Cubed Mobile Privacy Notice

You can find information about us and how we collect, use and store your personal data in each section of this Privacy Notice:

Purpose and Who We Are

The purpose of this Privacy Notice is to describe how Privacy Software Solutions Ltd., our subsidiaries, and our international branches (“Cubed Mobile”, “us”, “we”, or “our”), may collect, use, or share information about you through our online interfaces (e.g., websites and mobile applications) owned and controlled by us (collectively referred to herein as the “Site”).

Please read this Privacy Notice carefully to understand what we do. If you do not understand any aspects of our Privacy Notice, please feel free to contact us at info@cubedmobile.com. Your use of our Site is also governed by our Master Service Agreement. Terms used but not defined in this Privacy Notice can be found in our Master Service Agreement.

Privacy Software Solutions Ltd. is an Israeli corporation with a registered office at Kibbutz Einat, POB 83, Israel. If you reside or are located in the European Economic Area (“EEA”) Cubed Mobile is the data controller of all Personally Identifiable Information (as defined below) collected via the Site and of certain Personally Identifiable Information collected from third parties, as set out in this Privacy Notice.

What Information this Privacy Notice Covers

This Privacy Notice covers information we collect from you through our Site. Some of our Site’s functionality can be used without revealing any Personally Identifiable Information, though, for features or services related to the CM Product (the “Services”), Personally Identifiable Information may be required. In order to access certain features and benefits on our Site, you may need to submit, or we may collect, “Personally Identifiable Information” (i.e., information that can be used to identify you) (may also be referred to as “personal data” or “personal information”). Personally Identifiable Information can include information such as your name, email address, mobile or cellphone number, IP address, and device identifier, among other things. You are responsible for ensuring the accuracy of the Personally Identifiable Information you submit to Cubed Mobile. Inaccurate information may affect your ability to use the Site, the information you receive when using the Site, and our ability to contact you.

What You Agree to by Using Our Sites

We consider that the legal bases for using your personal information as set out in this Privacy Notice are as follows:

• our use of your personal information is necessary to perform our obligations under any contract with you or a relevant party (for example, to comply with the Master Service Agreement of our Site or to comply with our contract to provide the CM Product to you); or
• our use of your personal information is necessary for complying with our legal obligations, a court order, or to exercise or defend legal claims; or
• use of your personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are, among others, to run, grow and develop our business; operate our Site and provide our Services; carry out research and statistical analysis; maintain information security and prevent fraudulent operations and for internal administrative and auditing purposes; or
• consent.

Which legal basis applies to a specific processing activity will depend on the type of personal information processed and the context in which it is processed.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.

We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time as described below).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by communicating to us your willingness to remove consent or delete your account and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide our Services to you.

What Information We Collect

We gather two types of information about users through the Site:

1. Information relating to your use of our Site. When users come to our Site, we may track, collect, and aggregate information indicating, among other things, which pages or screens of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks or buttons were clicked. We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity. We also may use cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to the relevant section below, Cookies and Other Technologies.

2. Personally Identifiable Information provided directly by you or via third parties. We collect Personally Identifiable Information that you provide to us when you register for an account, update or change information for your account, purchase products or Services, complete a survey, sign-up for email updates, send us email messages, or uses the Services on our Site. We may use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific Services you select, send you updates about the Services, and send you email messages about Site maintenance or updates.

• Account Registration. If you register for an account on our Site, you may be required to provide us with Personally Identifiable Information such as your name, mobile or cellphone number and email address.
• Updates. Cubed Mobile may offer you the ability to receive updates either via email or by posting on portions of the Site as part of the Services.
• Identity Verification. Cubed Mobile may offer you the ability to verify your identity for select Services. In order to enroll for these Services, you may be required to provide us or our third-party identity verification vendor with Personally Identifiable Information such as your name, name of organization, address and date of birth. Subject to your consent, we may collect other personal information for your improved security or convenience, or for the purpose of fraud prevention.
• Communications with Cubed Mobile. We may receive Personally Identifiable Information when you send us an email message or otherwise contact us.
• Surveys.We may receive Personally Identifiable Information when you provide information in response to a survey operated by us.
• Third Party Credit Card Processing. Cubed Mobile provides you with the ability to pay for CM Product and other Services using a credit card or other methods of payment through a third-party payment processing service provider. Please note that our service provider – not Cubed Mobile – collects and processes your credit card information.

Cookies and Other Technologies

Cubed Mobile may use cookies, web beacons (including pixels and tags), and similar technologies on our Sites that collect certain information about you by automated means. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

We may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns relevant to our Services. The information we obtain in this manner includes IP address and other identifiers associated with your devices, types of devices connected to our Sites, device characteristics (such as operating system), language preferences, referring/exit pages, navigation paths, access times, browser preferences and characteristics, installed plugins, local time zones, local storage preferences, clickstream data and other information about your online activities. We use on our Sites both first-party cookies (served directly by our website domain when you visit our Sites) and third-party cookies (if served by any third-party website or services with whom we have partnered when you visit our Sites and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).

The cookies we may use on our Online Channels include (1) essential and functional cookies; (2) analytics cookies; and (3) targeting/advertising cookies, as described below.

