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 firstname.lastname@example.org. 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:
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:
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.
Cookies and Other Technologies
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.
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.
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 email@example.com. If you reside or are located in the EEA, you have the right to request that we:
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 firstname.lastname@example.org. 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.
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2019 will receive information regarding 2018 sharing activities).
To obtain this information, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
Under the California Consumer Privacy Act (“CCPA”), California residents have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. Cubed Mobile does not sell any of the data we collect about you. If you would like to exercise any of the other rights afforded to you, contact us at firstname.lastname@example.org.
Cubed Mobile’s Sites are primarily operated and managed on servers located and operated within the EEA. In order to provide our products and Services to you, we may send and store your Personally Identifiable Information (also commonly referred to as personal data) outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your Personally Identifiable Information. We are committed to protecting the privacy and confidentiality of Personally Identifiable Information when it is transferred. If you reside or are located within the EEA and such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as you would have within the EEA to the extent feasible under applicable law.
Please note that we review our privacy practices from time to time and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our Site. We will notify you of any material change to this Privacy Notice by posting a notice on our Site’s homepage for a reasonable period of time following such update or by sending an email to the email address associated with your user account, and by changing the effective date (located at the top or bottom of this page). Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Notice
Cubed Mobile strongly believes in protecting the privacy of children. Any use or access by anyone under the age of 16 is prohibited. In line with this belief, we do not knowingly collect or maintain Personally Identifiable Information on our Site from persons under 16 years of age, and no part of our Site is directed to persons under 16 years of age. If you are under 16 years of age, then please do not use or access this Site at any time or in any manner. We will take appropriate steps to delete any Personally Identifiable Information of persons less than 16 years of age that has been collected on our Site without verified parental consent upon learning of the existence of such Personally Identifiable Information.
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