Privacy Policy

De-Mbarukas and its affiliates, subsidiaries, trusted business partners or alliances, agents, subcontractors, third-party vendors or newly acquired companies (also referred to below as “we”, “us” and “our”) is a privacy conscious organization and strongly committed to respecting, protecting and processing personal data responsibly in compliance with applicable data protection laws and this Privacy Policy.

This Privacy Policy and its sub-pages describe our general privacy and data processing practices, where we collect personal data gathered (1) through use of our websites or mobile apps that post, display or link to this Privacy Policy (“Sites”), (2) through downloadable applications accessed from mobile devices with respect to which this Privacy Policy is posted or linked (“Mobile Apps”), (3) from individuals who engage regarding our or our clients services or individuals within our clients’, business partners’, suppliers’ and other organizations with which we have or contemplate a business relationship (“Services”), or (4) by any other mode of interacting with you relating to our communications, such as online or offline newsletters and magazines (“Communication”) as referenced in this Privacy Policy.

This Privacy Policy also explains the choices and rights individuals have regarding their personal data. We also have implemented global policies, along with standards and procedures, as part of our Global Data Protection & ePrivacy Program for our consistent handling, sharing and protecting personal data. Some of our other websites may include additional or different privacy policies, and if a different privacy policy applies, we will disclose this to you.

Information collection
We may collect information, including personal data, that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with our existing or potential employees, clients, client constituents or customers, business contacts, strategic alliances, suppliers, shareholders and Site users.

Generally, we collect the below-mentioned information and personal data categories. If the data we collect are not listed in this Privacy Policy, we will give individuals, when required by law, appropriate notice of which other data will be collected and how they will be used.

Except for certain information that is required by law, your decision to provide any personal data to us is voluntary. You will therefore not be subject to adverse consequences if you do not wish to provide us with your personal data. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Policy, and you may not be able to use certain tools and systems which require the use of such personal data.

Personal data excludes: publicly available information from government records, deidentified or aggregated information, and automated non-identifiable data that cannot be linked back to an individual.

Information sources
Personal data may be collected either directly from you or indirectly from certain third parties (e.g., affiliates, public authorities, public websites and social media, suppliers and vendors) when you:

– access our Services.
– provide personal data by filling in Site forms (e.g., registering an online account, subscribing to Services, newsletters and alerts, registering for a conference or requesting further information).
– submit our online forms or communicate with us on email.
– submit reviews or participate in surveys.
– upload or post any comments or other content to our Sites, on social media, or blogs.
– interact with us on social media.
– sign up for our mailing lists, register for events we host or sponsor, submit information as part of certain online Services, or otherwise provide us information through the Sites.
– participate in a prize promotion or contest, or related event.
– use the Site for online career resources.
– are an individual employee or constituent of our clients and other companies with which we have an existing business relationship.
– have information on public sources, including, for example, content made public at social media websites.

Purposes, legal basis and use
We may use or disclose the personal data we collect only where one or more of the below outlined principal legal grounds and specific business purpose justifications exist.

Where we rely on our legitimate interests for a given purpose, it is our understanding that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on our data processing activities, (ii) our data protection by design and default approach, (iii) our routine data protection reviews, and (iv) the rights you have in relation to our data processing activities.

We will process your personal data for the above referenced purposes based on your prior consent, to the extent such consent is mandatory under applicable laws.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons/checkboxes/functionalities in relation to a privacy policy, we will consider this step as you providing your consent for us to process your personal data, only in the countries where such consent is required by regulations. In all other countries, such action will be considered as a mere acknowledgement. The legal basis of the processing of your personal data will not be your consent but any other above applicable legal basis.

We will not collect or use additional personal data categories we collect for materially different, unrelated, or incompatible purposes without providing you notice or, as applicable, your consent; unless it is required or authorized by law, or it is in your own or another person’s vital interest (e.g. in case of a medical emergency) to do so.

Data recipients
Personal data collected in the course of our activities, including in connection with some client services, as well as on the Sites may be shared with:

our subsidiaries or affiliates, clients and strategic alliances on a need-to-know and authorized basis.
our trusted suppliers or service providers, professional advisors or other third parties on a need-to-know and authorized basis that is necessary for the purposes for which such access is granted and in connection with an existing or potential corporate or commercial transaction.
For example, to provide services related to the Sites, our business activities, including in connection with some client services, in the manner agreed upon in our client services agreements, or supporting our interactions with you, including, for example, processing recruitment materials, administering surveys or contests, or communicating with you. When disclosing personal data to third parties, we take into account third parties’ data handling processes, and require these third parties to maintain privacy and security processes designed to ensure that their personal data processing activities are consistent with this Privacy Policy and safeguards the confidentiality, availability and integrity of personal data they process on our behalf.
with prospective or actual purchasers, or sellers on a need-to-know and authorized basis in the event of a sale, merger, joint venture, reorganization, assignment or other transfer or disposition of all or any portion of our business. It also is our practice to require appropriate protection for personal data under each commercial transaction.
with government agencies pursuant to a judicial proceeding, court order, or legal process.

