This privacy clause is relevant for all endusers of the Cubigo Community platform.
Regarding the Cubigo Community platform, Cubigo operates in a dual role both as processor and controller of personal data. We highlight the corresponding responsibilities towards you as end-user in 2 sections: all information about Cubigo as processor of personal data is described in this section 2; read more in section 3 about Cubigo as controller of personal data.
Section 1 : General principles
- Explaining the way we use the information you share with us as end-user of Cubigo Community and give you a great experience with it;
- Ensuring that you understand what information we collect with your permission, and what we do and not do with it; and
- 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 regulations and enforced by European GDPR regulation.
1.2 Legal ground
We process your personal data on the following legal grounds:
· based on your consent
· based on a legitimate interest in which we have made a balancing of interests
· for the execution of an agreement to which you are a party
· because it is necessary to comply with a legal obligation to which Cubigo is subject
If we collected personal data under a legitimate interest or agreement, then we may also use this data in the future for another purpose compatible with the original purpose. We may do only if we take into consideration the relation between the original and future purpose, the context for data processing, the type of data, the applied security measures and the impact for you as subject.
1.3 Contact us
The company that operates the Cubigo platform and processes your personal data, whether on behalf of its partners or not, is: Cubigo Inc.
Corda Campus Hal B
Kempische Steenweg 303 bus 103
3500 Hasselt, Belgium
For the sake of completeness, we inform you that if our answer does not meet your needs, you have the right to file a complaint with the Belgian Data Protection Authority (GBA), at the e-mail address firstname.lastname@example.org.
1.4 Personal data collection
1.4.1. Type of data
The personal information we collect may include contact data, profile data, data collected in relation to the purpose and/or technical (device) data:
- Registration information, including your name, email address, and other details you provide us (birth date, phone number) when you sign up for the Cubigo platform. Information provided when filling out a request form;
- Information provided when subscribing to our newsletter;
- Information provided when placing orders or reservations via 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. Cubigo will only present the status of transactions and the corresponding payment method.
- Information provided in the context of surveys or any other marketing communication;
- Information provided in connection with certain websites that are associated with 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.
1.4.2 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.
1.4.3 Sensitive data
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 processed. 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 securely process and safeguard any kind of personal data you share via the Cubigo platform.
1.4.4 Additional personal information
In addition, service providers offering their services via Cubes on the Cubigo platform (hairdresser, manicure, home care, …) may collect additional personal data from you in order to deliver a high quality and gain customer satisfaction.
1.5. Data collection method
Most personal data is supplied by yourself as an end-user of Cubigo Community when registering to or using the Cubigo platform. Although we may also receive personal information automatically from your computer system. Furthermore, depending on the kind of profile and the Cubes you use, third parties such as caregivers, service providers, family etc., may also provide additional personal data about you.
1.6. Protecting your data
Your password is the first level of protection for your user account on the Cubigo Community platform. You should therefore use a unique and strong password, restrict access to your browser and computer, and log out after using the Cubigo platform.
With ISO27001 as a guideline, we have implemented profound security measures to guarantee an appropriate level of security according to technological evolution, the nature, scope, context and purpose of the processing. So, we install and maintain appropriate technical and organizational measures to protect your personal data against accidental or unwanted destruction, loss, modification, access or any other unauthorized processing.
We store your personal data in a regionally segregated data center operated by a qualitative partner (subprocessor) who's profoundly assessed and with whom Cubigo Inc has put in place a data processing agreement. All personal data is encrypted by Secure Socket Layer (SSL) technology.
In any transfer of personal data to a processor, we do so in accordance with the terms of this Privacy clause and we follow the applicable data protection laws and regulations to ensure adequate safeguards.
1.7. 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 account will be removed from the platform and your personal data will be anonymised. Anonymised personal data may be used to help us to improve the Cubigo platform and the services offered therein.
1.8. Links to third-party websites
1.9. 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.
Section 2 : Cubigo as processor of personal data
Pursuant to national regulations on data protection, the organisation who operates the community is designated as 'Controller'; it's the natural or legal person who determines the purpose and means for the processing of your personal data. The Controller can do this alone or in cooperation with other parties such as its related service providers who offer their services and products on the Cubigo platform through specific Cubes. This means that Cubigo processes such personal data solely according to the instructions of the community (operator) and/or its related service provider(s). Therefore, Cubigo Inc as platform provider is designated as 'Processor'.
2.1 Purposes for data processing as processor
Cubigo community platform supports the community operators with the following purposes and so processes your personal data on behalf of the operator/community to:
- 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 and reservations;
- to support healthcare professionals in their work processes.
All the information we collect when you use the Cubigo platform is related to the provision of services within the operator's ecosystem via the Cubigo platform and its features.
2.2. Exercising your rights
This operator/community is responsible and held liable for the secure processing of your personal data according to the local regulations. To exercise your rights as data subject to the community you belong to, you can reach out to its Data Protection Officer (DPO) via the contact details mentioned in its privacy clause.
Section 3: Cubigo as controller of personal data
As platform provider Cubigo wants to ensure a high level of performance and user experience towards the Cubigo Community platform end-users. To meet these objectives Cubigo processes some personal data and operates as a Controller. More information about the purpose and your rights can be found in this section.
3.1. Purposes for data processing as controller
As controller Cubigo collects personal information from its end-users for the following specific purposes:
- Information and feedback we need so that you can use the Cubigo platform in an optimal way and offer you the best possible user experience;
- Information we need so that we can optimize the performance of our platform and its related apps;
- Information we can use in the future to provide new solutions and improved experiences if you choose to share that information
Based on the personal data we have about you, and in order to optimize our communication and business relation, we may analyze, evaluate and assess your preferences and needs in order to offer a more end-user centric experience. For clarity's sake, we emphasize that these activities can be qualified as 'profiling'.
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. 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.
3.3 Relevant and reasonable
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 this privacy clause. 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.
3.4 Exercising your rights towards Cubigo as controller
For the purposes Cubigo operates as Controller, you can exercise your rights directly to Cubigo by sending us a written and signed request, accompanied by a copy of your identity card, to email@example.com. We will respond to your request as soon as possible.
3.4.1 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.
3.4.2. Right to rectification
When we process personal data, it is important that such data is accurate. As an end-user of the Cubigo platform you can self-manage your personal data and keep these up-to-date. On top, you can always tell us to correct or delete inaccurate or incomplete data about you. So, you may send us a written and signed request accompanied by a copy of your identity card, to firstname.lastname@example.org. We will respond to your request as soon as possible.
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.
3.4.3. Right of objection/Right to be forgotten
Any end-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.
If you don't or no longer agree to the processing of your personal data as described in this Privacy Statement, you can execute your rights as data subject. Please reach out with your request to email@example.com
If you do not longer want to receive emails sent by Cubigo, you can unsubscribe from emails by clicking 'Unsubscribe' at the bottom of the email or send this request to firstname.lastname@example.org. Important service-related emails will still be sent.