Privacy Policy
Lebara is committed to your right to privacy and shall comply with the provisions of the Data Protection Act 1998 in relation to our use of your information. We reserve the right at all times to disclose any information as we deem necessary to satisfy any applicable law, regulation, legal process or governmental request.
Privacy Policy
In this Privacy Policy, references to "we", "us ", “our” and "Lebara" are to Lebara Group B.V. and members of the Lebara Group.
The Lebara Group consists of Lebara Group B.V. and its subsidiary companies, which include its mobile phone companies, Lebara Ltd, embrace-u Ltd and Lebara Services Limited.
This Privacy Policy applies to use of the www.lebara.com web-site, including job applications made on the “Careers” page. Use of any other Lebara Group web-site or service may be subject to a separate privacy policy which must be read in conjunction with the applicable general terms & conditions and any other product or service terms.
"Personal Data" is any data that relates to you as an identified or identifiable individual (and does not include general, statistical, aggregated or anonymised information).
The Personal Data which you supply to us you agree will be true, complete and accurate in all respects and you agree to notify us as soon as possible of any changes to such Personal Data. We will deal with your Personal Data in compliance with current Dutch data protection law.
1. How We Collect Personal Data about You
1.1 We collect Personal Data directly from you when you are asked to provide personal details about yourself, including but not limited to when you:
- register and/or apply for employment with us;
- submit enquiries to us or contact us;
- enter promotions, competitions or prize draws;
- use Lebara products and services; and/or
- take part in market research.
1.2 We collect Personal Data indirectly from you through your interactions with us, including but not limited to when you:
- visit or browse this site or other Lebara Group websites;
- browse or otherwise access the Internet, WAP sites and/or the mobile internet via the services; or
- use our networks.
1.3 We collect Personal Data about you from other sources, including but not limited to credit reference agencies, fraud prevention agencies; and business directories and other commercially or publicly available sources.
2. The Type of Personal Data We Would Collect
2.1 We collect such information as:
- your name;
- e-mail address;
- information contained in any CV you supply to us;
- positions you apply for.
3. Consent
3.1 By using, our web-site, including applying for employment with us, you consent to us processing your Personal Data in accordance with this Privacy Policy and transferring your Personal Data to other countries that may not provide the same level of data protection as the Netherlands, where necessary for providing the products and services you require. If we do make such a transfer, we will put appropriate measures in place to ensure your information is adequately protected at all times.
3.2 In particular, where you have registered or applied for employment, your Personal Data may be transferred to any Lebara Group company.
4. How We Use Your Personal Data
4.1 We may use and analyse information about you in order to:
- provide you with access to parts of this site;
- contact you;
- consider you for positions within Lebara, even if you have not made specific applications for such positions;
- verify that you are an authorised user for security purposes;
- inform you of any service related message or of any new services or functionality (e.g. the introduction of a new messaging service);
- assist us with crime and fraud prevention such as to check your identity, background checks, criminal record checks;
- investigate any complaints or other enquiries that you submit to us;
- enhance and personalise the products and services that we offer you and to develop new products and services;
- analyse markets and produce reports, perform research and statistical analysis and to monitor usage behaviour;
- send information to you from time to time about Lebara, and potentially suitable positions within the Lebara Group, by phone, post, email, text or other means (subject to any objection or preference you may indicate when submitting your details to us);
- disclose your personal information or usage of our services to certain third parties. Please see Section 5 below;
- aggregate information about you and your use of the services with information about other users of the services in order to identify trends ("Aggregated Data"). We may pass Aggregated Data to third parties, such as advertisers, content providers and business partners or prospective business partners, to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.
- analyse information about you including your searching, browsing and location data on a personalised or aggregated basis. We may pass this data to the third parties and we may use this information to provide you with targeted Lebara or third party offers, promotions, adverts or commercial communications.
