Rebura LTD – PRIVACY NOTICE (EFFECTIVE DATE: 23rd June, 2021)
IMPORTANT NOTICE FOR UK/EU/EEA PERSONS REGARDING BREXIT:
THE UNITED KINGDOM (‘UK’) LEFT THE EUROPEAN UNION (‘EU’) AND EUROPEAN ECONOMIC AREA (‘EEA’) EFFECTIVE 31 JANUARY 2020 (‘BREXIT’) AND A ‘TRANSITION PERIOD’ EXTENDING EU/EEA DATA PROTECTION OBLIGATIONS IN THE UK EXPIRED ON 31 DECEMBER 2020. EFFECTIVE 1 JANUARY 2021 UNTIL 30 APRIL 2021, PER THE TRADE AND COOPERATION AGREEMENT BETWEEN THE EU, EEA, AND UK, 31 DEC. 2020, 2020 O.J. (L 444) 14, PART 7 FINAL PROVISIONS, ART. FINPROV.10A (THE ‘TCA’), TRANSFERS OF EU/EEA PERSONAL DATA TO THE UK SHALL CONTINUE TO FOLLOW THE EU GENERAL DATA PROTECTION REGULATION (EU) 2016/679 AS IT EXISTED ON 31 DECEMBER 2020 (‘GDPR’) UNTIL SUCH TIME AN EU ADEQUACY DECISION IS REACHED REGARDING TRANSFERS OF PERSONAL DATA TO THE UK (THE ‘BRIDGING MECHANISM’). IF AN ADEQUACY DECISION IS NOT REACHED BY 30 APRIL 2021, UNLESS A TCA PARTY OBJECTS, THE BRIDGING MECHANISM IS AUTOMATICALLY EXTENDED UNTIL 30 JUNE 2021. ACCORDINGLY, REBURA LIMITED (AS DEFINED BELOW) SHALL CONTINUE TO FOLLOW THE GDPR (AS DEFINED BELOW) AND NO CHANGES SHALL BE MADE TO THE FOLLOWING PRIVACY NOTICE WITH RESPECT TO THESE DATA TRANSFERS UNTIL SUCH TIME AN ADEQUACY DECISION IS REACHED, THE BRIDGING MECHANISM EXPIRES, OR A FURTHER INTERNATIONAL AGREEMENT IS MADE BETWEEN THE TCA PARTIES. PLEASE CHECK THIS PRIVACY NOTICE PERIODICALLY FOR UPDATES.
I. Introduction. Your privacy is important. This Privacy Notice (the “Privacy Notice,”) together with its addendums, our Terms and Conditions and any other documents referred to in this Privacy Notice or the Terms and Conditions explains how we comply with applicable privacy requirements and sets out minimum standards for how we deal with all personal data that we collect from you, or that you provide to us including via this website and any other websites or applications of Rebura Holdings Limited (United Kingdom) and its subsidiaries (collectively, the “Websites”). Rebura Holdings Limited (United Kingdom), its subsidiaries and our applicable affiliates (collectively, “we,” “us,” “our,” or “Rebura”) include Rebura Limited (United Kingdom), Rebura Inc. (USA), and the Jefferson Frank brand of Frank Recruitment Group Services Limited (United Kingdom). For more information on the privacy practices of our other affiliates not subject to this Privacy Notice including those which operate under Frank Recruitment Group Services Limited (United Kingdom) not mentioned here and its applicable affiliates, please see https://www.frankgroup.com/privacy-notice/.
This Privacy Notice sets out the basis on which we collect, store, use and disclose personal data we receive in writing, through our Websites or through the consulting services that we provide. It therefore applies to personal data that you provide to Rebura telephonically, electronically (including email) and in person.
This information may be updated from time to time, and should be read in the context of any additional specific information such as that provided in privacy policies applicable to specific businesses or local areas as displayed on the relevant Website or distributed to you from time to time.
