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Privacy Policy

Here to Inform and Protect

Last updated 19 June 2015


1. About Us
2. Changes to this Privacy Policy
3. Collection of data
4. How is your personal data used?
5. With whom is your personal data shared?
6. The requirements of Data Protection Laws
7. Use of cookies and web beacons
8. Security
9. Reviewing your personal data
10. Children’s information
11. Links to other websites
12. Enforcement of this Privacy Policy

1. About us

1.1 The Lebara Group consists of Lebara B.V. and its subsidiary companies, including (but not limited to) Lebara Limited, Lebara Mobile Limited, Lebara Services Limited and Lebara Media Services Limited.

1.2 The Lebara Group offer a number of services, each of which is offered by the following specific member of the Lebara Group:

  • Lebara Mobile Phones: provided by Lebara Mobile Limited.
  • Lebara Money: provided by Lebara Services Limited.
  • Lebara Talk: provided by Lebara Media Services Limited.
  • Lebara Play: provided by Lebara Media Services Limited.

1.3 Each service above shall be referred to as a Service, all or multiple services above shall be referred to as the Services. Each subsidiary of the Lebara Group listed above shall be referred to as we, us and our (both individually and collectively).

1.4 We are committed to protecting your privacy and personal data. This Privacy and Cookie Policy (Privacy Policy) details the steps we take to protect your personal data when you use any of our Services. It describes the personal data that we collect, the purposes for which we use such data, and your choices regarding our use of it.

1.5 In providing the Service to you our status is that of a data controller and in this capacity we will securely store and process your personal data which you have provided to us. Data controller is a legal term used in the Data Protection Act 1998 (the Act) to signify the person who controls what to do with any given personal data. As data controller we have registered with the Information Commissioner’s Office and our registration numbers are as follows:

  • Lebara Mobile Limited: Z1006140
  • Lebara Services Limited: ZA034904.
  • Lebara Media Services Limited: ZA072052.

1.6 The steps we take to protect your personal data and how you can review and correct your personal data are also covered here. By accessing our Services, you are consenting to the data collection and use practices described in this Privacy Policy.

1.7 When reading this Privacy Policy references to us, we, our and Service will apply to the Service to which you receive and the related entity provided such Service.

2. Changes to this Privacy Policy

2.1 We may occasionally update this Privacy Policy. When we do, we will notify you. However, we recommend that you frequently check this Privacy Policy for any updates.

3. Collection of data

3.1 By using our Services, registering your details with us, contact us and by submitting personal data to us then this Privacy Policy will apply.

3.2 The personal data we collect from you may include:

  • your name;
  • billing address;
  • home address;
  • work address;
  • telephone number;
  • your use of our Services (including but not limited to your management of your account with us, communications made, online searches made, browsing history, web sites visited and location data);
  • company/organisation name;
  • email address;
  • bank details; and
  • payment information.

3.3 You are not required to provide any of this data, but if you do not, we may not be able to provide you the requested services.

3.4 We may also collect data about your from third party agencies such as credit references agencies, fraud prevention agencies, commercially available directories and publicly available sources.

4. How is your personal data used?

4.1 We may use the personal data you provide to us to:

  • provide you with the Services you have signed up for;
  • complete any orders you make with us;
  • contact you where necessary;
  • verify you identity;
  • confirm that you are an authorised user of our Services;
  • inform you of Service related information such as updates and new features;
  • assist us in crime and fraud prevention;
  • process payments made by you;
  • analyse your use to generate market reports and statistical analysis;
  • market our products;
  • improve our Services;
  • recommend goods, services or promotions which may be of interest to you (but only where you have consented to be contacted for such purposes); and
  • send out email alerts you may have signed up for.

4.2 In addition to the above, we may also share your personal data with other our partners as described below.

5. With whom is your personal data shared?

5.1 We may disclose your personal data in the following ways: to the Lebara Group, our partners, sub-contractors, agents and prospective partners who are involved in the provision of our Services;

  • to third parties where you have consented to us doing so;
  • to public bodies, government authorities or the legal industry where required by law, regulation or legal proceedings;
  • to a buyer (or prospective buyer) of the Lebara Group or any of its entities; and
  • to a third party when we are required by law to do so.

5.2 We may disclose depersonalised data (such as aggregated statistics) about the users of our Services in order to describe our sales, customers, traffic patterns and other Service information to prospective partners, advertisers, investors and other reputable third parties and for other lawful purposes, but these statistics will include no personally identifying data.

