Last updated: July 28, 2026
Who Surely? ("we," "us," "our") is operated by Jamal Khalili, an independent sole trader based in Berlin, Germany. This policy explains what personal data we collect when you visit whosurely.com or place an order, and how we use it.
Jamal Khalili
Berlin, Germany
Contact: hello@whosurely.com / via the Contact page
When you place an order, we (via our payment processor, Stripe) collect your name, email address, shipping address, and payment details. We do not store your full card details ourselves — Stripe handles and stores that securely.
When you use the Contact page, we collect whatever you submit: typically your name, email address, and message.
We do not use tracking or advertising cookies. The site only sets essential cookies required to process checkout through Stripe.
We use this data to: process and fulfil your order, communicate with you about your order (confirmations, shipping updates, issues), respond to enquiries sent through the Contact page, and meet our legal obligations (e.g. invoicing, tax records).
We process your data on the basis of: performance of a contract (fulfilling your order), legitimate interest (responding to enquiries, keeping the site running securely), and legal obligation (accounting and tax records).
Stripe, Inc. processes all payments and handles the associated personal and payment data under its own privacy policy. We also use a hosting provider to run the site, which processes data (like IP address and access logs) purely to serve the pages. We do not sell or rent your data to anyone.
Some of these providers may process data outside the EU/EEA (for example, Stripe's infrastructure spans multiple regions). Where this happens, it is covered by appropriate safeguards such as Standard Contractual Clauses.
Order and invoice data is kept as long as required by German tax and commercial law (generally up to 10 years). Contact form messages are kept only as long as needed to resolve your enquiry, unless we're legally required to keep them longer.
Under GDPR, you have the right to:
To exercise any of these, contact us via the details above.
Who Surely? is intended for players aged 14 and up. We do not knowingly collect data from children under 14.
We may update this policy from time to time. Changes will be posted on this page with an updated date.
Questions about this policy: hello@whosurely.com or the Contact page.