Privacy Clause

Version 15/03/2023

1.  Introduction

We value the privacy and secure processing of your data very highly. Transparency with regard to the use of your personal data is crucial for building trust, goodwill and a strong relationship. That is why we will tell you how we collect and process your personal data in this Privacy Statement. This ensures that you as a user always know what kind of and how much personal information we have about you and what we use it for.

Before discussing this Privacy Policy in detail, we would like to highlight some of the key principles behind it. This Privacy Policy exists for three reasons:

1. Explaining the way we use the information you share with us in order to build a digital platform and give you a great experience with it;
2. Ensuring that you understand what information we collect with your permission, and what we do and not do with it; and
3. Holding us accountable for protecting your rights and privacy under this Policy.

We hereby confirm, among other things, that we comply with the legal requirements for the processing of personal data, pursuant to national and European regulations.

1.1.

When you visit our website (www.cubigo.com) and our Platform (https://community.cubigo.com), you are expected to have read this Privacy Statement. Please note that we update this Privacy Statement on a regular basis. Therefore, we kindly ask you to visit this page regularly. Substantial changes will be clearly communicated on the website and the Cubigo platform. Obviously, you can save this Privacy Statement in digital format, print it out, or otherwise make a copy of it.

1.2.

If you have any questions or concerns after reading this Privacy Statement, please contact us via email at privacy@cubigo.com.

2.  Personal data collected

2.1.

The personal information we collect includes:

• Registration information, including your name, email address, and other details you provide us (birth date, phone number, community address) when you sign up for the Cubigo platform. When you place an order via the Cubigo platform, you do so within your community, who is deemed responsible for the proper execution of the service delivery. If any financial data is requested, the processing thereof will be handled through external e-commerce payment software. Such data will not be communicated to Cubigo and will be handled by (payment) service providers only.
• Information provided when filling out a form or our website, or when filling in specific Cubes;
• Information provided when subscribing to our newsletter;
• Information provided when placing orders on the Cubigo platform;
• Information provided in the context of surveys or any other marketing communication;
• Information provided in connection with the use of certain websites that are associated with the Cubigo website or the Cubigo platform, such as Zendesk, with which our support department can assist you with any questions or problems you may encounter when using the Cubigo platform;
• Any other information that you send to us, such as when you contact us with questions or comments.

2.2. Cookies

Cookies are small files that are stored on the computer of a website visitor. These files store small amounts of data on a specific user and website, which can be accessed from the user's computer. The web page can therefore be tailored to the user. The Cubigo website only uses essential cookies.

You can find out more about the use of cookies in our Cookies policy.

2.3. Data for which explicit permission has been obtained

Another information category comprises information that enables us to offer you additional features. We never receive such information unless you expressly choose to share it with us. Here are some examples:
- Your specific location: We will never collect or use your specific device location without first getting your explicit permission.
- Your microphone: By using the microphone, you will be able to control the Cubigo platform with your voice. Nevertheless, we will never access or use your microphone unless you give us explicit permission to do so. Even if you give us permission to do so, you will always have the ability to disable access to the microphone.

2.4.

In addition, service providers offering their services via Cubes on the Cubigo platform may collect additional personal data.

2.5.

Although in principle we do not collect sensitive personal data (such as data on race, ethnic origin, religious beliefs, criminal background, physical or mental health, and/or sexual preferences), it is possible that this type of information will be processed. Based on how you use the Cubigo platform - and certain Cubes in particular - implicit information about your health, medication, religion and more may be communicated. We would like to draw your attention to this fact and make you aware of the sensitivity of this data. Obviously, we take the necessary measures to protect your personal data.

3.  Data collection method

Most personal data is supplied by yourself as a user - when registering or using the Cubigo platform, for instance - although we may also receive it automatically from your computer system. Furthermore, depending on the kind of profile you opt for and the Cubes you use, third parties such as caregivers, family, acquaintances, etc., may also provide additional personal data about you.