6. The requirements of Data Protection Laws

6.1 We regard the lawful and correct treatment of your personal data by us as very important to our successful operation, and to maintaining confidence between us and our users. We ensure that our organisation treats personal data lawfully and correctly. To this end we fully endorse and adhere to the 'Data Protection Principles' set out in the Act. In particular, without your consent or first amending this Privacy Policy to reflect any change in our usage of personal data:

  • we will not use your personal data for any purpose that is incompatible with this Privacy Policy;
  • we will only collect sufficient personal data for the uses set out above;
  • we will endeavour to keep your personal data up-to-date;
  • we will not retain your personal data longer than necessary unless required to do so by law;
  • we will operate appropriate technical and organisational processes to protect your personal data against unauthorised or unlawful access or processing and against accidental loss or destruction. The detailed measures we take are described elsewhere in this Privacy Policy; and
  • we will not transfer your personal data to a country outside the European Economic Area unless safeguards are in place to protect your personal data to the standards that apply within the EEA.

7. Use of cookies and web beacons

7.1 Cookies are small files that websites save to your hard drive or to your browser's memory. You have the ability to accept or decline cookies. Most Internet browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies or to notify you when a cookie is being placed on your computer. If you choose to decline cookies, you may not be able to fully experience the features of our Services or other websites that you visit.

7.2 To learn more about cookies and how to disable them we recommend you visit the Information Commissioner’s website. Furthermore, whilst we do not use third party marketing cookies, you can learn more about these and how to delete them here.

7.3 By using our Services you consent to us using the following cookies:

Cookie Purpose More Information
Google Analytics Analytics Google Analytics gives you insights into your website traffic and marketing effectiveness. We help you buy the right keywords, target your best markets, and engage and convert more customers.,Find out more here.
Google Tag Manager Tagging Google Tag Manager is free and easy, leaving more time and money to spend on your marketing campaigns. You manage your tags yourself, with an easy-to-use web interface, rather than forcing you or your IT department to write or rewrite site code. Find out more here.
Crazy Egg Tracking Crazy Egg shows you where people clicked on your site. Our servers will create a report that shows you the clicks on the pages you are tracking. Find out more here.
Optimizely Analytics Optimizely, Inc. offers a range of website analytics services for A/B and multivariate testing purposes. Optimizely partners implement Optimizely as a way to better understand how their website is used. Find out more here.
TagMan Tagging TagMan is the global leader in Tag Management, with the industry's most mature and proven platform for enterprise e-commerce. Since launching the first, independent Tag Management platform in 2007, TagMan has been helping over 100 customers solve tagging, site performance and attribution-related challenges. Find out more here.
Yieldify Analytics Yieldify is a simple to use software solution which allows you to maximise your opt-in rates and revenue from visitors leaving your website. Once you have decided the type of campaign you want to run, Yieldify uses its algorithm learning engine to optimise the Overlay (an interactive message) displayed to the user. The Yieldify Algorithm Learning Engine (Y.A.L.E.) precisely tracks the visitor's mouse movements, speed and user behaviour to determine the style and timing of the overlay. Find out more here.
Session Identifier Tracking This cookie allows us to track user who has logged in.,The cookie expires when the user logs out.
Evercookie Tracking This is a persistent cookie which attempts to track a customer’s machine across all interactions with Lebara Money.,It is used to detect multiple accounts being accessed from a single computer, which is usually fraud.,This is the cookie which allows us to label devices as ‘ubiquitous’.,Your legal team should probably take a look at this. Find out more here.

8. Security

8.1 We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorised access, use, or disclosure. For example, we store the personal data you provide on computer systems with limited access that are located in facilities to which access is limited. Additionally, we ensure that data-processors used by us implement appropriate security measurements.

8.2 Please always be aware that communications over the Internet are not always secure unless even when they have been encrypted. We cannot accept responsibility for any unauthorised access or loss of personal data that is beyond our control.

8.3 It is your responsibility to ensure the security of your password and not to reveal this information to others.

9. Reviewing your personal data

9.1 In some cases, you can review and correct personal data provided through our Service by going to the page on which you provided the data. You may also be able to update your marketing preferences.

9.2 If you are a Lebara Registered Customer, you may verify, update or amend the personal information you have provided to us at any time by clicking on "Edit User Profile" under the website navigation heading "My Lebara". The 'opt-out' on the website allows you to decline our offer to send you marketing information, or from our business partners. You can opt-in of either or both if you change your mind at any time.

9.3 You may request copies of your personal data held by us by making a subject access request in writing using the form provided by Lebara upon request or available for download here. Your form, once completed should be addressed to Lebara’s Legal Department as set out in the standardised form and sent together with proof of your identity (such as a photocopy of your passport, birth certificate or driving licence) and a cheque for £10 to cover the administrative cost of supplying the requested information. Provision of such information will be made with 40 days of our receipt of your request.

9.4 You can help us to maintain the accuracy of your data by notifying us of any change.

10. Children's information

10.1 We do not knowingly collect data from children and we do not target or direct our Services at children / We may collect children’s data. Where we do we will ensure that all processing and data provided is appropriate to the age of the child.

11.1 Our Services may provide you with links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.

12. Enforcement of this Privacy Policy

12.1 If you have questions regarding this policy or our handling of your personal data, please contact us. We will promptly address your concern and strive to reach a satisfactory resolution.

Last updated 19 June 2015