This Privacy Notice also informs you how we obtain and use information gained by us through your use of the Websites, including by using “cookies” and third party vendors.
Please read the following carefully to understand our views and practices regarding your personal data, how we will treat it and your rights.
This Privacy Notice applies to Rebura globally. The first part of the policy is general and applies globally. The second of the Privacy Notice is comprised of country-specific addendums, and where applicable, Rebura will handle Personal Data relying on certain exemptions under local law. Please be sure to check the addendums below to see if there is one that applies to your country or local jurisdiction. In the event of a conflict between the general part of this Privacy Notice and an addendum, the addendum prevails.
II. Who are we?
Rebura is one of the fastest growing AWS Consulting Partners, AWS End User Computing (EUC) Partners, and AWS Solutions Providers in the world. We are a one-stop-shop for all of your AWS support, cost-optimization, and consulting needs (“AWS Services”).
If you want to contact Rebura or any of its group companies, please click here.
You can contact Rebura’s Chief Privacy Officer (“CPO”) by emailing email@example.com or by sending written correspondences here:
The St. Nicholas Building
St. Nicholas Street
Tyne & Wear U.K. NE1 1RF
Attn: Chief Privacy Officer
III. Who does this Privacy Notice protect?
This Privacy Notice protects individuals throughout the world who access our Websites or receive AWS services from us. This also includes individuals who are employed by an actual, former or prospective Rebura client. A Rebura “client” is one of (a) a business that Rebura has contracted with to provide AWS services or is in the process of doing so, (b) a business that Rebura may solicit with the intention of providing AWS services or (c) a business to whom Rebura may provide relevant AWS services information. Additionally, Rebura acts as the data controller for Personal Data (as defined below) obtained concerning those protected under this Section III. Notwithstanding the forgoing, Rebura and/or Rebura Limited acts as the data processor for Personal Data (as defined below) obtained concerning those protected under this Section III during the provision of AWS services.
IV. What information will we collect?
Some of the data that we collect and receive from you is personal data which means that it is information that could personally identify you (“Personal Data” or “PII”). The Personal Data that we may collect from all users of our Websites and users of our recruitment services may include any of the following:
V. Why do we process your Personal Data?
Generally, we use your Personal Data for our business and activities, and in our efforts to expand and improve our business. Examples include:
A. All users of the Websites and/or our services
a) To provide our AWS services to you, your employer or your company;
b) To facilitate the AWS services process, including but not limited to:
B. Entities or individuals who solicit or participate in AWS Consulting
VI. Who do we send your Personal Data to?
A. All users of the Websites and/or our services
VII. What will Rebura do if my Personal Data is breached?
Rebura has put in place reasonable technical, administrative and physical safeguards intended to prevent a breach of your Personal Data. That being said, Rebura cannot guarantee that your Personal Data will not be breached.
A breach can take many forms, including, without limitation, the loss of your Personal Data or the unauthorized access to, disclosure, modification, copying and transfer of your Personal Data.
Once Rebura becomes aware of the breach, Rebura will take reasonable steps to isolate the breach, stop the breach, determine the root cause, determine the Personal Data breached, fix the root cause and determine if notice to you and/or the appropriate government agency(ies) is required. Rebura will comply with all applicable law in reacting to, and dealing with, a breach of Personal Data.
If you believe, for any reason, that your Personal Data has been breached while in Rebura’s care, custody or control, please email Rebura immediately at firstname.lastname@example.org.
If Rebura obtains your Personal Data from someone other than you, this Privacy Notice includes all information required under applicable law except that Rebura shall not provide you with this information if you already possess this information, providing you with such information is against (or not mandatory under) applicable law, is subject to an obligation of professional secrecy, proves impossible, would involve a disproportionate effort or would render impossible or seriously impair the achievement of the objectives of the processing, in which case, Rebura shall take appropriate measures to protect your rights, freedoms and legitimate interests. If you have any questions, please contact Rebura at email@example.com.
