Privacy Policy

This statement is made by Ambassadeurs Group Ltd (AG) pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking Statement for the financial year ending 31 December 2021.

Contents

1: Introduction1
2: Cookies  1
3: Categories of personal data2
4: Data we may process under a legal obligation 3
5: Data we may process under our contract with you3
6: Data We may Process with Your Specific Consent3
7: Data we may process for a legitimate interest 4
8: Where your personal data may be stored 5
9: Access to your Personal Data6
10: How long do we keep your personal data?6
11: Who do we disclose your personal data to?6
12: Changes to this policy8
13: Your rights8
14: Contact us8
  APPENDIX 1 – “Ambassadeursgroup” subsidiaries9
  1. Introduction

The Proprietor and Owner of the Ambassadeurs Group is Ambassadeurs Group Limited (“Ambassadeurs Group”, “AG, we”, “our” or “us”). These privacy terms relate to your use of all websites, applications and services offered by the Ambassadeurs Group and its group of companies (“subsidiaries”) (a list of our trading entities is set out in the Annex to this notice); accordingly, the terms of this policy will govern the use of your personal data by us in addition to the separate Privacy Policies in force by these companies (which may be dictated by local laws to the company in question) which does not incorporate this notice.

The Ambassadeurs Group Limited registered address 5 Hamilton Place, London, W1J 7ED and our company registration no. is 13422044. We are registered with the Information Commissioner’s Office as a Data Controller (No: ZB138202) and as such, we are required to collect, process and disclose certain personal data. 

As we are a group of companies, any of the members of our group may individually be a data controller for the purposes of applicable data protection legislation. In certain circumstances more than one company in our group may be a controller jointly with another member or members of our subsidiaries. As controller, a company listed in the Annex hereto is responsible for ensuring that personal data obtained is used fairly and lawfully.

We want all our clients and participants in services offered (“you”) to know that we value your privacy and personal data just as much as you do. We apply the highest standards to ensure your personal data is secure, and we always comply with applicable data protection laws.

In this privacy policy (the “Policy”) we not only want to advise you of your rights, but also explain how we respect them.  Any personal data you provide to us directly or via virtue of acquiring services from our subsidiaries, jointly or separately will be processed only in accordance with this Policy. This Policy and AG’s collection, processing, use or disclosure of personal data shall be governed by and construed in accordance with English law.

Personal data is any information relating to you from which:

  • you can be identified from the information in question; or
  • you can be indirectly identified from that information in combination with other information.

Sensitive Data includes information concerning:

Racial or ethnic origin, Political opinions, Religious and philosophical beliefs, Trade union membership, Genetic data, Biometric data, Data concerning health, Sex life and sexual orientation.

The only sensitive type of data we process about you is that obtain and informed of via our subsidiaries, which for example, is Biometric data for the purpose of uniquely identifying you during registration / onboarding processes relating to our services. 

  1. Cookies

Our website requires the use of files containing small amounts of data that exchange between your computer’s browser and our web server.  They are known as “cookies” and are used for a number of functions such as remembering who you are and your choices, either for that session or for when you return to our website.  Some cookies are required for our website to work but only last as long as your visit.   As a result, you cannot opt out of those.  All of the other cookies we like to use you can control, though some functionality may be limited by your choice.   You can change your cookie preferences at any time.

  1. Categories of personal data

The table below sets out the categories of data we use, what they can include, and the period for which we retain that data (from the date of the last relevant activity).  Some sections may include categories from another section, particularly your contacts details and identifiers. Any information received from our subsidiaries in processed strictly in accordance with the purposes as defined within this and the relevant independent Privacy Policies.

