Disclosure & Privacy Notice
1. About Marabek and How to Contact Us
2. Scope of this Privacy Notice
4. What Personal Data do we Collect and Why
10. European Union Data Protection Rights
11. Your California Privacy Rights
13. Security
14. Our Policy with Respect to Children
1. About Marabek and How to Contact Us
Marabek, LLC and its subsidiaries (collectively “Marabek”, “we,” or “us”) are the controllers of personal data provided to us by data subjects. We also act as data processors when providing certain services to our business clients.
Marabek adopts this notice to provide transparency to individuals about the Personal Data we collect, how that data is used and how Marabek complies with data protection laws such as the General Data Protection Regulation (“GDPR”) and California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the GDPR or CCPA have the same meaning when used in this notice.
If you have any privacy concern or questions about how your personal data is used, please feel free to contact us.
You can find our contact details in the last section of this notice.
About Marabek
Marabek provides strategic advisory, business management consulting and expert services to businesses. You can find a list of our services here.We operate globally through our different legal entities. The location of our offices may change from time to time, but we maintain a link to a listing of Marabek’s current office locations and contact information here. Marabek is the data controller of information collected through this website or as provided by you when you otherwise interact with us. Marabek also serves as a data processor when we provide services and perform work for our business clients. Marabek’s services are delivered as requested and directed by our clients. The client remains the data controller of personal information provided to Marabek as necessary to perform the service. There are certain circumstances where our subsidiaries may also be data controllers or data processors, for instance when you engage us for the provision of services, but we will inform you of these circumstances in advance. How to contact us if you want to exercise your data protection rights, have any questions, or need further information about this Privacy notice or the processing of your Personal Data by Marabek, please contact us by email at [email protected].
2. Scope of this Disclosure and Privacy Notice
This privacy notice applies to information collected through the website, when you apply for a job position online, or when you otherwise interact with us. We have other privacy policies that apply in certain circumstances, such as when personal data is provided to us by a client and Marabek is acting as a data processor. We are also committed to complying with local legal requirements in jurisdictions where we offer services.
This Privacy Notice applies to:
- All electronic communications with Marabek, including visiting our website (‘Website’);
- Personal data we receive from anyone who requests information or otherwise interact with us;
- Job applications with Marabek;
- Our marketing activities, including events and conferences;
- Our collection and use of information in the normal course of business.
We have a separate policy for how we process personal data from our employees. If a service or a data collection has its own specific privacy and security provisions, then these provisions – not this privacy notice – applies.
This Privacy Notice is at all times subject to applicable local law requirements.
3. Sources of Personal Data
We collect information from different sources depending on the context of your interactions with Marabek, for instance when you visit our website, when applying for a job position, or when engaging our services.
We collect information and data from you in various ways, including:
Information received directly or indirectly from you:
- Online data. Through use of the Website, including any information you send to us and through our use of “cookies” – see our Cookie Policy;
- Contact and event registration. Information that you provide when you contact us, or for event registration;
- Job applications. When you apply for a job position with Marabek;
- Business relationships. When you provide or receive services from Marabek we usually collect information voluntarily from you, or from third parties, with your authorization;
Or from third-party sources:
- Information that we obtain from other third-party sources as permitted by local law, such as publicly accessible social media sites, company websites, and subscription-based third-party databases such as business research databases.
4. What Personal Data We Collect and Why
Depending on the relationship you have with Marabek and where you are located, we collect and use different types of personal data, according to local laws.
“Personal Data” as used herein means all information that can directly or indirectly identify you or other individuals.
Technical Usage Information and Analytics
When you visit our Site, we collect usage information sent to us by your computer or mobile device that tells us how you are using the Website, including information such as the browser type, IP address, user language, the operating system, unique device identifier, or location. This information is collected through the use of cookies and similar technologies. Please see the Cookie Policy for further details.
Contact information for Event Registration and to respond to inquiries
We collect your name, email, title, company, postal address, telephone number or other information that you voluntarily choose to provide to us for event registration, or to send you marketing information as requested.
Career Information
If you apply for a position at Marabek, we will collect information including, but not limited to, your name, address, telephone number, employment history, education, reference information, salary expectations, work permit/visa requirements, and other information that you choose to provide to us.
When providing names and contact information of third-party references in connection with applying for a position with Marabek, you represent that you have obtained permission from your references to provide us with their personal information. Any providers we engage during the screening process will be vetted to ensure they have the appropriate privacy and security practices in place.
If you don’t provide us with all the requested information, we may not be able to consider your job application.
Additionally, as permitted by applicable local law and when you authorize us through a separate consent, we will collect special categories of personal data, such as your social security number, or information necessary to complete a background check.
