Privacy Policy

Last Update: [November 9], 2022

Introduction

Cubo World Inc.(hereinafter referred to as “Cubo”, “we” or “us”) takes your privacy very seriously, and we are committed to protecting and respecting your privacy. That value powers all of the decisions we make, including how we collect, use, share, store and respect your Personal Data. Please read this Privacy Policy carefully so that you can make appropriate decisions on an informed and freely given basis.

PLEASE NOTE, IF YOU CONTINUE USING OR ACCESSING OUR SERVICES, YOU WILL BE DEEMED THAT YOU HAVE FULLY UNDERSTOOD AND ACCEPTED, AND IS WILLING TO COMPLY WITH ALL THE FOLLOWING CLAUSES, AND THIS TERMS SHALL BECOME EFFECTIVE BETWEEN YOU AND US. IF YOU DISAGREE WITH THIS TERMS IN WHOLE OR PART, YOU SHALL IMMEDIATELY STOP USING OUR SERVICES.

Our services are currently available to users in North America and the EEA and the United Kingdom. If you are not a user in these regions, you may not receive adequate protection from this Privacy Policy, so please be aware of the privacy laws and regulations in your region. Cubo World Inc. will not discriminate against any user in regions where we are not yet able to provide services

Updates To This Privacy Policy

We may amend this Privacy Policy from time to time, and we will notify you about such changes by posting the amended version on our websites and application. Please check back periodically to ensure that you are aware of any changes, and your continued use of our application will be deemed your acceptance of these changes.

Children’s Personal Data

Unless otherwise specified, our application are designed for a general audience and are not directed to children. In connection with the Services, we do not knowingly solicit or collect Personal Data from children under the age of 13 without parental consent. If parents believe that we have unintentionally collected their children’s’ Personal Data, please contact us to delay the information via appropriate means as set forth in “Contact Details” Section of this Privacy Policy.

Scope

This Privacy Policy applies to users of【CUBO】application (“our application”) , websites and related services (the “Service”) developed and operated by us. It is important that you read this Privacy Policy together with any other privacy policy or fair processing policy we may provide on specific occasions, so that you are fully aware of when, why and how we collect and process your Personal Data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Unless otherwise prescribed in the Privacy Policy, the terms in the Privacy Policy shall have the same implications with the terms in the Terms of Service.

PLEASE NOTE THAT, this Privacy Policy doesNOTapply to the following cases:

Any information or Personal Data collected by any third party services, products, applications, websites and/or platforms, regardless whether they are accessible through our application; or
Any information or Personal Data collected by other companies or institutions that provide advertisments through our services.

In such circumstances, you should refer directly to the Privacy Policies for the relevant third party.

Please understand that we cannot know your approximate location until you log in for the first time, at which point your device information such as IP or MAC will be sent to us. Therefore, if you are outside the scope of our services, but sigh up and use our services, we consider that you agree to the contents of this Privacy Policy.

Personal Data We Collect

The term "Personal Data" under this Privacy Policy means any information relating to an identified or identifiable natural person including information that specifically identifies an individual (such as a name, address, telephone number, mobile number, e-mail address, credit card number, ACH bank information, identification number, location data, or an online identifier) and information about that individual or his or her activities that is directly linked to the individual. PLEASE NOTE that Personal Data does not include aggregate data, which is data we collect about the use of our Services or about a group or category of services or users, from which an individual’s identity cannot be discerned and all other Personal Data has been removed.

We may collect your Personal Data as follows:

a. Technical Information We Collect About You. The technical information about the device(s) and/or browsers you use may be automatically collected. This includes your IP address, browsing type, mobile model, operating systems, network type, IMEI, MAC address and other browse settings/preference, etc. (collectively “Log Data”). The Log Data is stored by us and used to identify each unique visit to our application, establish and maintain the technical connection to our application, and to provide you with better browsing experience.

b. Basic Registration Information.