CategoryWhy is this data collected or shared by our subsidiaries?Data IncludedRetention Period
Client personal and contact informationTo be able to make available, communicate to you and fulfil our services requested, directly from AG.                                                                                                                                                                                                                           To communicate with you about your experiences with AG. To ensure best working practices are being followed by us any of our subsidiaries by way of quality control mechanisms and or legal / regulatory auditing.Name; date of birth; identity documentation (image); gender; nationality; biometric data; address; email contact; telephone contact; visits; interactions with us (including emails and phone calls).6 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.
Mailing List (Ad-hoc information about, for example, interests, special occasions, special requests.)To arrange or provide services tailored to your requirements.                                                                                                                                                                                                                                                                                                                                                                                                                                                To communicate in a relevant way.
Name, postal address, email address, telephone number, age, gender, occupation, email contact; telephone contact; lifestyle and social circumstances; preferences.
6 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.
Current and Historic InformationTo arrange or provide services tailored to your requirements.                                                                                                                                                                                                                                                                                                                                                                                                                                                          For purposes of accounting, reporting, analysis and, as may be required, lawful or regulatory disclosures.                                                                                                                                                                                                                                                                                                                                                                                                          To communicate in a relevant way.Service data, visits, transactions, complaints and disputes, financial transactions, behaviours. and geographical locations.
6 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.
Finance and Payment InformationTo be able to process your payments.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      To meet any auditing, lawful or regulatory requirement.
Name; date of birth; identity documentation (passport / visa); gender; nationality; biometric data; residential address; concessions; invoices; applications; financial transaction history; bank account details; bank card details; debt information; payment services, Winnings, applications, cheques awaiting clearance, affordability history; 3rd party affordability referencing data; 3rd party adverse media referencing data, information from 3rd party debt collection and tracing agencies, and other authorised agents, data from regulatory or government authorities,  lifestyle and social circumstances, occupation, employment and educational history, payment services and other details of products and services you have purchased from us.7 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.
MarketingTo make you aware of new products, services, and promotionsincluding those of our partners and subsidiaries from time to time which we feel would be useful to you. (All Marketing preferences are based on you opting in and may be managed at any time)Name, residential address, date of birth, nationality, biometric data, email contact, telephone contact, travel and geographic movement information, preferences, interactions with us (including emails and phone calls), behaviours, complaints, and issues.
2 years or deletion on request.
Complaints & issuesTo assist you in relation to any arrangements and to handle complaints.Complaints and evidence of unlawful activities.6 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.
Audio recordingsStaff Development, identifying errors and to enable the effective resolution of complaints and issues.Telephone audio recordings.
6 years or as defined by the Privacy Policy in force by any of the AG subsidiaries.

These are the maximum retention periods but where it is appropriate, we may apply lesser retention periods.

  1. Data we may process under a legal obligation

Basis: Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Type of Data: Client Personal and Contact Information, Current and Historic Information; Mailing List; Finance and Payment Information, Complaints & Issues and Audio Recordings.

When Data is Processed: We may collect and process this personal data in the following circumstances:

  • When you apply for services or when you update your personal details or ID documents with us.
  • When we verify your identity and personal details, or when we conduct security, due diligence, dispute resolutions and/or compliance and auditing checks.

Your Rights: As we are under a legal duty to process this data you some of your rights (see below) may not apply. 

  1. Data we may process under our contract with you

Basis:  When you become a participant of our services, you enter into a contract with us directly or via one of our subsidiaries indirectly. This contract includes the either our or the subsidiaries terms and conditions and you have to agree to the respective privacy policy. We would only use your personal data to provide our services to you; including to maintain our accounts and records, to provide customer services.

Type of Data:  Client Personal and Contact Information, Current and Historic Information; Mailing List; Finance and Payment Information, Complaints & Issues and Audio Recordings.

When Data is Processed:  We may collect and process this data:

  • When you apply for services or when you update your personal details or ID documents with us.
  • When we verify your identity and personal details, or when we conduct lawful and or regulatory checks (including checks with 3rd parties).
  • When you contact us, request services, report a problem, or wish to make a complaint.

Your Rights:  While you may request that your personal data be removed from our live systems (which will also suspend or terminate your account) we may nonetheless retain a separate secure copy in order to deal with any complaints or contractual issues. 

  1. Data we may process with your specific consent

Basis:  Where you have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent to us using your personal data at any time, and to request that we delete it. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have a basis for doing so in law. You also have the right to object to our using your personal data for specific purposes. In each case, please contact us (see section 14).

Type of Data:  Marketing.

When Data is Processed:  We may collect and process this data:

  • If you give us your express permission when applying for services or if you subsequently update your marketing preferences.

Your Rights:  You are entitled to qualify, vary or withdraw your consent in relation to marketing whenever you want to. You can do so either via your online account details or by contacting us direct. 

  1. Data we may process for a legitimate interest

Basis:  Legitimate interest” means our interest in conducting and managing our businesses to enhance our services and experiences for our clients, users and contacts. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). 

Type of Data:  Client Personal and Contact Information, Current and Historic Information; Mailing List; Finance and Payment Information, Complaints & Issues and Audio Recordings.