Business information
When we have or are developing a business relationship, we collect business contact information, such as: name, title, organization, contact information and email address from you or from your employees or representatives, including areas of interest and potential and professional focus for purposes of identifying future opportunities to work together.
When receiving or providing services, we also collect payment information, conflict checks and credit reference information (including background checks when appropriate and according to local laws).
If you do not provide us with the information required, we may not be able to do business with you.
Information related to the provision of our services
When providing services to clients, in addition to collecting business contact information, we will process various documents, files, or other data using software or hardware tools at the request of our clients. The data we process on behalf of our clients may contain personal data, and special categories of personal data.
The receipt and processing of this type of information and the appropriate data protection measures are defined on a case-by-case basis through a risk analysis and/or through a separate agreement with each of our clients.
Information from Other Sources
The information we collect may be combined with information from outside records (e.g., demographic information, navigation information, additional contact information) that we have acquired in accordance with law. For example, if you work at a law firm but we don’t know your title, we may go to the firm’s website or a social media site to confirm your title.
We do not use automated decision-making systems.
5. Our Use of Personal Data
The purposes for which we collect and use your personal data may vary depending on the type of relationship you have with us, such as if you are a website visitor, one of our clients, or an applicant for a job position with us.
When it is necessary for entering into or the performance of a contract:
- Recruitment. We process your job application for employment management and recruitment purposes;
- Compliance with contracts and engagements. We collect personal data to perform our business functions providing consultancy services to clients, and executing contracts with our providers;
- Billing and payments; we collect data of the appropriate representatives of accounts payable or receivable
To comply with applicable laws:
- To comply with laws such as anti-money-laundering rules, fraud prevention, tax, employment and other relevant national laws;
- Courts, and law enforcement requests. Including disclosures to courts, public authorities and law enforcement;
For our legitimate interests in:
- Collecting Technical usage information and Analytics. We collect information automatically for administering and improving our Website, including analyzing the traffic patterns of our site, according to our cookie policy;
- Responding to inquiries and information requests;
- Providing registration for Events. We collect information necessary for the organization of events, seminars, and publications related to our different practices and services;
- Conducting Marketing activities. Our marketing activities include sending newsletters, updates, and other information and materials related to our services and events that we think will be of your business interest;
- Engaging in Business development. Building business relationships and synergies for future projects with our clients and potential clients, including business strategy decisions;
- Client Administration and management. Consolidating information relating to our clients, potential clients and service providers among Marabek’s offices for the provision of services and for business development purposes;
- Information security. Implementing security measures to protect availability, integrity and confidentiality of information processed by Marabek, and to prevent and respond to cybersecurity threats and data breaches.
- Defending our interest and legal rights. For instance, to enforce our website terms, policies and contracts with clients and providers; for the establishment, exercise or defense of legal claims;
- Business transfer. Sharing certain personal data in the context of a merger, sale, acquisition, reorganization, dissolution or other change of ownership of control;
We also use your personal data based on your consent, in these cases you can withdraw that consent at any time:
- When appropriate and permitted by applicable local laws we process special categories of personal data based on your explicit consent (for instance when you provide diet preferences or disability-related needs when you register to our events).
- Some marketing activities and events are based on your consent (for instance, when we don’t have a business relationship with you).
6. Data Retention
We retain personal data only for the length of time required to fulfill the purpose for which the data was collected or to comply with legal obligations.
According to our retention policy, we retain Personal Data as necessary for the duration of the purposes outlined in this Privacy Notice and to comply with our legal obligations. The retention period depends on the context in which we process personal data, for instance:
- Technical Usage Information. Information collected automatically through the use of cookies is retained for a maximum period of 13 months, see our Cookie Policy for additional information.
- Career information. We keep your personal data up to 5 years for consideration of potential future employment opportunities unless you request that we delete your information sooner. If you are offered and accept employment with Marabek, this information will be retained and transferred to your personnel file and used to manage your employment or other relationship with Marabek (e.g. to administer benefits, training, performance reviews, regulatory compliance).
- Remaining information. Retention periods for data not referenced above are determined by the purposes defined above for which the information is collected and used, for instance when it is necessary to continue providing a service or to comply with our professional obligations, taking into account applicable data protection laws, and legal requirements, including tax and anti-money laundering regulations, that may vary depending on the jurisdiction.
We will delete or block your Personal Data after these retention periods, unless you authorize us to keep it, or when it is necessary to enforce our agreements or resolve disputes.
These retention terms apply unless agreed upon otherwise in a contract with Marabek or as required by applicable local law.