To register as a Cubo personal user, you need to provide your email address, company name and preferred name to create a Cubo account, and thereafter you may optionally upload your photo.
To register as a Cubo organization user, you need to provide your organization name, team size, currency, logo (optional), preferred settings, team member’s email and role.
To access Cubo as a visitor, you need to provide your email address for access. In addition, we may send you advertisements based on your consent ( if you are a California user, you can refuse these advertisements by selecting opt-out in the settings).

c. Task Information. When you use our Services, we collect certain information about your inputs into our Services which may contain Personal Data, such as comments, attachments, and daily stand-ups entered by users of our Services.

d. Contact Details. We may collect your email address or any other contact details provided by you in case you contact us for certain services, and we will only store such information for the time necessary to address your request.

e. Geo-location information. If you are accessing our Services from a mobile device or through a mobile application, you may be asked to share your precise (GPS level) geo-location information with us so we can customize your experience on our Services. Such geolocation information may include physical locations visited (latitude & longitude). If you agree to such collection, in most cases, you will be able to turn off such data collection at any time by accessing the privacy settings of your mobile device and/or through the setting in the applicable mobile application.

f. Keyboard Active Status. We may also collect information about whether your keyboard is being typed on if the organization you joined has chosen to use our monitor feature. PLEASE NOTE that we will only record whether your keyboard is active or inactive, instead of what you are typing.

g. Public information. We may also collect information about you from publicly available sources. Information you make publicly available in any public or open forum, such as on a social network, may be considered public information for the purposes of this Privacy Policy, and may be accessed and collected by us. Please be aware that any content or information you share with or provide to third parties using or related to your use of our Services is neither private nor confidential. We are not responsible for any content or information you post or share with third parties. If you do not wish for certain information to be public, please do not share it publicly.

h. We may also collect other information about you, your devices and your use of our Services, in ways we describe at the time we collect the information or otherwise with your consent.

We DO NOT collect any special categories of Personal Data about you (including 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).

How We Use Your Personal Data

We will use the Personal Data we collect about you in accordance with the laws of applicable jurisdictions in the following ways:

a. To enter into and to perform our contract with you, or to perform any steps you require from us before entering into a contract with you;

b. To communicate with you, including but not limited to respond to your request for any help with our Services or for exercising your rights with respect to your Personal Data;

c. To check your online activities for the advertising purpose (if you permit);

d. To pursue our legitimate interests（or those of a third party）as we deem fit and necessary, where your interests and fundamental rights do not override those legitimate interests of ours (or any third party’s), such as:

to understand, improve, optimize and develop our application;
to conduct research and monitor the quality of our application;
to respond to complaints, hearings, arbitration, law suits or other governmental or regulatory proceedings;

e. To comply with our legal obligations under relevant laws, regulations, and orders (including subpoenas), injunctions, or any other legal documents issued by the court or competent governmental or regulatory authorities.

PLEASE NOTE THAT, we do not sell or share your Personal Data with any third parties for their direct marketing, but those third parties who provide us with SDKs may collect your Personal Data directly, please refer to “How We Share Your Personal Data” Section for detailed information.

Communications

We engage in Services and promotional communications, through email, phone, SMS and notifications.

Services Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Services. You can control your communications and notifications settings from your User Profile settings, or otherwise in accordance with the instructions that may be included in the communications sent to you. However, please note that you will not be able to opt-out of receiving certain Services communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify cubo.to at any time by sending an email to：contact@cubo.to, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.

How We Share Your Personal Data

We will not share your Personal Data with companies, organizations or individuals other than our service providers, except in the following circumstances:

a. Sharing with explicit consent. We will share your Personal Data with other parties with your explicit consent;

b. Sharing as required by laws. We may share your Personal Data as required by laws, regulations, litigation, dispute resolution, or by administrative or judicial authority in accordance with laws;

c. Sharing with our vendors. We may share your information with our vendors that perform support and other services in connection with our application as follows:

with advertising service providers and advertising partners that enable us to conduct and display advertising on our application, website, and third-party sites, applications, or social media platforms;
with third parties for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, for use in aggregate or anonymous form, and for other purposes with your permission;
with the following SDK providers:
AWS. AWS is a cloud platform that provides compute, storage, and databases services. For more information about how AWS collect and use your Personal Data, please refer to its privacy policies by the following link:https://aws.amazon.com/privacy
Twilio. Twilio is a cloud communications platform that provides software developers with building blocks to add communications to web and mobile applications or manage email applications (such as through our SendGrid products and services).For more information about how Twilio collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.twilio.com/legal/privacy
Xuifei. Xunfei provides Voice-to-Text Services for Applications. For more information about how Xunfei collect and use your Personal Data, please refer to its privacy policies by the following link:http://x.xunfei.cn/mall/privacy.html
Qiniu. Qiniu is a multimedia data processing platform providing picture, video and audio storage services for applications. For more information about how Qiniu collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.qiniu.com/agreements/privacy-right
Agora. Agora provides full IM capabilities for applications, such as single chat, group chat, and chat rooms. For more information about how Agora collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.agora.io/cn/privacy-policy
Auth0 is an easy to implement, adaptable authentication and authorization platform.For more information about how Auth0 collect and use your Personal Data, please refer to its privacy policies by the following link:https://auth0.com/security
Clearout. Clearout Is a platform for email authentication and authorization. For more information about how Clearout collect and use your Personal Data, please refer to its privacy policies by the following link:https://clearout.io/privacy-policy
Nylas. Nylas is a scheduling and calendar editing service that provides text and date storage for applications.For more information about how Nylas collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.nylas.com/privacy-policy
Stripe. Stripe Is an internet payment kiosk platform that provides application functionality with the payment module.For more information about how Stripe collect and use your Personal Data, please refer to its privacy policies by the following link:https://stripe.com/privacy
Mailgun. Mailgun Is a platform for processing complex and large volumes of email, providing email processing services for software developers and technicians. For more information about how mailgun collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.mailgun.com/legal/privacy-policy
Mailreach. Mailreach Is a mailbox warm-up platform, for applications to provide fast and efficient interaction features such as mail services.For more information about how Mailreach collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.mailreach.co/privacy-policy
Mailchimp. Mailchimp Is an email marketing platform that provides applications with personalization, automation, and premium content editing features.For more information about how Mailchimp collect and use your Personal Data, please refer to its privacy policies by the following link:https://www.intuit.com/privacy/statement

Because Cubo World Inc. is based in the United States, information collected in other countries/regions is usually transmitted to the United States for processing. Cubo World Inc. participates in the EU-US Privacy Shield frameworks II and Swiss-US Privacy Shield frameworks ( as to Frameworks ) regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland.

In the event of any conflict between this Privacy Policy and the Frameworks, the terms of the Frameworks shall govern.

Cookies

We use cookies and other similar technologies(“Cookies”) to help us remember your information so you will not have to re-enter it, tailor our application around your preferences, and otherwise enhance your experience using our application. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the game) or web browser (in the case of the website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device.

How We Protect Your Personal Data

We endeavors to take appropriate measures to safeguard and secure your Personal Data collected by us. For example, we have established internal procedures to restrict employees to access such information, only employees who need to use the information for performing their duties will be allowed to access such information, and they are required to comply with confidential policies. Although we endeavors to protect your Personal Data, PLEASE NOTE that information sent over the internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not liable for any of such interception. You SHALL take care with regard to how you handle and disclose your Personal Data or any username or password that you are required to use to access services on our applications.

International Transfer

Except as otherwise stated in this Privacy Policy, any Personal Data we collected will be stored on the server located in the United States. In case we need to transfer any of your Personal Data out of the United States, we will take steps to ensure that your Personal Data continues to enjoy appropriate protections.

If any change happens to our international transfer policy and we need to transmit your Personal Data outside of the United States, we will update this Privacy Policy and notify you of such change.