VIII. Will my Personal Data be transferred to another country?
Yes, Rebura may transfer your Personal Data to the categories of third parties described in this Privacy Notice, some of whom are located outside of the country in which you provided your Personal Data to Rebura or the country of collection.
If so, Rebura will take reasonable steps to ensure that your Personal Data is protected and treated in accordance with this Privacy Notice and local applicable law. The countries where Rebura may transfer your Personal Data will have varying levels of data security practices and laws, some of which may be less stringent or protective than your country. Rebura will use all reasonable efforts to require that any of its suppliers and vendors who receive your Personal Data are contractually bound to (a) keep your Personal Data confidential and (b) take, at a minimum, reasonable efforts to maintain the privacy and security of your Personal Data.
Under certain circumstances, Rebura may share your Personal Data with one or more of its group companies who may be located in a country other than yours or other than the country in which Rebura collected your Personal Data. In such cases, Rebura will comply with applicable laws and its Intercompany Data Processing Agreements (“DPAs”). The DPAs are incorporated by reference into this Privacy Notice.
IX. How long will Rebura store my Personal Data for?
We are required by applicable law to store your Personal Data for as long as is necessary to comply with our legal, regulatory and contractual obligations. This period of time will vary based on the law in your country and in the country where Rebura stores your Personal Data.
In addition, Rebura will keep your Personal Data for the identified purposes until it reasonably believes that it no longer needs it, that there is no reasonable chance that you, your employer or your company will do business with Rebura, and there is no reason to believe that we will need the Personal Data for any special circumstances such as the issuance or defence of legal proceedings, audit, investigation or collections.
X. Sending Rebura Personal Data over the internet
Your Personal Data is held on servers hosted by us, our internet services providers or third party vendors with whom Rebura has a contract. The transmission of information via the internet is not completely secure. Although we will take the efforts set forth in the Privacy Notice to protect your Personal Data, we cannot guarantee the security of any data transmitted through or to our Websites. Any transmission of data by you to us over the internet is at your own risk.
XI. How we collect and aggregate information about visitors to our Websites
We also collect information about the way job seekers and visitors use the Websites in order to improve our services, to understand our users better, and to determine aggregate trends, most popular pages, etc. By using the Websites, you agree that we may share de-identified aggregate data with selected third parties to assist with these purposes. We may also undertake marketing profiling to help us identify candidates, clients, or jobs which may be of interest to you. We may process Personal Data that you submit to us through the Websites under one or more of the permissible bases for processing Personal Data set forth in the Privacy Notice.
XII. Technology and Tools
Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content. Those tools include services from search engines and other companies that help us to tailor our products and services to better suit our clients and potential clients. Search engines provide facilities to allow you to indicate your preferences in relation to the use of those tools in connection with computers and other devices controlled or used by you.
We also set out further information below about Cookies and Web Beacons.
A. What are cookies?
A “cookie” is a piece of information that is stored on your computer’s hard drive and which records your navigation of a website so that, when you revisit that website, it can present tailored options to you based upon the stored information about your last visit. You can normally alter the settings of your browser to prevent acceptance of cookies.
Cookies are used are many, many websites, including Rebura’s Websites.
We use “cookies” and plug ins to: (1) make the Websites function properly and as a user would normally expect of a commercial website; and (2) monitor Website user traffic patterns and Website usage. Our use of these tools helps us to understand how our users use our Websites so that we can develop and improve the design, layout and functionality of the Websites and to provide more efficient and relevant services to you.
C. There are different kinds of cookies with different functions.
The cookies we use are explained below:
The Rebura Websites use personalisation cookies to help us to advertise jobs that we think may be of interest to you. These cookies are persistent and mean that when you log in, or return to, the particular Rebura Website, you may see advertising for jobs that are similar to jobs that you have previously browsed.