5. Disclosure of your Information
5.1 We may disclose your information:
- to members of the Lebara Group, our partners, agents and subcontractors (including Mr. Ted Ltd, who operate our TalentLink job portal, prospective partners, agents and subcontractors) who are involved in the delivery of services used or ordered by you;
- to other companies in the Lebara Group, including their respective partners, agents and sub contractors (including their prospective partners, agents and subcontractors);
- to credit reference agencies and fraud prevention agencies;
- in response to a valid, legally compliant request from any public authority or law enforcement agency;
- to third parties for checking details of job applicants and employees;
- where there is a change (or prospective change) in the ownership of Lebara, to new or prospective owners of Lebara. In these circumstances we would require them to keep it confidential;
- where required by law, regulation or legal proceedings;
- where we believe it is necessary to protect Lebara or third party rights and property;
- where you give us false or inaccurate information and we identify or suspect fraud;
- during emergencies when we believe physical safety is at risk; or
- in response to a complaint that that there has been a breach of the services terms & conditions or any other product or service terms of which you have been notified.
5.2 Additional terms and conditions may be presented when signing up for specific products and services.
6. Security Matters
6.1 We recognise that you may be concerned about how we would protect your personal information from misuse and abuse. The Lebara Group has security teams who are constantly reviewing and enhancing our technical, physical and managerial procedures and rules to protect your personal data from unauthorised access, accidental loss and/or destruction.
6.2 Where we have contracted with a third party to provide some part of a service that you have requested, we will ensure that those agents, by written agreement, are required to implement similar security measures and will process your information only as authorised by Lebara to fulfil the service that they have been contracted to provide on our behalf. Those third parties will not be entitled to use your personal data for their own purposes.
6.3 Please be aware that communications over the Internet, such as emails/webmails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered - this is the nature of the World Wide Web/Internet. Lebara cannot accept responsibility for any unauthorised access or loss of personal information that is beyond our control.
7. Retention of Personal Data
7.1 We retain Personal Data only for as long as we need it or as required by law.
8. Accessing your Information
8.1 If you make a job application and register with Lebara, you may verify, update or amend the personal information you have provided to Lebara by contacting ATSTechSupport@lebara.com.
8.2 You may request copies of your personal data held by Lebara, by making a data access request in writing or by e-mail. Provision of such information will be subject to a charge of no more than €4,50 for e-mail responses and €0,23 per page in the case of a hard-copy or postal response, with a maximum of €4,50. Requests should be made in writing and include your name, and proof of your identity (such as a photocopy of your passport, birth certificate or driving licence) and address (for example, a copy of a utility bill or bank statement), and the information you require. If we hold any inaccurate information about you, please tell us and we will correct it.
Our address is: Data Controller
Lebara Group
2nd Floor, 25 Copthall Ave
London
EC2R 7BP
9. Changes to this Policy
We will keep this policy under review and any changes made from time to time will be posted on this page.
10. Security and Protection of Customer Information
10.1 Security
- Passwords
You must not share your password for any services or portal access. Your passwords and the answers to secret questions are your responsibility, and must not be disclosed to any third party. This is also important for your own protection.
- i Data Security Procedures
We are constantly reviewing our procedures to protect your Personal Data from unauthorised access, accidental loss and/or destruction. We may employ third parties, including members of the Lebara Group, to provide services on our behalf. In such cases, if they collect any Personal Data on their own behalf it will be covered by this policy. We do endeavour to ensure that any partners we use apply the same high standards of privacy and security over your Personal Data.
10.2 Users 16 and under
If you are aged 16 or under, please get your parent or guardian's permission before providing any Personal Data. Users without this consent are not allowed to provide us with Personal Data.
10.3 Co-Branded Micro Sites and Third Party Sites
Some web pages and Micro Websites included within Lebara’s websites may be co-branded with third party names, logos, or properties. These Micro Websites are operated or maintained by or on behalf of Lebara. While such third parties are sponsors of these web pages or Micro Websites, Lebara does not share any personal data collected within those web pages or Micro Websites with these third parties unless otherwise stated.
This policy does not apply to third party sites that you may access via our portals. You should therefore ensure that you are familiar with the applicable third party privacy policy before entering any personal information on a third party site.
