Privacy Policy

This Privacy Policy explains how Emberly Books Limited (“Emberly Books”, “we”, “us” or “our”) collects, uses, shares and protects your personal information when you visit www.emberlybooks.com (the “Website”), place an order, or otherwise use our products and services (together, the “Service”).

We make personalised children's books in which a child becomes the hero of their own story. To do this, we ask you to upload a photo of the child and tell us a few details about them, and we use artificial intelligence to generate an illustrated character based on that photo. Because this involves a child's image and personal details, we take particular care with how that information is handled — please read the section “The Child's Photo and AI Character Generation” below.

Please read this policy carefully. By using the Service, you confirm you have read and understood it.

1. Who We Are and How to Contact Us

Emberly Books Limited is the controller responsible for your personal data.

• Company registration number: 17160334
• Registered address: 124-128 City Road, London, England, EC1V 2NX
• Privacy contact / data requests: [email protected]

If you have any questions about this policy, or want to exercise any of your rights, please contact us at [email protected].

2. The Personal Data We Collect

We collect the following categories of personal data.

2.1 Information you give us

When you create an account, place an order, or contact us, you may provide:

• Your details (the customer): name, email address, billing address, delivery address, phone number, and account password.
• The child's details (the book's hero): the child's name, age and/or date of birth, gender, hair colour, eye colour, and a photo of the child.
• Personalisation content: a dedication message and any other text you choose to add to the book.
• Communications: the contents of messages you send us, including support requests and feedback.

2.2 Information we collect automatically

When you use the Website, we automatically collect certain technical and usage data, including your IP address, device and browser type and version, operating system, time zone setting, the pages you view, the links you click, the products you view or search for, page response times, and the dates and times of your visits. We collect this using cookies and similar technologies (see Section 6).

2.3 Information from third parties

We may receive information about you from our service providers, including our payment providers (confirmation of payment, fraud-screening signals), our analytics and advertising partners, and from publicly available sources.

2.4 Payment information

We do not collect or store your full payment card details. All payments are processed directly by our payment providers — Stripe, PayPal and Klarna — who handle your card and payment information under their own privacy policies.

3. The Child's Photo and AI Character Generation

This section explains exactly what happens to the photo you upload, because it is the most sensitive information we handle.

• When you order a personalised book, you upload a photo of the child and select details such as hair and eye colour.
• We transmit that photo to our AI image-generation systems for the sole purpose of generating an original illustrated character that resembles the child in the style of the chosen book.
• We do not store the child's photo on our own systems. Once your character has been generated, the original photo is deleted immediately. We do not keep it, archive it, or use it for any other purpose, and we do not use uploaded photos to train any AI models of our own.
• Our AI processes the photo solely to generate your character. We do not use your photo to train our AI models.

By uploading a photo, you confirm that you are the child's parent or legal guardian, or that you otherwise have the authority and permission to upload the image and the child's details for this purpose.

4. How We Use Your Data and Our Legal Bases

Under UK and EU data protection law we must have a “legal basis” for using your personal data. The table below sets out what we do and why.

Where we rely on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Marketing and Your Choices

If you have consented or are an existing customer, we may send you marketing emails about our books and offers.

You can opt out of marketing at any time by clicking the “unsubscribe” link in any marketing email, or by emailing us at [email protected]. Opting out of marketing will not stop transactional messages relating to your orders.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.

6. Cookies, Analytics and Advertising

We use cookies and similar technologies to operate the Website, remember your preferences, understand how the Website is used, and deliver relevant advertising. When you first visit, our cookie banner lets you accept or reject non-essential cookies.

• Essential cookies are required for the Website and checkout to function and cannot be switched off.
• Analytics cookies help us understand how visitors use the Website so we can improve it. We may use analytics providers such as Google Analytics.
• Advertising cookies allow us and our advertising partners to show you relevant ads on other websites and platforms (retargeting) and to measure how our ads perform. For this purpose we may share limited data, such as anonymised or hashed identifiers, with advertising partners.

You can manage cookies through our cookie banner and through your browser settings. Blocking all cookies may affect how parts of the Website work.

