Ordered by 7 December, home by Christmas.

Amberro: Your child as the hero of their own picture book

Privacy policy

Who is responsible for your data

Amberro, Box D1379, Oder 20, 2491 DC Den Haag, Nederland. Email: kontakt@amberro.de.

We have not appointed a data protection officer; at this size that is not required under Art. 37 GDPR.

What we process, why, and on what basis

The child's photograph. You upload a photo so that the pictures in the book can be drawn from it. The legal basis is Art. 6(1)(b) GDPR: the processing is necessary to perform the contract, because the photo is the input to the product. We do not rely on consent for this, because a consent withdrawn mid-production would make the book impossible.

The photo first becomes one drawn character. Every other page is drawn from that character, not from the photo again.

Another story for the same child. On your order's page and in the email with the finished book we offer you another story. If you order it, we use the photo and the drawn character from your earlier order again, so that you do not have to upload a new photo; for this book too the photo goes to Google (see our processors below). We suggest your earlier dedication again; you can change or delete it. The legal basis is Art. 6(1)(b) GDPR. We then also store the photo and the character with the new order and delete them there 90 days after its delivery, independently of the earlier one. For the note in the email the same applies as for our notes on the hardcover (see below), including your right to object.

The child's name, age and pronoun. For the text of the book. Art. 6(1)(b) GDPR.

Your email address. So we can send you the book and the order confirmation. Art. 6(1)(b) GDPR.

The child's profile. Once you have paid, we keep the child's first name, form of address and age, and the birthday and who gives the book if you filled in those two optional fields. That way your next order for the same child is already filled in, and we may write to you at most once before the next birthday to ask whether you would like another book. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest in offering our own customers another book; for the email, § 7(3) of the German Act against Unfair Competition (UWG) applies as well. The profile lives exactly as long as the last book for that child and goes with it, at the latest one year after delivery. You can object at any time: an email to kontakt@amberro.de is enough and costs you nothing; we then delete the profile and stop writing to you.

The hardcover. If you also order your book printed, you enter your name and the delivery address on the payment page. We need both so that the book can be printed and sent to you, and for that we pass them, together with your email address, to our printer. Art. 6(1)(b) GDPR. Name and address are part of this order's records; the retention periods of tax law apply to them.

Our offers of the hardcover. In the email with your finished book and at most once a few days later, we offer you the same book as a hardcover. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest in offering our own customers a similar product of ours; for the email, § 7(3) UWG applies as well. You can object at any time: every one of these emails contains a link for that, an email to kontakt@amberro.de works just as well, and it costs you nothing. After an objection we keep only your email address and the time of the objection, so that we send you no more offers.

Payment data. We never see or store card details. Payment runs through our payment provider. From it we receive the fact that payment was made, a reference and the country of your billing address or payment account; for the hardcover also the delivery address you enter there (see “The hardcover”). We need the country because VAT depends on it (Art. 6(1)(c) GDPR); it stays with the order records.

Server logs. Technical log data arises when the site is called up. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest in secure operation.

We need the photo, the child's name and your email address for the contract. You do not have to give them, but without them we cannot make the book.

Carrying on without a photo. If you ask for a link on step 1 to carry on later, we keep the child's name, sex and age group for 30 days, until the link has expired (Art. 6(1)(b) GDPR, steps before the contract at your request). The email address we send the link to is not stored in clear text, only as a digest against misuse.

Saving the book. If you save your book on step 3, we also keep the story, the design, the dedication, the edition you chose and a reference to the uploaded photo for 30 days, until the link has expired (Art. 6(1)(b) GDPR). The photo itself is deleted after one day, like every photo without an order. If you expressly ask for a reminder, we store your email address, send you exactly one reminder the next day and then delete the address; if you have ordered in the meantime, we send none (Art. 6(1)(a) GDPR, your consent, which you can withdraw at any time by writing to kontakt@amberro.de).

Who else sees the data

We use service providers who process on our behalf (Art. 28 GDPR):

  • Google (Gemini interface, Google LLC, USA): the drawn character is made there from the photo, and the pages of the book are drawn from that character. If you ask for a dedication to be suggested, that suggestion is written there too. Google does not use your data to train its own models. It does not vanish there without a trace, though: to guard against abuse, Google keeps requests and results for a limited time (currently 55 days; only staff authorised for that purpose may look at them), keeps the book pages drawn there available for up to six weeks, and deletes the drawing we upload after 48 hours. Processing takes place wherever Google runs data centres, including the USA.
  • the storage service that holds the photo and the finished book
  • the host of the website, the operator of our servers in Frankfurt and the provider of the database your order sits in
  • the service that sends our email, which also carries the finished book file
  • if you order a hardcover: the printer Gelato (Norway), which makes the book with partner printers in Europe and sends it to you through a delivery service. It receives your name, the delivery address and your email address for that. Norway is part of the European Economic Area.
  • the payment provider, which acts as its own controller

Transfers outside the EU. Some of these providers process outside the European Economic Area. This takes place on the basis of the European Commission's standard contractual clauses or an adequacy decision. We will send you a copy of these safeguards on request; an email to kontakt@amberro.de is enough.