4.  Data Controller

Pursuant to national and European regulations on personal data protection, the 'Data Controller' is the natural or legal person who determines the purpose and means for the processing of personal data. The Data Controller can do this alone or in cooperation with other parties.

The company that manages the Cubigo website and platform and processes your personal data, whether on behalf of its partners or not, is:

Cubigo, International
Corda Campus Hal B
Kempische Steenweg 303 bus 103
3500 Hasselt, Belgium

Email address: privacy@cubigo.com

We are solely responsible for processing personal data for our own purposes, such as handling the personal data of our (prospective) users for customer relationship management, sales, direct marketing, shipping and invoicing,

Furthermore, your community and its related service providers may offer their services and products on the Cubigo platform through specific Cubes. With regard to the personal data collected by these service providers on the aforementioned Cubes, only those service providers are responsible for the data processing and Cubigo acts solely as a processor. This means that Cubigo processes such personal data solely according to the instructions of the service provider. Therefore, Cubigo will only be liable for such data as a processor and not as Data Controller.

5.  Purposes of data processing

5.1.

We offer digital services on the Cubigo platform with the following purposes:

• to connect residents and their family with the community and its staff
• to provide access to quality services in terms of comfort, well-being, leisure and healthcare;
• to inform residents and their family on the news and activities in the community;
• to follow-up on requested services;
• to support healthcare professionals in their work processes.

All the information we collect when you visit the Cubigo website or platform is related to the provision of services via the Cubigo platform and its features.

In brief, we collect information for the following specific purposes:

1. Information we need so that you can use the Cubigo platform;
2. Information we can use in the future to provide new solutions and improved experiences if you choose to share that Information; and
3. Information we need so that we can offer you the best possible support when using the Cubigo platform.

5.2. Information we need so that you can use the Cubigo platform

We collect your data first off al to create and maintain your personal account on Cubigo Community, to ensure the proper functioning of the Cubigo platform and to deliver the services and/or products (or have them delivered) that you order from or via the Cubigo platform.

For instance, you can use the Cubigo platform to:

• Communicate with your community, staff, caregivers, family or acquaintances, and vice versa;
• Receive the necessary information to follow up on the requested services;
• Set up communication between you, your family, the community, service providers and its staff;

5.3. Information we need in order to provide new solutions and improved experiences

Based on the personal data we have about you, and in order to optimize our services, we may analyze, evaluate and assess your preferences and needs. For clarity's sake, we emphasize that these activities can be qualified as 'profiling' under national and European regulations on personal data protection.

We also use the personal data and information we collect to:

• Customize your experience as a user;
• Determine the kind of content and offers you are most interested in and inform you about them;
• Offer you a better service, answer more of your questions, and meet your needs better;
• Provide you with information;
• Process your queries and orders quickly; and
• Communicate with you on various topics such as events, news items, and Platform feedback.

We never sell, trade or transfer your personal data to/with any third parties, unless we inform you about this in advance and you give us your explicit permission to do so.

We do share your contact details with website hosting partners or other third parties that help us conduct our business or operate our website and the Cubigo platform, or that provide services directly to you. This mostly - but not only - includes service providers and product vendors that have a Cube on the Cubigo platform. These partners are also obliged to keep this information confidential. Furthermore, we may share your personal data when we are legally obliged or entitled to do so.

Certain information that cannot lead to the identification of a natural person, such as website/platform statistics and similar data, may be shared with external parties for marketing, advertising or other purposes.

6.  Protecting your data

We strive to protect the information of our users. Your password is the first level of protection for your user account. You should therefore use a unique and strong password, restrict access to your browser and computer, and log out after using the Cubigo platform. Furthermore, we always take the appropriate technical and organizational measures to protect your personal data against accidental or unwanted destruction, loss, modification, access or any other unauthorized processing.

We have also implemented several security measures to guarantee an appropriate level of security according to technological evolution, implementation costs and the nature, scope, context and purpose of the processing.

