policy at proton.me/legal/privacy.
9. Data Retention
Unless a more specific retention period is stated, personal data is stored only as long as necessary for the purposes described in this policy.
Survey responses are stored for up to 24 months for research purposes and may then be anonymised or deleted.
Newsletter data is stored until you unsubscribe.
10. Links to Third-Party Websites
Our website may contain links to external websites. We are not responsible for the privacy practices or content of those websites. We recommend reviewing the privacy policies of any external websites you visit.
11. Changes to This Policy
We may update this privacy policy from time to time. The current version will always be available on this page. We will notify newsletter subscribers of any material changes by email.
12. Contact
For any questions about this privacy policy or how we handle your personal data please contact us at: privacy@therealsparrow.com