We do not sell data and we pass nothing on for third-party advertising.

No facial recognition

We do not compare the photo against other photos or against any database, and we do not create biometric templates for the unique identification of a person. No automated decision within the meaning of Art. 22 GDPR takes place.

How long we keep things

The uploaded photo is removed from the upload area when the order is created and belongs from then on to that order. We delete the photo, the drawn character and the pages of the book 90 days after delivery; until then we can make the book up for you again, and after that we no longer need those files. We keep the finished book file for a year, exactly as long as the link in the delivery email works; anyone who has that link can open the book, so only pass it on if you want to. After that the book file goes too. Statutory retention periods apply to invoicing records.

You can ask us to delete it at any time: an email to kontakt@amberro.de is enough. We then delete the photo, the character and the book, and confirm the deletion to you. If you withdraw from the contract the same happens without your having to ask. Invoicing data has to be kept until the statutory periods expire.

We also take a daily backup copy of the order data (not of photos or book files) and keep it for 30 days, so a deleted order can live on in that copy for up to 30 days.

Your rights

You have the right of access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18) and data portability (Art. 20 GDPR). Write to kontakt@amberro.de.

Objection. You can object at any time to processing we base on a legitimate interest (Art. 21 GDPR). For us that is the server logs, the child's profile including the email before the next birthday, and our offers of the hardcover. An email to kontakt@amberro.de is enough.

You may also complain to a data protection supervisory authority.

Cookies and usage measurement

For the purchase itself we set only what is technically necessary (§ 25 (2) no. 2 TDDDG). We set advertising cookies only with your consent; more on this below under „Advertising on Facebook and Instagram“. How many books are ordered and how our pages are used we count in our own database, with no cookie and no other provider. Only rough values are counted: which page or ad someone came from, whether on a phone, tablet or computer, how long and how far a page was viewed, what kind of button was tapped, at which step an order ended and which of its fields had been filled in by then, which notices appeared along the way, whether a photo was too large or could not be read, how the cookie question was answered, and whether “Yes” or “Not really” was tapped under the drawn figure. What you type, your photo and your IP address are not part of these values.

On your first visit we also ask whether we may record how you use our pages. Only if you agree do we load PostHog for that (PostHog, Inc., USA; the analysis runs on servers in Frankfurt), and that service sets cookies of its own. The legal basis is your consent, § 25 (1) TDDDG and Art. 6 (1) (a) GDPR.

What is then recorded is your page views and the course of your visit: mouse movement, clicks, scrolling. What is not recorded is the photo, which appears as an empty block, and everything you type: name, email address, dedication, birthday. On the page holding your order the recording does not run at all. We build no user profile and we do not connect the recording to your order.

Your answer is kept in a cookie („amberro.consent.v2“, six months). You can change it at any time: „Cookie settings“ sits at the bottom of every page. Until you have agreed, not a single connection to PostHog is made.

Advertising on Facebook and Instagram

We advertise our books on Facebook and Instagram. So that these ads are more likely to reach people who are interested in a book, and so that we can see which ad led to an order, we use the Meta Pixel and the Conversions API of Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland („Meta“). Both only if you chose „Yes, gladly“ in the cookie notice or switched on „Advertising“. The legal basis is your consent, § 25 (1) TDDDG and Art. 6 (1) (a) GDPR.

With your consent your browser loads a program from Meta that can set two cookies on our site: „_fbp“ (an identifier of your browser) and, if you came through one of our ads, „_fbc“ (an identifier of that click), each for 90 days. Meta then learns which of our pages you open, whether you upload a photo, whether you go on to payment and whether you pay, with the price wherever money is involved. Added to this are your IP address, the details of your browser and the two identifiers. If you are logged in to Facebook or Instagram, Meta can link your visit to your account. We also send the reports about the photo and the payment from our server to Meta (Conversions API), so that they arrive even if a browser loses them on the way; the report about the purchase we send only from there. For this we keep the IP address, the browser details and the two identifiers with the order until it is paid, for seven days at most. Meta does not get your name, your email address, the child's name or your photo. On the page holding your order the Meta Pixel does not run at all.

We and Meta are jointly responsible for collecting this data on our site and transmitting it to Meta (Art. 26 GDPR). What each of us takes on is set out in Meta's joint controller agreement (facebook.com/legal/controller_addendum): we inform you, and Meta fulfils your rights under Art. 15 to 20 GDPR for the data Meta stores afterwards. You can also contact us, though. What Meta then does with the data is Meta's sole responsibility; it is described in Meta's privacy policy (facebook.com/privacy/policy). Meta may transfer data to the USA. Meta Platforms, Inc. is certified under the EU-US Data Privacy Framework, for which the European Commission found an adequate level of protection on 10 July 2023.

Your answer is kept in a cookie („amberro.consent.v2“, six months). You can withdraw your consent at any time: at the bottom of every page under „Cookie settings“. After that we delete the two cookies, your browser no longer loads Meta's program, and we do not report to Meta what you do on our site from then on. Until you have agreed, the site makes not a single connection to Meta.