• Essential and Functional Cookies. We use cookies on our Sites that are necessary for us to provide you with our products and Services. This includes essential cookies (such as those used to authenticate you to our website and identify you after you have logged in), functional cookies (such as those that remember what you added to your shopping cart or the language preference you selected), and user-centric security cookies used to increase the security of the products and services we provide to you (such as to detect authentication abuses). Given the necessary functionality of these cookies, they typically may not be disabled.
• Essential and Functional Cookies. We use analytics cookies to collect information on how users navigate and use our Sites, such as how the users traverse our Sites, the pages they view, how long they stay on a page and whether the page is displayed correctly or whether errors occur. Such cookies help us to improve the performance of our Sites and make the Sites more user-friendly. These cookies are provided by third-party analytics providers, such as Google Analytics. To learn more about these analytics services and how to opt-out, please contact us at info@cubedmobile.com.
• Advertising Cookies. Advertising cookies are used to control and manage advertisements. These Cookies may collect information on whether a user has reacted to an advertisement and visited another website. Such cookies help us to offer you content and provide targeted information that is more relevant to your interests. They also help us to measure the effectiveness of our advertisements and communications. In the EEA, we deploy analytics and advertising cookies on our websites only when users have opted-in as required by applicable law.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Sites. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

To the extent required by applicable law, we will obtain your consent before using cookies or similar tools.

The providers of third-party apps, tools, widgets and plug-ins on our Sites (such as Twitter, LinkedIn and Facebook) also may use automated means to collect information regarding your interactions with these features or applications. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, Cubed Mobile is not responsible for these providers’ information practices.

How We Use the Information

1. Information relating to your use of our Site.We use information relating to your use of the Site to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use this information to ensure the security of our Services and the Site.

2. Personally Identifiable Information provided directly by you or via third parties. Except as set forth in this Privacy Notice or as specifically agreed to by you, Cubed Mobile will not disclose any of your Personally Identifiable Information. In addition to the other uses set forth in this Privacy Notice, we may disclose and otherwise use Personally Identifiable Information as described below.

• Providing the Site and our Services. We use Personally Identifiable Information which you provide to us in order to allow you to access and use the Site and in order to provide any information, products, or Services that you request from us.
• Technical support and security. We may use Personally Identifiable Information to provide technical support to you, where required, and to ensure the security of our Services and the Site.
• Updates. We use Personally Identifiable Information collected when you sign-up for our various email or update services to send you the messages in connection with the Site or CM Product. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
• Identity Verification. For Services that require identity verification, we may use the Personally Identifiable Information that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This Service may be provided through a third-party identity verification vendor.
• Auditing and Billing. We may use Personally Identifiable Information collected when you use or Site or Services, such as history of your actions, for auditing, billing, and for your future reference purposes.
• Communications with or from Cubed Mobile. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Notice. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
• Disclosure to Cubed Mobile Operations and Maintenance Contractors. We may use service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our Services to you. Our Contractors may have limited access to your Personally Identifiable Information in the course of providing their products or services to us, so that we in turn can provide our Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site or the CM Product. Access to:
  • your Personally Identifiable Information by these Contractors is limited to the information reasonably necessary for the Contractor to perform its limited function for us.
  • Government Authorities; Legal Rights and Actions. Cubed Mobile may share your Personally Identifiable Information with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personally Identifiable Information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Cubed Mobile, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.
  • Disclosure to Acquirers. Cubed Mobile may disclose and/or transfer your Personally Identifiable Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business, or assets of Cubed Mobile to which your Personally Identifiable Information relates

Retention of Personally Identifiable Information

We keep your Personally Identifiable Information for no longer than necessary for the purposes for which the Personally Identifiable Information is collected and processed. The length of time we retain Personally Identifiable Information depends on the purposes for which we collect and use it or as required to comply with applicable laws and to establish, exercise, or defend our legal rights.

Confidentiality & Security of Personally Identifiable Information

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical, and administrative security measures to keep your Personally Identifiable Information confidential and secure, and will not share it with third parties, except as otherwise provided in this Privacy Notice, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Because the Internet is not a 100% secure environment, we cannot guarantee the security of Personally Identifiable Information, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails communications are typically not encrypted and should not be considered secure.

Updating or Deleting Your Personally Identifiable Information

You have certain rights in relation to your Personally Identifiable Information. You can access your Personally Identifiable Information and confirm that it remains correct and up-to-date, choose whether or not you wish to receive material from us or some of our partners, and request that we delete or provide you with a copy of your personal data by contacting us or, where applicable, logging into the Site and visiting your user account page.

If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us via info@cubedmobile.com. If you reside or are located in the EEA, you have the right to request that we:

• provide access to any Personally Identifiable Information we hold about you;
• prevent the processing of your Personally Identifiable Information for direct-marketing purposes;
• update any Personally Identifiable Information which is out of date or incorrect;
• delete any Personally Identifiable Information which we are holding about you;
• restrict the way that we process your Personally Identifiable Information;
• provide your Personally Identifiable Information to a third party provider of services; or
• provide you with a copy of any Personally Identifiable Information which we hold about you.

We try to answer every email promptly where possible, and provide our response within the time period stated by applicable law. Keep in mind, however, that there will be residual information that will remain within our databases, access logs, and other records, which may or may not contain your Personally Identifiable Information. Please also note that certain Personally Identifiable Information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your Personally Identifiable Information to comply with a legal obligation. When you email us with a request, we may ask that you provide us with information necessary to confirm your identity.

Questions, Suggestions, and Complaints

If you have any privacy-related questions, suggestions, unresolved problems, or complaints, as well as queries regarding our processing of Personally Identifiable Information, you may contact us via info@cubedmobile.com. If you reside or are located in the EEA, you may make a complaint to the address stated above or seek a remedy through local courts if you believe that your rights have been breached.