10.4 Non-EEA Use of Personal Data
The Personal Data you provide to us may be passed to entities outside the European Economic Area (“EEA”), including to Lebara Group companies such as Lebara Australia (Pty) Ltd., and Lebara GmbH in Switzerland, and other third parties in non-EEA countries. Some countries outside the EEA do not have an adequate level of protection. However we will always take steps to ensure that your Personal Data is used by such entities in accordance with this policy.
10.5 Marketing Information from Third Parties
If you choose to receive marketing information from other companies, we will only disclose your Personal Data to these companies where they have undertaken not to use your Personal Data for any purpose other than to provide information to you or other uses to which you have agreed. If you decide that you no longer want to receive information from a particular company, you should contact that company directly. You should be aware that if you subsequently give any Personal Data to another company, the uses to which that information may be put will be determined by that company's privacy policy.
11. Cookies
11.1 Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu
11.2 For a video about cookies visit www.google.co.uk/goodtoknow/data-on-the-web/cookies
11.3 Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improve the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.
11.4 The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide. A list of all the cookies used on this website by category is set out below:
11.5 Strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
Cookie Name | Created By | Purpose |
ClientHeight | Mr. Ted (operator of the TalentLink careers portal) | This cookie stores an application parameter for height of client browser |
ClientWidth | Mr. Ted | This cookie stores an application parameter for width of client browser |
forciblyclosePopUp | Mr. Ted | This cookie stores an application parameter in form: false |
Igip | Mr. Ted | This cookie is set by loadbalancer to link HTTP session with corresponding JBoss instances |
JSESSIONID | Mr. Ted | This cookie allows Lebara’s web servers to respond to your actions on the website or when just browsing the website. |
LastScript | Mr. Ted | This cookie stores the Path to cfm script |
MTTraceAct | Mr. Ted | This cookie is set to trace candidates in applying to process |
NSC_xxx.mfcbsb-npcjmf.dp.vl-IUUQ | Lebara | This cookie allows Lebara’s load balancer to direct your traffic to the same server during your visit for customer experience |
NSC_xxx.mfcbsb-npcjmf.dp.vl-IUUQT | Lebara | This cookie allows Lebara’s load balancer to direct your traffic to the same server during your visit for customer experience |
URLLoginBank | Mr. Ted | This cookie stores the URL of logout page for the current session |
versionOfUserTimer | Mr. Ted | This cookie stores an application parameter in form: 16 |
11.6 Performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages.
These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works
Cookie Name | Created By | Purpose |
__utma, __utmb , __utmc _utmz | Google | These cookies enable the function of Google Analytics. Software. This helps Lebara analyse visitor information such as browser usage, visitor numbers and length of stay.
The data stored by these cookies can be seen only by Google and Lebara and doesn’t include any personal information. |
11.7 Functionality cookies
These cookies allow the website to remember choices you make (such as your user name, login-id, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located.
These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Cookie Name | Created By | Purpose |
LastLogin | Mr. Ted | This cookie stores the last logid ID in session form format |
LastVisit | Mr. Ted | This cookie stores the last visit date and time |
loginId | Lebara | This cookie allows Lebara’s web servers to remember you so you only have to enter your password to login |
SAccountName | Mr. Ted | This cookie stores the name of the last account that has been accessed in TalentLink |
SUserLogin | Mr. Ted | This cookie stores the login of the user who accessed last SAccountName on this machine |
UserLanguage | Mr. Ted | This cookie stores the language chosen as preferred by the last user who accessed TalentLink on this machine. |
12. Disabling Cookies
12.1 If you do not wish to accept our cookies you can decline cookies by using your web Browser. The facilities within your web Browser to allow you to do this will vary from Browser to Browser but they may be found in the "Privacy" or "Cookies" section of the “Help” or "Properties" menu of your Browser. If you require assistance in disabling cookies you should refer to the "help" menu within your Browser. Please note however, that you may not be able to use all of the interactive features of our Website if cookies are disabled. For example, if you block or otherwise reject cookies you will not be able to add items to your shopping basket, proceed to checkout, or use any of our products and services that require you to log in.
12.2 If you leave cookies turned on, remember to sign off when you finish using a shared computer.
12.3 See www.allaboutcookies.org for further information on disabling cookies.