For information on how to reject these personalisation cookies, see Section E below
D. Cookies and Plug-ins set by Rebura or Third Parties used by Rebura
For our Rebura Websites generally:
This cookie is set by doubleclick.net. The purpose of the cookie is to determine if the user’s browser supports cookies.
This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.
The cookie is set by Facebook to show relevant advertisements to the users and measure and improve the advertisements. The cookie also tracks the behaviour of the user across the web on sites that have Facebook pixel or Facebook social plugin.
This cookie is a browser ID cookie set by Linked share Buttons and ad tags.
This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors.
This cookie is installed by Google Analytics. The cookie is used to store information of how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected including the number visitors, the source where they have come from, and the pages visited in an anonymous form.
This cookie is set by the Google Analytics. This cookie is used for tracking the signup commissions via affiliate program.
This is set by Hotjar to identify a new user’s first session. It stores a true/false value, indicating whether this was the first time Hotjar saw this user. It is used by Recording filters to identify new user sessions.
The cookie is set when the visitor is logged in as a Pardot user.
This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.
This cookie is set by LinkedIn. The purpose of the cookie is to enable LinkedIn functionalities on the page.
This cookie is set by LinkedIn and used for routing.
This cookie is used to store the language preferences of a user to serve up content in that stored language the next time user visit the website.
This cookie is set by Hotjar. This cookie is set when the client first lands on a page with the Hotjar script. It is used to persist the random user ID, unique to that site on the browser. This ensures that behaviour in subsequent visits to the same site will be attributed to the same user ID.
LinkedIn – Used to track visitors on multiple websites, in order to present relevant advertisement based on the visitor’s preferences.
This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. It appears to be a variation of the _gat cookie which is used to limit the amount of data recorded by Google on high traffic volume websites.
E. How to reject cookies
If you don’t wish to receive cookies that are not strictly necessary to perform basic features of our Websites, you may choose to opt out of them by selecting the appropriate box at the bottom of any of the Websites, in a link called “Cookie Preferences.”
Note that most web browsers will accept cookies, but if you would rather that we did not collect data in this way you can choose to accept or reject some or all cookies in your browser’s privacy settings. Rejecting all cookies means that certain features of the Website(s) cannot then be provided to you and accordingly you may not be able to take full advantage of all our Websites’ features. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences.
For more information generally on cookies, including how to disable them or change cookies’ settings, please refer to aboutcookies.org (http://www.allaboutcookies.org/). You will also find details on how to delete cookies from your computer. Find out how to manage cookies on popular browsers:
To find information relating to other browsers, visit the browser developer’s website.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
F. Web Beacons
Rebura may use or include web beacons in emails or other electronic communications that Rebura sends to you. We use web beacons to help us analyze the effectiveness of our communications to you. For example, we may use web beacons to understand when and if you opened our email, how many times you opened the email, if you have forwarded the email to another email address, or if you clicked on a link in an email that we sent to you. The web beacons do not collect or give us your PII but they do provide information to us about your actions after receiving a communication from us. If you would like to stop receiving emails with web beacons from us, you may unsubscribe by clicking the “Unsubscribe” link in the email or by emailing firstname.lastname@example.org. However, you may receive auto generated emails from Rebura after you create an account on the Websites or take some other affirmative action on the Websites which contain web beacons but do not contain an “Unsubscribe” link. In those cases, just simply email email@example.com if you would like to stop receiving emails from Rebura with web beacons.
Also, Rebura works with third parties to help manage online advertising who embed web beacons in online job postings and job advertisements that Rebura requests these third parties to post online. These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by a third party such as Google Analytics. These files enable Google Analytics to recognize a unique cookie on your web browser, which in turn enables third parties to learn which advertisements bring users to our Websites or websites on which third parties placed our advertisements. The cookie on your web browser was placed by third party advertisers who work with Google Analytics. With both cookies and web beacon technology, the information that Google Analytics (either directly, see cookie/plug-in chart above) or third parties collects and shares with us is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. For more information about Google Analytics, including information about how to opt out of these technologies, go to www.google-analytics.com.
