Privacy Policy

CUBAKA LTD PRIVACY POLICY

Protecting your private information is our priority. This Privacy Policy applies to the website and services of Cubaka Ltd and governs data collection and usage.

Who we are:

Cubaka Ltd means Cubaka Limited,

Registered in England with number  06544244

Registered office at Cubaka Ltd, 60 Great Portland Street, London, W1W 7RT

Trading as Cubaka Ltd.

 

Collection of your Personal Information

Cubaka Ltd may collect and process personal data, such as your name and email address if you enter these on the contact form on our website or to fulfil our contractual obligations – to provide our services, invoice and receive payment for services, send legal updates, news and information about our services and related services. We may gather additional personal or non-personal information in the future.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of services you have purchased from us.

  • Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device model and other technology on the devices you use to access this website or our software.

  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

  • Usage Data includes information about how you use our website and services.

  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) or information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your name, email address and contact details in person, or by filling in forms on our website or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

  • request our products or service

  • meet with one of our employees or consultants;

  • participate in an event which we have organised;

  • complete a form on our website requesting us to contact you;

  • subscribe to our publications or newsletter;

  • request marketing to be sent to you;

  • enter a competition, promotion or survey;

  • submit an application for a role within Cubaka Ltd; or

  • make a complaint or give us some feedback.

Information we collect automatically.  

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

In your use of our website or services (including receiving our newsletter), certain Usage Data is transmitted to us such as the device you are using, your IP address and other such data.

Third parties or publicly available sources.

We may receive personal data about you from various third parties as set out below

  • Technical Data or Usage Data from analytics providers or search information providers.

  • Employment, Identity and Contact Data from third party recruitment agencies.

If you fail to provide personal data

 If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide services to you, we will not be able to provide these services to you. Purposes for which we will process your personal data

Most commonly, we will use your personal data in the following circumstances:

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Transfer of Personal Data

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and applicable law.

We make sure to enter into written agreements with these third parties to make sure that they comply with similar and equally stringent undertakings of privacy and confidentiality.

We may share your personal information with:

Affiliates of Cubaka Ltd;

  • Our third-party service providers who perform functions on our behalf in connection with the operation of our business such as IT service providers and system administrators, third parties who host and manage data or provide programming or technical support, deliver our products and services, conduct reference checks on candidates on our behalf etc;

  • Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services; an

  • Our third-party analytics partners to analyse website traffic and understand customer needs and trends or our third-party marketing service providers to help us to communicate with.

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. 

Our appointed data processors include:

             I.                  Prospect Global Ltd (trading as sopro) Reg. UK Co. 09648733. You can contact SoPro and view their privacy policy here: http://sopro.io.  Sopro are registered with the ICO Reg: Z123456 their Data Protection Officer can be emailed at: dpo@sopro.io.

Transferring your personal information outside of the EEA

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent data protection law. It may also be processed by staff who are situated outside the EEA who work for us, for a company in the same group as us or for one of our suppliers. This include staff engaged in, among other things, the fulfilment of service deliver, the processing of payment details and the provision of support services.

Where personal data is transferred in relation to providing our services we will take all steps reasonably necessary to ensure that it is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism which may include by entering into EC approved standard contractual clauses relevant to transfers of personal information (see http://ec.europa.eu/justice/dataprotection/internationaltransfers/transfer/index_en.html) and that it is treated securely and in accordance with this privacy policy.

Cubaka Ltd will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

a)          conform to the edicts of the law or comply with legal process served on Cubaka Ltd or the site

b)         protect and defend the rights or property of Cubaka Ltd; and,

c)          act under exigent circumstances to protect the personal safety of users of Cubaka Ltd, or the public.

Data retention

Cubaka Ltd will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Data reviewed regularly for relevance. Any data deemed no-longer relevant is deleted. Cubaka Ltd shall keep your personal data for at least two years from the date of the last interaction. Cubaka Ltd shall keep staff and consultant personal data for at least seven years. Cubaka Ltd shall keep emails of clients and prospective clients for as long as it has a legitimate interest to do so. You can request details of retention periods for different aspects of your personal data by contacting us at dpo-hub@next15.com

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analytical, research and statistical purposes and to help us to improve our products and services, in which case this is no longer personal data and we may use this information indefinitely without further notice to you.

Use of Cookies

The Cubaka Ltd website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. You can find out more about how Cubaka uses cookies over on our cookie policy.

If you wish to withdraw consent for any reason, please contact dpo-hub@next15.com.

Opt-Out & Unsubscribe

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from Cubaka Ltd by contacting us or selecting the “Unsubscribe” option on their email.

Your Legal Rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

  • The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection regulator.

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Changes to this Privacy Policy

Cubaka Ltd will occasionally update this Privacy Policy to reflect company and customer feedback and any changes in data protection regulations. Cubaka Ltd encourages you to periodically review this Privacy Policy to be informed of how Cubaka Ltd is protecting your information.

Contact Information

Cubaka Ltd welcomes your questions or comments regarding this Privacy Policy. If you believe that Cubaka Ltd has not adhered to this Privacy Policy, please contact Cubaka Ltd at:

Our DPO is Amanda Hamilton.

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: Cubaka Ltd

Email address: dpo-hub@next15.com

Attn: Amanda Hamilton, Data Protection Officer, Cubaka

Postal address: 60 Great Portland Street, London, United Kingdom, W1W 7RT