7. Who Receives Your Data
At times, we disclose your personal data to our Marabek subsidiaries and to our vendors to help accomplish our business objectives and provide you services. There are other circumstances where we are required by law to disclose personal data to public bodies or judicial authorities.
Information collected may be shared with:
Marabek subsidiaries
We may share the information we collect about you with our Marabek affiliates and subsidiaries. Contact details of Marabek’s offices are available here.
The information may be disclosed (i) to provide services (e.g. consultancy services); (ii) to help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches; and (iii) to guide decisions about our Marabek services, website, and communications.
Service Providers and Other Third Parties
We may disclose your information to service providers under contract who help with our business operations including, sub-contractors supporting the delivery of professional, technology, or communication services. Any providers or third parties we engage will be vetted to ensure they have the appropriate privacy and security practices in place.
Other Entities with your Consent
We will disclose your information to other third parties to whom you explicitly ask us to send your Personal Data. On this Site, you may have opportunities to express interest in or register for other services such as registering for events and webinars organized by third parties. If you do, we will provide your Personal Data to those third parties, to fulfill your request.
Social media sites
When you interact with our Website through social media sites, plug-ins or other applications, depending upon your privacy settings, this information may become public on the Internet. We cannot prevent further use of this information. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party sites’ privacy policies and terms of use to learn more about their privacy practices, which we do not control.
Legal Obligations
We may disclose your Personal Data as required by law, such as to comply with lawful requests by law enforcement and public authorities or courts, when we believe in good faith that disclosure is necessary to comply with such legal process, or to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. We will use reasonable endeavors to notify you before doing so, unless we are legally restricted from so doing.
Change of Control
Marabek may in the future reorganize or transfer all or part of its businesses, which may result in the transfer of your Personal Data to new Marabek entities or third parties through which the whole or a part of the Marabek businesses will be carried out. If Marabek becomes insolvent, enters receivership or any similar or equivalent event occurs, parts of the business may be sold or transferred to a third party. This change of control may result in the transfer of your Personal Data to a third party that will carry out the business.
8. Opt-Out of Marketing Communications
You can opt-out of your marketing communications anytime.
You can opt-out of receiving our newsletter or other marketing communications by following the opt-out instructions in our commercial e-mails or by contacting [email protected].
9. Transfers of Personal Data
If you are located outside the United States and you interact with our Website or provide Marabek Personal Data, then your information may be transferred to the United States. Only in certain circumstances, your personal data will be transferred to other jurisdictions. However, we provide appropriate safeguards to ensure the same level of protection of your personal data.
If you are located outside the United States and you interact with our Website or provide us Personal Data, then your information may be transferred to Marabek affiliates in the United States or to our third-party service providers located in the United States. In certain circumstances, for instance, when it is necessary for the provision of services, we may transfer your personal data to Marabek’s offices or service providers based in other jurisdictions. In these situations, we ensure compliance with local data protection requirements.
If you are based in the European Economic Area (EEA), the United Kingdom or Switzerland, we use Standard Contractual Clauses (SCC) to ensure appropriate safeguards when we transfer your personal data to the US or to other jurisdictions that do not provide an equivalent level of protection. These contracts can be provided on request. In exceptional situations where it is not possible to use SCC or other transfer mechanisms, we rely on derogations including your explicit consent, necessity to enter into a contract with you or in your interest, or for the establishment, exercise or defense of legal claims.
10. European Union Data Protection Rights
If you interact with our EEA/UK offices, reside in these territories or in other locations where similar rules apply Marabek is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence.
Marabek is committed to facilitate the exercise of your rights granted by the data protection laws of your country of residence. Accordingly, some of the rights listed below will only apply in certain circumstances. You can contact us at any time to discuss any of these rights or your privacy concerns at [email protected].
- Transparency and the right to information: we provide you notice of how we use your Personal Data in our day-to-day operations at the time of collection, or as soon thereafter as possible. We also publish this privacy notice for a greater transparency.
- Right to access, and rectification: we provide you with access to your own personal data where required by applicable law. In addition, we will rectify your Personal Data when we are notified that it is inaccurate.
- Right to object, restriction of processing, erasure and withdraw consent at any time: for all marketing materials, you can opt-out anytime, and free of charge. The right to object for other processing activities, the right of erasure and restriction of processing will be balanced to ensure that these are not incompatible with local laws and regulations or other overriding rights. When we have collected your personal data with your consent, then you can withdraw it at any time.
- Right to data portability: based on your specific situation, we provide you with the right to obtain and reuse your data across different services, including the transfer of your data to you or to another third-party.