We may make certain non-personal data available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Service. We will not intentionally disclose (and will take reasonable steps to prevent the unauthorized or accidental disclosure of) your personal data to any third parties for their own direct marketing use.

Direct marketing
As noted, we may send periodic promotional emails to you, and where required by law, we will obtain your consent to do so. You may opt out of such communications at any time. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Cookies, beacons, tags and other technologies
We use cookies, web beacons and other technologies on our Sites in order to collect the information described above in “Automatically-collected Information” and also to remember your settings and for authentication.

Cookies: Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but, if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

Clear GIFs, pixel tags and other technologies: Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the activities of users of our services, help us manage content, and compile statistics about usage of our services.

Log files: Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and Internet browser type and version. This information is gathered automatically and stored in log files.

Third party analytics: We also use automated devices and applications, such as Google Analytics to evaluate the use of our services. We use these tools to gather non-personal data about users to help us improve our services and user experiences. These analytics providers may use cookies and other technologies to perform their services, and may combine the information they collect about you on our Sites with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

You can manage the use of cookies through your browser: You may still use our Site if you reject cookies, but it may limit your ability to use some areas of our Site or otherwise diminish your experience of the Site. You can learn more about cookies at our Cookie Policy.

Third party websites and links
Our Sites may contain links or embed third-party applications to third party websites that are governed by their own terms and privacy statements. We may provide links to these third-party sites for your convenience and informational purposes only. For example, these links may allow you to interact with sites on which you may have accounts (such as Facebook and other social media sites) or join communities on sites that allow you to login, post content, or join communities from our Sites.

Third-party apps and websites have their own policies and disclosures, which we encourage you to read before interacting with such third-party websites or providing information on or through them. If you follow a link to any of those third-party websites, please note that we do not accept any responsibility or liability for their policies, or processing of your personal data. De-Mbarukas is not responsible for the content, accuracy of, or cookies set by any third-party linked site that is not operated by or on behalf of De-Mbarukas or for any other links contained in such third-party sites. The inclusion of any link to a website not owned by De-Mbarukas is not an endorsement by De-Mbarukas of the site or its contents or accuracy and does not suggest that the opinions expressed on a third-party site are representative of the views or opinions of De-Mbarukas.

De-Mbarukas assumes no responsibility or liability for any links to our Sites from another party’s website. You may post a link to any portion of the Site without prior written permission. However, any such links must not use framing techniques or in any way represent the Site or its content as being connected with another organization. In addition, you may not use any meta tags or hidden text in your website that incorporate the De-Mbarukas name or the names of any De-Mbarukas affiliate, subsidiary, business, program, or service.

Children’s privacy protection
De-Mbarukas is committed to protecting children’s privacy online.

Our Sites are not intentionally designed for or directed at children under the age of 13, and requires no such information be submitted to us. De-Mbarukas will not knowingly or intentionally collect, store, use, or share, personal data of children, anyone children under the age of 13 without prior documented parental or guardian consent.

If you are under the age of 13, please do not provide any personal data, even if prompted by the Site to do so. If you are under the age of 13 and you believe you have provided personal data to us, please ask your parent(s) or guardian(s) to notify us and we will delete all such personal data.

If we become aware that we have inadvertently received personal data from a user under the age of 13, we will delete these data from our records.

We retain relevant personal data as long as necessary to meet our criteria.

We retain personal data about unsuccessful candidates/applicants for 12 months following submission.

Personal data accuracy, privacy and security
We intend to maintain personal data accuracy, completeness, current status, and security. In the event of changes in your personal data, you may inform us to make sure that our information is up-to-date.

We implement commercially reasonable physical, administrative and technical safeguards to help us protect the confidentiality, security, and integrity of your personal data and prevent the loss, misuse, unauthorized access, unauthorized interception, or information alteration. For example, De-Mbarukas takes appropriate measures to make sure that the personal data you provide is stored on computer servers in controlled, secure environments.

All of our partners, employees, consultants, workers and data processors (i.e., those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of such personal data.

Your choice to disclose personal data in an email submission or online form is voluntary. Unfortunately, no data transmission over the Internet is 100% secure. While we strive to protect your personal data, we cannot ensure or warranty the security of any such personal data or fully ensure that your private communications and other personal data will not be inadvertently disclosed to third parties by De-Mbarukas or its business partners, agents, subcontractors, or other third-party vendors.

Although we take commercially reasonable precautions to maintain the security of our Sites and servers, third parties may unlawfully intercept or access transmissions or private communications.

Notification of our Privacy Policy changes
We may make changes to this Privacy Policy from time to time, to reflect changes in our practices. We also may make changes as required to comply with changes in applicable law or regulatory requirements. Where we materially change this Policy, we will take steps to notify you (such as by posting a notice on the Site or via email), and where required by applicable law to obtain your consent.

Please note that no permission is granted for you to use De-Mbarukas ’ logo, icons, or content. You must obtain our prior written permission to post additional graphic or textual material along with your link to our Sites.