We store your personal data on secure servers, which are only accessible to a limited number of people who have special access rights to these systems in emergency cases. These technicians are also bound by a confidentiality agreement and must always use and handle personal data in accordance with the Cubigo Privacy Policy.

Furthermore, all personal data is encrypted by Secure Socket Layer (SSL) technology.

Moreover, we implement a variety of security measures to protect your personal data when you, as a user, enter your data or access your personal information.

7.  Data retention period

We store your personal data as long as your account remains active and no longer than necessary. Once you ask us to delete your profile, your data will be permanently and irrevocably removed from the Cubigo platform. Inactive users' personal data may be anonymized in order to assess and improve the Cubigo platform and the services offered therein.

8.  Your rights as a Cubigo website or platform user

We process your personal data in a fair and lawful manner. This means that we only process your personal data for the legitimate purposes explicitly stated in Section 5. Furthermore, we ensure that the type and amount of personal information we collect is always relevant and in reasonable proportion to the purposes for which it is processed.

8.1. Right of access

Anyone who proves their identity has the right to access the personal data we hold about them. This means that you have the right to request information about the data we process, the purposes for which we process it, the categories of personal data concerned, and the recipients we share your data with. This privacy statement is a first step towards this. You have the right to ask us to provide you with an overview of all personal data we hold and process about you, as well as the source from which we have obtained it, in an easily intelligible way.

8.2. Right to rectification

When we process personal data, it is important that such data is accurate. Therefore, you can always tell us to correct or delete inaccurate or incomplete data about you.

Since we cannot detect errors or omissions in your personal data, we are counting on you to inform us of any inaccuracies or omissions and to make the necessary adjustments to your registration data.

8.3. Right of objection/Right to be forgotten

Any user can exercise their right to object to the processing of personal data for serious and legitimate reasons, free of charge. However, the user cannot object to the processing of personal data if the data is necessary to fulfill the respective contractual obligations. Cubigo Inc will notify the user of the deletion of their personal data within thirty (30) days.

8.4. Exercising these rights

You can exercise the above rights by sending us a written and signed request, accompanied by a copy of your identity card, to privacy@cubigo.com We will respond to your request as soon as possible.

9.  Abrogation of this Privacy Statement

If you don't or no longer agree to the processing of your personal data as described in this Privacy Statement, you can delete your profile.

You can unsubscribe from emails sent by Cubigo by clicking 'Unsubscribe' at the bottom of the email or by following this link. Important service-related emails will still be sent.

10.  Links to third-party websites

Our website and the Cubigo platform may contain links to websites, products and/or third-party services. If these websites are not managed by Cubigo Inc, Cubigo Inc can in no way be held liable for their content nor for the privacy policy that applies to them. Nevertheless, protecting the integrity of our website and the Cubigo platform is our highest priority, and we appreciate any feedback you may want to give us regarding these websites.

11.  Can children use the Cubigo platform?

We do not wish to collect personal data from minors. Persons under the age of 18 can only use the Cubigo platform if they submit a written permission from a parent or legal guardian who has read this Privacy Statement. In the case of underage users, the parents or legal guardians are fully responsible for all actions taken by the minor.

12.  Modifications to this Privacy Statement

Since we want to continuously improve our website, the Cubigo platform and our services, we occasionally adjust this privacy statement so that it is consistent with applicable laws, our business needs, and the needs of our users, visitors and service providers.

That is why we publish updated versions of this Privacy Statement on the website and on the Cubigo platform. These new versions are given a timestamp so that you can check which version of the Privacy Statement is the most recent. Important changes will always be communicated to you.

13.  Contact

In case you have any question regarding Cubigo data privacy policy, please contact Cubigo DPO via privacy@cubigo.com.

Cubigo and its DPO is registered at Belgian dataprotectionauthority as DGVQDDFL.

Cubigo, International
Corda Campus Hal B
Kempische Steenweg 303 bus 103
3500 Hasselt, Belgium