- Right to lodge a complaint with your supervisory authority: if you are not satisfied with our response or how we process your personal data you can complain to the data protection authority of your habitual residence.
How to exercise these data protection rights
All these requests should be submitted as follows:
- Opt-out of marketing communications: you can opt-out anytime by following the opt-out instructions in our commercial e-mails or by contacting us at [email protected].
- To exercise the rest of your rights: you should send a communication in writing to [email protected]. Marabek will attend to your request in a timely manner within 30 days after receiving your request. If for any reason we need to extend this period of time, we will contact you.
- You also have the right to lodge a complaint with a supervisory authority: A list of the European authorities is available here, the contact information of the Federal Data Protection and Information Commissioner of Switzerland is available here, and the Information Commissioner’s Office in the UK is available here.
11. Your California Privacy Rights
The California Consumer Privacy Act (CCPA) provides California residents with specific rights regarding their personal information. This section describes the CCPA rights and explains how to exercise those rights. We will not discriminate against you for exercising your CCPA rights.
Right to Know
You may have the right to send us a request, no more than twice in a 12-month period, for any of the following:
- The categories of personal information (PI) we collect about you
- The categories of sources for the PI we collect about you
- Our business or commercial purposes for collecting that PI
- The categories of third parties with whom we share that PI, and categories of PI that each recipient received
- The specific pieces of PI we collect about you
Right to Delete
You have the right to request that a company delete any of your Personal Information that it has collected from you and retained, subject to certain exceptions.
For example, we may deny your deletion request if retaining the information is necessary for us to complete the transaction or service that you requested, detect security incidents or enable internal uses that are reasonable aligned with your expectations.
How to Exercise your California Privacy Rights
To exercise the right to access and/or the right to delete your personal information, please submit a verifiable consumer request to us by either:
- Sending us an email at: [email protected]
Please, describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In order to verify a request from you exercising your rights, you will need to provide (i) your legal first and last name, (ii) email address you use to correspond with Marabek, (iii) describe your relationship with Marabek, and (iv) identify the state in which you currently reside.
Once the initial identification and verification process is complete, we will send you an acknowledgement of receipt within 10 days from receiving your request and a reference number. Any request that you submit to us is subject to an identification process to verify your identity or authority to make the request. We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you in writing. To exercise any of these privacy rights you can also designate another person to act on your behalf. In this case, we will need this person to provide us with a written authorization (such as a Power of Attorney). We will typically not charge a fee to fully respond to your requests. However, if we determine that the request warrants a fee according to the CCPA, we will tell you why and a cost estimate before completing your request. If you require this notice to be provided in a different format, please contact us at: [email protected]
Sale of Personal Information
Marabek does not sell or lease information to third parties as defined by the CCPA. Marabek does use cookies and similar technologies on our websites to analyze and improve performance, enhance visitor or member experience, and offer customized experiences. These cookies and technologies may share information with other parties, however, we provide visitors the ability to block any cookie which is not strictly necessary for our site to operate. For more information on how to block cookies and modify your settings, please see our Cookie Notice here.
12. Data Protection Officer
You can contact our Data Protection Officer at [email protected].
13. Security
We take commercially reasonable precautions to try to keep all information obtained from you secure against unauthorized access and use, and we periodically review our security measures.
We are committed to processing your data in a secure manner and have implemented appropriate technical and organizational measures designed to help prevent the Personal Data we hold from being accidentally or deliberately compromised.
We maintain technical, physical and administrative security measures to try to protect the security of your Personal Data against loss, misuse, unauthorized access, disclosure or alteration. Authorized Marabek personnel and third parties will only have access to your Personal Data to the extent needed to do their job or provide their services. Despite these precautions Marabek cannot guarantee that unauthorized persons will not obtain access to your information.
Please note that any electronic communication made between us, including via the Website, may not be secure and, unless you are already a client, may not be treated as confidential. While we welcome your inquiries, please do not send us any electronic communication that contains any confidential or sensitive Personal Data.
Our Site may contain links to other third-party websites. We are not responsible for the privacy practices or the content or security of these third-party sites.
Our Site does not respond to do-not-track signals.
14. Our Policy with respect to Children
Our services are not directed to children
We do not knowingly collect personal data from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without their consent, please contact us at [email protected].
15. Changes to this Notice
We reserve the right to modify this privacy notice at any time. We will duly inform you of any material changes.
This Privacy Policy may be amended by us at any time. If we make any material changes to how we treat Personal Data, we will notify you by placing a prominent notice on the Site. The time stamp you see on the policy will indicate the last date it was revised.
This Policy was last updated on September 18, 2023.