The legitimate interests that we pursue include:

  • It is in our legitimate interests to provide our clients with a fast and professional manner of performing their services. We do so in a manner that is consistent with applicable regulations and standards.
  • Developing and improving our services and keeping in touch with our clients and potential clients, is a key part of our business relationship development. We also have an interest in identifying and developing new opportunities and suppliers for our services.
  • Understanding and maintaining the awareness of the various industries that we operate in: this includes the various developments in these industries and the opportunities that they present to us.
  • We seek to earn revenue by communicating and marketing our services to our clients and developing and increasing our awareness and understanding of our services.
  • Some of the ways that we use personal data are justified if they are necessary to protect our systems and data.
  • Reorganising our business operations and corporate structure.
  • Fraud prevention.
  • Disclosure to appropriate authorities of potentially criminal acts or security threats.
  • Engaging personnel/suppliers/subcontractors
  • Ensuring we operate suitable and appropriate IT systems and website content.

We may also use your personal information in the following situations, which are likely to be rare:

  • Where we need to protect your interests (or someone else’s interests).
  • Where it is needed in the public interest.

Your Rights:  Whilst you are entitled to correct incorrect personal data, if you do not agree to this processing then this may result in your services being terminated.

  1. Where your personal data may bestored

The information that you provide to us will be held in our systems, which are located on our or our subsidiaries registered premises or those of an appointed third party. We are based in the United Kingdom and your information will be accessed and used here and elsewhere in the European Economic Area (EEA) where we enable the provision of the contracted services.

While countries within the EEA all ensure a high standard of data protection law, some parts of the world may not provide the same level of legal protection of your personal data. In each case, your data may, for purposes described in this notice or otherwise approved by you, be transferred to, processed by and stored by persons operating outside of the EEA and the third party may require access to all or some of your data. For example:

  • other AG trading companies based outside the EEA may need to use data in accordance with this notice;
  • our staff, suppliers or agents located outside of the EEA may need to access and process personal data to fulfil requested and or contracted services or provide other support services;
  • we may use cloud-based technology hosted outside of the EEA to host some of our applications;
  • we may use service providers based outside of the EEA to help us support some of our information technology infrastructure and these service providers may need to access your personal data in order to provide and support that infrastructure.

When we send personal data outside of the EEA we take steps to put in place appropriate safeguards to protect the information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed in accordance with applicable data protection laws. We protect your personal data, for example, by:

  • transferring to a jurisdiction which the European Commission recognises as providing adequate protection for the rights and freedoms of data subjects in connection with the processing of their personal data; 
  • where possible, putting in place standard contractual clauses (SCC`s) in accordance with European Commission decisions on transferring personal data).
  • requiring all Les Ambassadeurs Online trading companies to be subject to group data protection policies, designed to protect data in accordance with EU data protection law;
  • ensuring access controls which limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know; and
  • ensuring they will only process your personal information on our instructions, for the reasons we specify.

We may also from time to time rely on one or more of the ‘derogations’ available in applicable data protection laws, for example:

  • The transfer is necessary for the establishment, exercise or defence of legal claims; or
  • We have the individual’s explicit consent; or
  • The transfer is necessary for the conclusion or performance of a contract in the interest of the individual concerned, and we are party to that contract;
  • The transfer is necessary in order to perform a contract between us and the individual concerned, or the implementation of pre-contractual measures taken at the individual’s request.

We may also be compelled by law to disclose your personal data to a third party and will have limited control over how it is protected by that party in such circumstances.

9) Access to your personal data

When you ask to see a copy of your personal data as permitted under data protection laws we will supply you with all the personal data to which you are entitled, promptly and normally no later than one month after the receipt of your data subject access request. In rare cases, where the requests are complex or contain multiple requests, the period of compliance may be extended by a further two months, but we will write to you and explain why any extension is required within one month of your request.

We will want to ensure that we have properly identified anyone making a data subject access request and may therefore ask to see additional identification.

Any access request is normally free, although in some cases we may charge a reasonable fee based purely on our administrative costs when a request is clearly unfounded, is made excessively, or is made repetitively.

You may also have the right to Data Portability which allows you to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without affecting its usability. If you wish to exercise this right, we will transmit such data to you in a machine-readable code where it is technically feasible to do so. 

10) How long do we keep your personal data?

Generally, we comply with the retention periods specified above although there may be exceptions, such as where there is an ongoing legal enquiry.  Your personal data may also be subject to increasing internal restrictions on accessing.  For example, personal data may be removed from front office functions and only accessible by senior management with specific reasons.

11) Who do we disclose your personal data to?

Your data may be required to be made accessible to the Ambassadeurs Group for the purposes set out in this notice (for example, information and customer relationship management; software and service compatibility and improvements; and to provide you with any information, applications or services that you have requested).