XIII. Links to other websites
Please note that clicking on links and banner advertisements and RSS (Rich Site Summary) feeds may result in your transfer to another website, where data privacy practices may be different than described in this Privacy Notice. It is your responsibility to check other website privacy notices and policies to ensure that you are happy for your personal information, including Personal Data, to be used in accordance with those third parties’ privacy notices and policies. We accept no responsibility for, and have no control over, third party websites, links, adverts or RSS feeds or information that is submitted to or collected by third parties.
XIV. Changes to our Privacy Notice
We reserve the right to change this Privacy Notice from time to time by updating this Privacy Notice on our website. Any changes to this Privacy Notice or any of its addendums will be posted on this Website so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We encourage you to check this Website frequently for updates. Your continued use of this Website or any Rebura services shall constitute your acceptance of the revised Privacy Notice.
Rebura will interpret and enforce this Privacy Notice in accordance with all applicable law.
This Privacy Notice was updated on 20th April 2018.
This Privacy Notice was last updated on 23rd June 2021.
 The “Purposes” listed in this chart are brief summaries and not intended to explain all or every reason why Rebura uses the particular cookie or plug in. If you have any questions about the cookie table, please click the link to the cookie creator’s website and/or email Rebura at firstname.lastname@example.org.
UNITED KINGDOM AND EUROPEAN ECONOMIC AREA ADDENDUM
UNITED STATES OF AMERICA ADDENDUM
I. If you would like a copy of Rebura’s US comprehensive information security program, please email Rebura’s CPO at email@example.com.
If Rebura receives a “Do Not Track” signal or request from a web browser, Rebura will not honor such request or signal. Rebura has taken this position in part to provide you with a personalized and efficient experience on the Websites.
As discussed in this Privacy Notice, there are third parties who conduct tracking on the Websites.
Information about web beacons used by Rebura and third parties with whom it contracts can be found in Section XII.F of the Privacy Notice above.
II. For information on Rebura’s transfers of EEA/UK/Swiss data to the U.S., see the section entitled “ In addition to the forgoing, for compliance with applicable law, the following terms, to which Rebura reserves the right to revise from time to time without notice, shall be incorporated by reference where these terms are required in client contracts:
(A). In the event Rebura transfers to client or any of its affiliates, or provides client or any of its affiliates with access to any Personal Data (as defined for this Section II below) of European Union or Switzerland residents, including employees of Rebura or its affiliates and actual or prospective Rebura client contacts, and client maintains, receives, has access to, stores, uses or processes such Personal Data in the United States, client shall comply with data protection, data security and confidentiality requirements at least as strong as those set forth in the Privacy Shield Principles issued by the U.S. Department of Commerce, as revised from time to time (collectively, the “Principles”) During the term of such contracts and while client creates, receives, maintains, stores, uses, processes or disseminates any Personal Data, client shall:
(B) Upon the termination or expiration of the applicable client contract, client shall, at Rebura’s option, return all Personal Data to Rebura as applicable or permanently destroy all Personal Data (and all copies and derivative works thereof) in its care, custody or control except for any Personal Data that applicable law, if any, requires client to maintain (“Archival Personal Data”). With respect to any Archival Personal Data, client’s obligations and requirements under this Section II shall remain in full force and effect for as long as such Archival Personal Data remains in client’s care, custody or control.
(C) If client forwards or gives access to any of the Personal Data to any third party at any time, including any subprocessor or controller of client, client shall ensure that its written contract with such third party contains these terms, as applicable.
(D) For purposes of this Section II, the term “Personal Data” shall have the same meaning ascribed to that term as in the Principles which can be found at https://www.privacyshield.gov/servlet/servlet.FileDownload?file=015t00000004qAg as revised from time to time.