Your Rights and Controls

You have rights under applicable data protection law in relation to our use of your Personal Data, including:

(a)Your choices about information provided by you.If you do not want to provide us your Personal Data, then you can choose not to provide it. However, if you fail to provide us with Personal Data, we may unable to provide you with certain product or service；

(b) Objection. You have the right to object to certain uses of your Personal Data, including direct marketing (by click unsubscribe link in the email), processing based on legitimate interests, and processing for purposes of scientific or historical research and statistics, on grounds relating to your particular situation;

(c) Erasure. You have the right to request the deletion of your Personal Data, or restrict its use, in certain circumstances (for example you can request us to erase your contact detail where it is no longer necessary for the purpose for which it was collected unless certain exceptions apply);

(d)Access Your Data and Portability:You can ask us to confirm we process your Personal Data and for a copy of your Personal Data in a machine readable form；and

(e) Withdrawing Consent. If we are processing your Personal Data based on your consent you can withdraw your consent at any time by email us and specifying which consent you are withdrawing. PLEASE NOTE that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

(f) Opting of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list——however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

Access your account settings and update your preferences.

PLEASE NOTE that, if your account on our application is not registered by yourself, but provided by your company, then your company shall be the data controller instead of us, and therefore, you may need to exercise the rights set out above through your company.

If you have any question about these rights or you would like exercise any of them, please contact us via appropriate means as set forth in “Contact Details” Section of this Privacy Policy. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. Please note that your ability to access or control your Personal Data will be limited in some cases, as required or permitted by applicable law.

If you are a resident in the EEA or UK or Switzerland and you believe we are unlawfully processing your personal information, please contact us at:contact@cubo.to; you also have the right to complain to your local dara protection supervisory authority.

Cubo World Inc. are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We may be required to disclose personal information that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

European Data Protecticon Specific Information

Data Subjects Rights

If you are in the EEA, Switzerland, or the UK, your rights in relation to your personal data processed by us as a controller specifically include:

Right of access and/or portability: You have the right to access any personal data that we hold about you and, in some circumstances, have that data provided to you so that you can provide or “port” that data to another provider;
Right of erasure: In certain circumstances, you have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected);
Right to object to processing: In certain circumstances, you have the right to request that we stop processing your personal data and/or stop sending you marketing communications;
Right to rectification: You have the right to require us to correct any inaccurate or incomplete personal data;
Right to restrict processing: You have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).

To exercise your rights, please click here. If you have any other questions about our use of your personal data, please send a request at the contact details specified in the Contact Us section of this Privacy Statement. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

You also have the right to lodge a complaint to a data protection authority. For more information, please contact your local data protection authority.

Legal Basis for Processing Personal Data

We only use your information in a lawful, transparent, and fair manner. Depending on the specific personal data concerned and the factual context, when Cubo processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction:

As necessary for our contract:When we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Cubo products and services, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all products and services;
Consistent with specific revocable consents:We rely on your prior consent in order to utilize cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage. You have the right to withdraw your consent at any time by visiting our cookie management tool, available Cookies Settings;
As necessary to comply with our legal obligations:We process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;
To protect your vital interests or those of others:
We process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
As necessary for our (or others’) legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data:We process your personal data based on such legitimate interests to (i) enter and perform the contract with the account
owner and/or reseller providing you with the products and services (which includes billing, compliance with contractual obligations, and related administration and support); (ii) develop, test, and improve our products and services and troubleshoot products and services; (iii) ensure authentication, integrity, security, and safety of accounts, activity, and products and services, including detect and prevent malicious conduct and violations of our terms and policies, prevent or investigate bad or unsafe experiences, and address security threats; (iv) send marketing communications, advertising, and promotions related to the products and services; and (v) comply with non-EEA laws, regulations, codes of practice, guidelines, or rules applicable to us and respond to requests from, and other communications with, competent non-EEA public, governmental, judicial, or other regulatory authorities, as well as meet our corporate and social responsibility commitments, protect our rights and property and the ones of our customers, resolve disputes, and enforce agreements.