We may also share some of your information with the following categories of third parties:

  • authorised representatives or agents acting on our behalf with respect to the promotion of our services in particular territories;
  • suppliers where necessary, in performance of services which you have contracted, with or through us (which may include sharing data in order to perform and process payments associated with performance of such services);
  • information technology companies undertaking services for us in connection with maintenance, support, development or enhancement of our websites or our other information technology platforms and infrastructure;
  • third parties that we engage to perform market surveys/client feedback surveys, subject to your selected preferences;
  • third parties which we engage to securely host communication services (emails and SMS) and act as suppliers to distribute our notifications and other marketing communications on our behalf, both where you have requested information and where we believe that information will be of interest to you;
  • companies used to facilitate payment transactions arising from engagement of our services;
  • credit reference agencies for the purposes of supporting mechanisms which asset us in safer gambling and affordability assessments;
  • fraud prevention agencies;
  • recruitment agencies or website recruitment platforms in the context employment;
  • law enforcement agencies, regulators or other applicable third parties, where necessary to enable us to comply with our regulatory and legal obligations (including statutory or regulatory reporting or the detection or prevention of unlawful acts ), or where necessary to assist them in the conduct of their investigations;
  • authorised third parties engaged to support us in performing customer and enhanced customer due diligence checks;
  • our clients (if you are a supplier), in the course of performing any engagement for services;
  • relevant third parties in the context of actual or potential legal proceedings (for example in response to a court order, enforcement of the terms of a contract and debt recovery);
  • our own professional advisors and auditors for the purpose of seeking professional advice or to meet our legal, regulatory and auditing responsibilities; and 
  • another organisation if we sell or buy (or negotiate to sell or buy) any of our companies, business or assets;

We may compile statistics about the use of our websites including data on traffic, usage patterns, user numbers, and other information. All such data will be anonymised and will not include any data which can be used to identify you either by itself or when combined with other data. We may share non-personally identifiable information about the use of our website, applications, products or services publicly or with third parties, but this will not include information that can be used to identify you.

We do not sell personal data to third parties for marketing purposes.

Your Rights:  You have the right to object to this and to correct any incorrect data.  Services may be conditional on allowing us to share this personal data.

12) Changes to this policy

From time to time we will need to update, change or supplement this Policy, including by altering the types of personal data that may be collected, processed or shared. If this happens, we will update this Policy on our website, in our literature, and we will make contact (normally by email) to inform you of any updates to this Policy before such changes come into effect.  If you do not agree to these changes then you will have to inform us.

Ambassadeurs Group, 5 Hamilton Place, London, W1J 7ED.

13) Your rights

You have the following rights:

  • The right to be informed: This privacy policy is intended to meet our obligation to provide “fair processing information”. 
  • The right of access: You have the right at any time to ask to see a copy of the personal data we hold about you.
  • The right to withdraw consent:  Where you have given your consent to our processing you may withdraw this at any time.
  • The right to rectification and data quality:  If your personal data is incorrect or incomplete then you may ask us to remedy that.
  • The right to erasure including retention and disposal:  You may ask us to delete or remove your personal data where there is no compelling reason for its continued processing but this may affect any services, we provide to you which relies on that personal data.
  • The right to restrict processing:  Where you have highlighted an issue with the data.
  • The right to data portability:  This allows you to request that your personal data be shared with other processors at your request.
  • The right to object:  Where you have an objection to our processing you may do so.

You may also have the right to lodge a complaint with the Information Commissioner’s Office if you believe we are in breach of our legal obligations under data protection laws.

14) Contact Us

If you wish to exercise any of your Data Protection Rights, if you have any questions, complaints, or comments regarding this Policy, please contact us:

  • by post to: The Data Protection Officer (DPO), Ambassadeurs Group, 5 Hamilton Place, London, W1J 7ED.
  • by email to: The Data Protection Officer (DPO) at DPO@Ambassadeurs.com.

To further query your rights regarding your personal data, to lodge a complaint, raise a concern about how your complaint has been handled and / or appeal against any decision made following your complaint, in accordance with your rights, you may contact the Information Commissioner’s Office (ICO): https://ico.org.uk/

APPENDIX 1 – “Ambassadeursgroup”subsidiaries

Les Ambassadeurs Club Limited 

Les Ambassadeurs Club registered address is 5 Hamilton Place, London W1J 7ED, and our company registration no. is 02708889.

Les Ambassadeurs Online Limited 

Les Ambassadeurs Online registered address is 5 Hamilton Place, London W1J 7ED, and our company registration no. is 11183191

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