Privacy clause for Cubigo

This privacy clause is relevant for all Cubigo stakeholders being you as as a visitor of www.cubigo.com, prospect, customer, partner, supplier, employee, contractor and more.

This version applies from 24/07/2023.

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 with all our stakeholders. Therefore this privacy notice is relevant for all Cubigo stakeholders being you as a visitor of www.cubigo.com, prospect, customer, partner, supplier, employee, contractor and more. In section 1 we tell you what kind of personal information we have about you and how we process your personal data. 

Regarding your relation with Cubigo as a company, Cubigo operates in the role as controller of your personal data. We highlight the corresponding responsibilities towards you in section 2. Regarding your relation with Cubigo as an end-user of the Cubigo Community platform, we refer to the corresponding privacy clause. 

Section 1 : General principles 

1.1 Motivation

First we’d like to highlight the key reasons behind this Privacy Policy:

• Explaining the way we use the information you share with us;
• 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 processes your personal data is: Cubigo Inc, California

In case you have any question regarding Cubigo privacy policy, please contact Cubigo Data Protection Officer (DPO) via privacy@cubigo.com.

Cubigo, International
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 contact@apd-gba.be.

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:

• Information provided by you when visiting our website included related cookie information according to your cookies preferences;
• Information provided when filling in a contact form on our website;
• Information provided when subscribing to our newsletter;
• Information provided by you in the context of surveys or any other marketing communication;
• Any other information that you send to us, such as when you contact us with questions or comments;
• Information provided by you when following Cubigo on LinkedIn;
• Information provided by you when subscribing to a Cubigo webinar;
• Information provided by you in relation to commercial business contacts and partnership;
• Information provided by you as candidate-employee;
• Information provided by you as freelance-contractor;
• Information provided by you as an employee including your name, email address, address, and other details you provide us (birth date, phone number, account number) in order to formalise and follow up on your employment at Cubigo

1.4.2  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- implicitly or not. 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 with Cubigo.

1.5.  Collecting your data

Most personal data is supplied or registered by yourself as (candidate-) employee, contractor, supplier, customer or (website) visitor. Although we may also receive personal information automatically via your computer system. 

1.6.  Protecting your data

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 according to the lifecycle of our business relation and no longer than necessary. As an employee or contractor, the data retention period is stipulated in the employment contract.

1.8.  Can children access the Cubigo website?

We do not wish to collect personal data from minors. Persons under the age of 18 can access the Cubigo website or subscribe to Cubigo newsletter or feeds although unintended. In the case of underage users, the parents or legal guardians are fully responsible for all actions taken by the minor.

1.9.  Modifications to this Privacy Policy

We occasionally adjust this privacy policy so that it is consistent with applicable laws, our business needs, and the needs of our users and visitors. We publish updated versions of this Privacy Policy with a timestamp. 

Section 2: Cubigo as controller of personal data

Cubigo wants to communicate with all stakeholders about its offering, company updates and vacancies via its website, newsletter, LinkedIn news feed and webinars. 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.

2.1. Purposes for data processing as controller

As controller Cubigo collects personal information for the following specific purposes:

1. To inform you about Cubigo company, market and product updates
2. To guarantee you a qualitative user experience as visitor of www.cubigo.com
3. To install and maintain a business relation with you as prospect, customer, supplier or partner
4. To install and maintain a business relation with you as (candidate-) employee or (candidate-) contractor
5. To install and maintain a business relation with you as investor or stakeholder

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 improve our product offering and user 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.

2.3  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.

2.4 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 privacy@cubigo.com. We will respond to your request as soon as possible.

2.4.1 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. 

2.4.2. Right to rectification

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

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.

2.4.3. Right of objection/Right to be forgotten

You can exercise your right to object to the processing of personal data for serious and legitimate reasons, free of charge. However, you 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.

2.4.4. Right to revoke consent

You have the right to revoke your consent given to us at any time. This has the consequence that we may no longer continue the processing of your data based on this consent in the future.

2.4.5. Right to restrict the processing

You have the right to request the restriction of the processing of your personal data, insofar as the accuracy of the data is disputed by you, the processing is unlawful. But you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defense of legal claims or you have objected to the processing pursuant to Article 21 of the GDPR.

2.4.6. Right of deletion

You have the right to request the deletion of your personal data stored by us, unless the processing is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims.

 

1.10.  Abrogation of this Privacy Policy

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 privacy@cubigo.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 privacy@cubigo.com. Important service-related emails will still be sent.

 

END of Cubigo.com privacy statement