California Consumer Privacy Act (“CCPA”)

If you are a California resident, the supplemental terms in this section may apply to you. PLEASE NOTEthat we may request proof of California residency before responding to requests made under this section.

a. Right to Opt-out. We do not sell your Personal Data or share, exchange your Personal Data with any third party. Therefore, we do not offer an opt-out to the sale of Personal Data as required by CCPA.

b. Right to know. You may submit a verifiable request for us to provide the following information, which we may be able to provide you for no more than twice in a 12-month period with free of charge:

The specific pieces of Personal Data we have about you;
The categories of Personal Data we collected, sold, or disclosed for a business purpose about you within the last 12 months;
The categories of sources from which the Personal Data was collected;
The purposes for which the information was collected or sold; and
The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.

If possible, we will provide this information to you in a readily usable format that allows transmission to another entity.

c. Right to Data Portability.You have the right to request certain copies of your Personal Data you have provided to us, to move data from one company to another (often called the right to data portability). PLEASE NOTE that your recordings will be stored on your local devices, and we therefore are not able to provide you with any copies; and

d. Right to Delete. You may submit a verifiable request for us to delete the Personal Data we have collected about you. We may retain Personal Data necessary to: (i) protect our business, systems, and users from fraudulent activity; (ii) comply with law enforcement requests pursuant to lawful process; or (iii) for scientific or historical research.

e. You WIll NOTbe discriminated (such as price discrimination) for exercising your rights under CCPA.

Please contact us via appropriate means as set forth in “Contact Details” Section of this Privacy Policy if you would like to exercise your rights under this section.

If you are a Nevada resident, the supplemental terms in this section may apply to you. PLEASE NOTE that we may request proof of Nevada residency before responding to requests made under this section.

According to Nevada Act, Nevada residents who have purchased goods or services from us shall be entitled to opt out of the sale of covered information for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered Information” including (i) a first and last name; (ii) a home or other physical address which includes the name of a street and the name of a city or town; (iii) an email address; (iv) a telephone number; (v) a social security number; (vi) an identifier that allows a specific person to be contacted either physically or online; (vii) any other information concerning a person collected from the person through our website or online service and maintained by us in combination with an identifier in a form that makes the information personally identifiable.

Again, we DO NOT sell your Personal Data or share, exchange your Personal Data with any third party. Therefore, we DO NOT offer an opt-out to the sale of Personal Data as required by Nevada.

Security of Personal Data

The security, integrity, and confidentiality of your Personal Data are extremely important to us. We will use various technologies and administrative measures to protect your Personal Data which have been collected and/or stored by us from being lost, being misused, unauthorized accessed or leaking. In addition, all processing by our staff are based on their work assignments and bound by confidentiality obligations.

PLEASE NOTE that, despite our best efforts to provide security protections for your Personal Data, due to limit of technology as well as various possible malicious means in the internet industry, no security measures are perfect or impenetrable. We will regularly review our security procedures to consider appropriate new technology and methods.

Where We Store Your Personal Data

Generally, we will only retain your Personal Data (such as email address) on our server located in the United States. However, if you provide us with your Personal Data for addressing technical problems or feedback, we may collect and use your technical information about the device(s) and/or browsers (including without limitation your IP address, browsing type, mobile model, operating systems, network type and other browser settings/preference) you may use, and such data may be transferred to and stored on where we located to the extent necessary to provide support and respond as per your request.

How Long We Store Your Personal Data

Generally, we do not store your Personal Data unless we otherwise expressed in this Privacy Policy. In the case we need to retain your Personal Data for the purposes stated in this Privacy Policy, such retention will be limited to the necessary period which permitted by applicable laws and regulations. For example, when you contact us for feedback, complaints, bug reports, or questions regarding your Personal Data, we will store such data and your personal contact details (such as email address) to the extent for responding your request, and then immediately delete the same properly, EXCEPT THAT we have other legitimate basis (such as complying with our legal obligations, resolving disputes, and enforcing our agreements) for keeping such data.

PLEASE NOTE THAT, the recordings or any other contents you create or edit with our application will be stored in your local folder on your device, and will not be stored by us.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your rights in respect of your Personal Data, please contact us in the following ways:

Full name of legal entity: Cubo World Inc.

Email address: contact@cubo.to

Address: 108 West 13th Street, Wilmington, Delaware 19801, USA