PRIVACY POLICY

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and services, when you participate in activities on the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order. 
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service. 
• To respond to user inquiries/offer support to users. We may process your information to provide you with the requested service. 
• To fulfill and manage your orders. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. 
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as prevention of harm. 

IF YOU ARE LOCATED IN THE EU OR UK, THIS SECTION APPLIES TO YOU. The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to provide you with the requested service.
• To fulfill and manage your orders. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as prevention of harm.

Business Transfers — We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
• We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide. Advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
• To the extent these online tracking technologies are deemed to be a “sale”/“Sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”
• Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

• We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
• When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

• In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request access and obtain a copy of your personal information, (ii) to request rectifications or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing or your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”below.
• We will consider and act upon any request in accordance with applicable data protection laws.
• If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
• WITHDRAWING YOUR CONSENT: If we are relying on your consent to process your personal information, which may be expressed and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” Below or updating your preferences.
• However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• OPTING OUT OF MARKETING AND PROMOTIONAL COMMUNICATIONS: You can unsubscribe from our marketing and promotional communications at any time by or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” Below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
• ACCOUNT INFORMATION
• If you would at any time like to review or change the information in your account or terminate your account, you can Log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

• Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preferences not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
• California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

We have collected the following categories of personal information in the past 12 months” 

1. Identifiers —  Ex) Contract details, such as real name, alias, postal address, telephone or mobile and contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name 
2. Personal information as defined in the California Customer Records Statute— Ex) Name, contact information, education, employment, employment history, and financial information 
3. Protected classification characteristics under state or federal law — Ex) Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data 
4. Commercial information — Ex) Transaction information, purchase history, financial details, and payment information 

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of: 

• Receiving help through our customer support channels; 
• Participation in customer surveys or contents; and 
• Facilitation in the delivery of our Services. And to respond to your inquiries. 

We will use and retain the collected personal information as needed to provide the Services or for: 

• Category A - As long as the user has an account with us 
• Category B - As long as the user has an account with us 
• Category D - As long as the user has an account with us 

SOURCES OF PERSONAL INFORMATION 

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?” 

HOW WE USE AND SHARE PERSONAL INFORMATION 

Learn more about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?” 

WILL YOUR INFORMATION BE SHARED WITH ANYONE ELSE? 

We may disclose your personal information with your service providers pursuant to a written contract between us and each other service provider. Learn more about how we disclose personal information in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” 

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12 months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers. 

YOUR RIGHTS 

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: 

• Right to know whether or not we are processing your personal data 
• Right to access your personal data 
• Right to correct inaccuracies in your personal data 
• Right to request the deletion of your personal data 
• Right to obtain a copy of the personal data you previously shared with us 
• Right to non-discrimination for exercising your rights 
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”) 

Depending upon the state where you live, you may also have the following rights: 

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota) 
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland) 
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon) 
• Right to review, understand question, and correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Minnesota) 
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California) 
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida) 

HOW TO EXERCISE YOUR RIGHTS 

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at info@kubeko.co.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. 

REQUEST VERIFICATION 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by use, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. 

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf. 

APPEALS 

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at info@kubeko.co We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general. 

CALIFORNIA “SHINE THE LIGHT” LAW 

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us through info@kubeko.co.

• AUSTRALIA AND NEW ZEALAND
• We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).
• This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.
• If you do not wish to provide the personal information necessary to fulfill their applicable purpose it may affect our ability to provide our services in particular:
• Offer you the products or services that you want
• Respond to or help with your requests
• Manage your account with us
• Confirm your identity and protect your account
• At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us through info@kubeko.co.
• If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.
• REPUBLIC OF SOUTH AFRICA
• At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?”
• If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
• The Information Regulator (South Africa)
• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

• We may update this Privacy Notice from time to time. The updated version will be indicated by an updated “Revised” date at the top of this Privacy Notice.

• If you have questions or comments about this notice, you may email us at info@kubeko.co

• Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.