Privacy Policy

Last updated: 27th April 2022

Thank you for choosing to shop or be part of the Ambessa Play community. If you have any questions about this Privacy Policy, please contact us at hello@ambessaplay.com.

Child version:

This year, we worked on a children co-designed privacy policy in partnership with Queen Mary University's qLegal, Wiggin LLP and local London primary schools. 

Adult version:

Your privacy is important to us at Ambessa Play Limited ("Company", "we", "us", "our") and we are committed to protecting your personal data. This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from us at www.ambessaplay.com (the “Site” “Sites” “Websites” “website” “us” “our page”).

This privacy policy will explain how our business uses the personal data we collect from you when you use our website, how the law protects you and how we look after your data. 

When you visit our website www.ambessaplay.com, and more generally, use any of our services (the "Services", which include the Website), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Services immediately.

 This privacy policy applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events.

Please read this privacy policy carefully as it will help you understand what we do with the information that we collect.

 We would also like to recommend this link for NSPCC guidance for talking to your child about online safety: https://www.nspcc.org.uk/keeping-children-safe/online-safety/talking-child-online-safety/ 

You always have the right to lodge a complaint with a legal authority if you are based in the UK. The designated data protection supervisory authority in the UK is the Information Commissioner’s Office (“ICO”). The designated ICO complaint website is ico.org.uk/make-a-complaint/ and the relevant helpline is 03031231113.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE USE YOUR INFORMATION?
  3. WHAT ARE OUR LAWFUL BASES FOR PROCESSING YOUR DATA?
  4. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
  7. HOW DO WE KEEP YOUR INFORMATION SAFE?
  8. WHAT ARE YOUR PRIVACY RIGHTS?
  9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  10. DO WE MAKE UPDATES TO THIS NOTICE?
  11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  12. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

 

  1. WHAT INFORMATION DO WE COLLECT?
    Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or at one of our physical events, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You. We collect names (including your child’s first name and age where asked); email addresses; mailing addresses; billing addresses; debit/credit card numbers.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by Shopify. You may find their privacy policy link(s) here: https://www.shopify.co.uk/legal/privacy/customers.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short:  Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Website.

We automatically collect certain information when you visit, use or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

  • Log and Usage Data.Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).
  • Device Data.We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
  • Location Data.We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
  1. HOW DO WE USE YOUR INFORMATION?

In Short:  We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website and at our physical events for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

  • To post testimonials.We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at hello@ambessaplay.com and be sure to include your name, testimonial location, and contact information.
  • To request feedback. We may use your information to request feedback and to contact you about your use of our Website.
  • To enable user-to-user communications.We may use your information in order to enable user-to-user communications with each user's consent.
  • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
  • To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
  • To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
  • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • To fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.
  • To deliver and facilitate delivery of services to the user.We may use your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users.We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
  • To send you marketing and promotional communications.We may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, or subscribing to marketing, we will collect personal information from you. You can opt-out of our marketing emails at any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).
  • To deliver targeted advertising to you.We may use your information to develop and display personalised content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. User consent via pop-up is required for the use of advertising cookies and online behavioural advertising.
  • For other business purposes.We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and physical events, to evaluate and improve our Website, products, marketing and your experience. We may use your information for general operations purposes. We may use and store this information in aggregated and anonymised form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.
  1. WHAT ARE OUR LAWFUL BASES FOR PROCESSING YOUR DATA?

In Short:  We only control and process information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations. We may control and process your data based on at least one of the following legal bases:

  • Consent:We may process your data if you have given us specific consent to use your personal information for a specific purpose.
  • Legitimate Interests:We may process your data when it is reasonably necessary to achieve our legitimate business interests, such as to develop and improve our engagement with you, to ensure effective operational management and internal administration of our business, document retention, compliance with regulatory guidance and exercise or defence of legal claims.
  • Performance of a Contract:Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
  • Legal Obligations:We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests:We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Public task: We may disclose your information where we are required to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

Where we rely on legitimate interest for processing your information, we carry out a ‘balancing test’ to ensure that our processing is necessary and that your fundamental rights of privacy are not outweighed by our legitimate interests, before we go ahead with such processing. You can find out more about the information in these balancing tests by contacting us using the details below. 

  1. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short:  We only share information under at least one of the lawful bases for processing data mentioned above. The recipients of your personal data are:

  • Business Transfers.We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • We share your personal information with trusted third parties where we have retained them to perform services on our behalf, such professional advisors (including our lawyers and accountants), service providers (including our communications agency and website design agency), IT consultants carrying out testing and development work on our website, and analytics and search engine providers that assist us in the improvement and optimisation of our services].
  • Other recipients. Where required we share your personal information with third parties to comply with a legal obligation; when we believe in good faith that an applicable law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our Website Terms and Conditions or other applicable policies; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to the our website, our business or the public.
  1. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

  1. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). We keep persal information for at maximum, 3 years. No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  1. DO WE TRANSFER YOUR INFORMATION OUTSIDE THE UK AND EEA?

In Short:  We use safeguards to ensure that your data is kept safe outside of the UK and EEA.

Your information is generally stored and processed in the UK and the EEA, including where it is hosted.  Where we transfer your information outside of the UK and EEA, we rely on appropriate safeguards permitted by UK data protection law for such transfers, such as “standard contractual clauses”.  If we intend to transfer your information to any additional countries, we will update this privacy policy to reflect such overseas transfers.

  1. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

  1. WHAT ARE YOUR PRIVACY RIGHTS?

In Short:  In some regions, such as the European Economic Area and United Kingdom, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

The UK GDPR provides the following rights for individuals:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at hello@ambessaplay.com if you wish to make a request.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to be informed about how your information is used, (ii) to request access and obtain a copy of your personal information, (iii) to request rectification or erasure; (iv) to restrict the processing of your personal information; (v) if applicable, to data portability, and (vi) if applicable, certain rights in relation to automated decision making and profiling. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you are a resident in the United Kingdom, the designated ICO complaint website is ico.org.uk/make-a-complaint/ and the relevant helpline is 03031231113.

If you have questions or comments about your privacy rights, you may email us at hello@ambessaplay.com.


Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may: unsubscribe, in the link at the bottom of every email, or email hello@ambessaplay.com. 

  1. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).


CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:


Category


Examples


Collected

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

YES

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history and financial information

YES

C. Protected classification characteristics under California or federal law

Gender and date of birth

YES

D. Commercial information

Transaction information, purchase history, financial details and payment information

YES

E. Biometric information

Fingerprints and voiceprints

NO

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

NO

 

G. Geolocation data

Device location

NO

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

NO

I. Professional or employment-related information

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

NO

J. Education Information

Student records and directory information

NO

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

YES

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at hello@ambessaplay.com, or by referring to the contact details at the bottom of this document.

If you are using an authorised agent to exercise your right to opt-out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf. 

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

Ambessa Play has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. Ambessa Play will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

  • you may object to the processing of your personal data
  • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
  • you can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
  • you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at hello@ambessaplay.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

  1. DO WE MAKE UPDATES TO THIS NOTICE?

 

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we plan to use your data for a new purpose, we update our privacy information and communication the changes to you before starting any new processing.

We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

  1. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at hello@ambessaplay.com or by post to:

Ambessa Play

10 Bradmore Road

Oxford, Oxfordshire OX2 6QN

United Kingdom


  1. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?    To request to review, update, or delete your personal information, you can inform us verbally or in writing. We have one month to respond to your request. For more information on Right to erasure, we recommend visiting ICO.