7. International Data Transfers

We are based in the UK and your data is primarily stored on servers located in Germany (EEA). However, some of our service providers — including our AI, payment, email and advertising partners — are located outside the UK and the EEA, including in the United States. This means your personal data may be transferred internationally.

Whenever we transfer your data outside the UK or EEA, we make sure a similar level of protection applies by relying on an appropriate safeguard, such as:

• a transfer to a country the UK or EU has decided provides adequate protection;
• the use of UK International Data Transfer Agreements / Addenda and the EU Standard Contractual Clauses; or
• a provider's certification under a recognised framework, such as the EU–US Data Privacy Framework, where applicable.

You can contact us for more information about the safeguards we use.

8. How Long We Keep Your Data

We keep your personal data only for as long as necessary for the purposes set out in this policy.

• The child's photo: deleted immediately after the character is generated; never stored (see Section 3).
• Order and transaction records: retained for 7 years to meet our legal, tax and accounting obligations.
• Account data: retained for as long as your account is active. If you close your account or ask us to delete your data, we will delete or anonymise it, except where we are required to keep certain information to meet a legal obligation, resolve disputes, or enforce our agreements.
• Marketing data: retained until you opt out, after which we keep a minimal record to honour your opt-out.

Where we anonymise data so it can no longer be associated with you, we may keep and use it indefinitely.

9. How We Protect Your Data

We have put in place appropriate technical and organisational measures to protect your personal data against loss, misuse, unauthorised access, alteration and disclosure. We limit access to your data to staff and service providers who need it, and they are bound by confidentiality obligations. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we work to protect your data and have procedures to deal with any suspected breach, including notifying you and the relevant regulator where we are legally required to do so.

10. Children's Privacy

Our Service is intended for adults (18 and over) who are purchasing a personalised book for a child. We do not knowingly allow children to create accounts or purchase from us, and we do not knowingly collect personal data directly from children.

The child's details and photo are provided to us by the purchasing adult, who confirms they are the child's parent or legal guardian or otherwise have authority to provide that information. If you believe a child has provided us with personal data without the appropriate authority, please contact us at [email protected] and we will take steps to address it.

11. Your Rights

Depending on where you live, you have rights over your personal data. We will respond to all valid requests within the time required by applicable law, and you will not normally have to pay a fee.

11.1 UK and EU/EEA (GDPR)

If you are in the UK or EEA, you have the right to:

• access the personal data we hold about you;
• request correction of inaccurate or incomplete data;
• request erasure of your data (“right to be forgotten”);
• object to processing based on our legitimate interests;
• request restriction of processing in certain circumstances;
• request portability of data you provided to us, in a structured, machine-readable format;
• withdraw consent at any time where we rely on consent; and
• complain to a data protection authority.

If you are in the UK, you can complain to the Information Commissioner's Office (ICO) at ico.org.uk. If you are in the EEA, you can complain to your local supervisory authority. We would, however, appreciate the chance to address your concerns first.

11.2 United States (including California)

Depending on your state of residence, you may have the right to:

• know what personal information we collect, use and disclose about you;
• request access to or a copy of that information;
• request correction of inaccurate information;
• request deletion of your information; and
• opt out of the “sale” or “sharing” of your personal information and of targeted advertising.

We do not sell your personal information for money. We do not discriminate against you for exercising any of these rights. To make a request, contact us at [email protected]. We may need to verify your identity before responding, and you may use an authorised agent where permitted by law.

11.3 Australia

If you are in Australia, we handle your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). You may request access to and correction of your personal information by contacting us at [email protected]. If you are not satisfied with how we handle a privacy issue, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.

To protect your data, we may ask you for information to verify your identity before acting on any request.

12. Links to Other Websites

The Website may contain links to other websites we do not operate or control. This policy does not apply to those sites, and we are not responsible for their content or privacy practices. We encourage you to read the privacy policy of every site you visit.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and revise the “Last updated” date at the top. Where the changes are significant, we will provide a more prominent notice, such as by email. Your continued use of the Service after an update means you accept the revised policy.

14. Contact Us

If you have any questions, comments or requests regarding this Privacy Policy or your personal data, please contact us:

Emberly Books Limited
124-128 City Road, London, England, EC1V 2NX
Email: [email protected]