Cubios Inc. takes care of your personal data and does everything possible to protect it. This Privacy Notice is written to help you understand what your personal data is collected, stored and used, and what happens to it when you use our website wowcube.com (“website”).

For convenience, this policy also describes the data that we collect when using Cubios web-platform, our mobile applications and any products and services offered by Cubios (all together as the “Service”).

In this Privacy Notice we answer the following questions:

1. Who are we?

We are Cubios Inc., registered in the 919 North Market St, Suite 950. Wilmington, DE 19801 Hereinafter, Cubios Inc., will be referred to as "we" and "our".

We are the controller of personal data of our clients and users which means that we determine what, for what purpose and how your personal data will be processed.

We are processors of personal data of invited users where controllers are our clients.

If you have any questions, you can contact us by sending an email to [email protected]

You can also send us a letter at the address: 919 North Market St, Suite 950. Wilmington, DE 19801.

To our European users

You can contact us by sending an email to [email protected] or you can also send us a letter at the address: Denis Chetverikov, WowCube 1075, Cyprus, Nicosia, Chytron 12, BLOCK B, Office 305.

2. What is the Privacy Notice covered by?

This Privacy Notice applies to our website and any use of the WowCube System and platform.

Website Address: wowcube.com

3. What data do we collect and why?

The data we process is divided into two categories: technical information and data that is provided to us by user, invited user* and client.

Invited user is the client's employee.

Technical information. When you visit our website, some data is collected automatically. We need technical data to operate, maintain, and improve our website. This includes data such as IP address, UTM parameters, geolocation, device type, browser type, cookies, and data about your interaction with the website - session ID.

The session ID includes your interaction with the website, the name of the website from which you went to our website, the functions you use, the pages viewed on our website, the way you use our website, and the actions you take if such actions are present.

Data provided by the user. For full interaction with our website and in order to provide you services we collect name and email.

Data provided by client. To perform a contract, as well as to provide the service, we need the following information: name, surname, contact details (email, phone number), company information (code, position, address, representative’s data), payment data, address.

Data provided by invited users. To provide the service, we need the following information: name, surname, contact details (email, phone number), company position/role, geolocation.

Once again, briefly about what personal data we collect:

PLEASE NOTE. We knowingly do not process the personal data of users under the age of 16 without consent from legal representative(s). If you are such a user, or you are the legal representative of the user, please let us know by email: [email protected].

4. How long do we keep your data?

We store personal data in the following categories:

● user’s data

We store personal data of users for the duration of the service and 24 months after completion.

● client’s data

We store personal data of clients for the duration of the contract and 36 months after completion.

● invited user’s data

We store user’s personal data for the duration of the contract with the client and 36 months after completion.

After the expiration of this period, we anonymize the data and store it for statistics and analytics.

Data processed based on your consent we are processing during the performance of the contract/ while your interaction with our service and 24 months after or until you withdraw your consent.

However, you can exercise your right to delete your data. In this case, your data will be deleted from our servers within 30 days of your request.

5. Do we share data with third parties?

We use your personal data to perform a contract and for communication between us and clients and between us and users. We share your personal data with our contractors in order to perform a contract. Also, we transfer your data on the following grounds:

Consent. We transfer your personal data based on your explicit consent.

Compliance with the law. We will disclose your personal data to third parties to the extent that it is necessary:

● to comply with a government request, court order, or applicable law;

● to prevent unlawful use of our website or violation of our the Terms and Conditions;

● to protect against claims of third parties;

● to help prevent or investigate fraud.

Transfer to third parties: We transfer your personal data to third parties on the basis of public offer for processing on our behalf, subject to technical and organizational measures to protect your personal data. We may transfer your data to certain companies, consultants, and contractors hired to provide certain services on our behalf.

We will ask for your consent unless the transfer of data is part of performance of a contract.

6. Do we do data transfer outside the European Economic Area?

The personal data we collect is stored on servers in Germany and Finland. By default, the data is stored there but we may need to process your personal data in another country. If a transfer is required, we will take the necessary data protection measures and ask for your consent. However, if a data transfer is required to perform a contract, we have the right to do so without your consent.

7. Do we use cookies?

We use cookies necessary for the functioning of the website. Using cookies, we receive the technical information specified in clause 3 and our Cookie Policy.

If you want to disable cookies, then you can find instructions for managing your browser settings at these links:

● Internet Explorer

● Firefox

● Safari

● Microsoft Edge

● Chrome

● Opera

● Vivaldi

8. What rights do I have regarding my data?

You, as subjects of personal data, have the following rights:

● The right to access information. You can request an explanation of the processing of your personal data.

● The right to portability. You can request all the data that you provided to us, as well as request to transfer data to another controller.

● The right to restrict processing. You may partially or completely prohibit us from processing your personal data.

● The right to file complaints. If your request was not satisfied, you can file a complaint to the regulatory body, the Data Protection Inspectorate.

● The right to be forgotten. You can send us a request to delete your personal data from our systems.

● The right to withdraw your consent. If you once gave us your consent, you have the right to withdraw it any time.

To exercise your rights, write us an email at [email protected].

If your request was not satisfied, you can file a complaint to the regulatory body, the Berlin data protection authority by email at [email protected] or by mail at 10969 Berlin, Friedrichstr. 219.

9. How do we update our Privacy Notice?

This Privacy Notice and the relationships falling under its effect are regulated by the GDPR. Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on our website. If significant material changes are made that affect your privacy and confidentiality, we will notify you by email or display information on the website and ask for your consent.

10. California privacy rights

We make these disclosures to those visiting our websites who reside in California which supersede and replace any conflicting disclosures found elsewhere on our websites as well as reflect your privacy rights granted by the California Consumer Privacy Act (CCPA).

Opt-out of disclosure for direct marketing purposes. The California laws allow its residents to learn the identities of entities that received their personal data for marketing purposes and the categories of information disclosed. You may request such information by contacting us by e-mail ­­­­­[email protected].

Please be aware that this opt-out does not prohibit our disclosure of personal data for any purpose other than direct marketing. The data we process and share may include your name, address, email address, and telephone number.

Automatic gathering of information. We collect data that you provide to us online, and through websites of unaffiliated third parties.

Automatic gathering of information by third parties. When you visit our websites, third parties can collect personal data about your online activities over time and across different websites pertaining to your visit to or use of our and other websites.

11. Do-not-track requests.

California residents visiting our websites may request that we do not automatically gather and track information pertaining to their online browsing movements across the Internet. Such requests are typically made through web browser settings that control signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personal data about an individual consumer's online activities over time and across third-party websites or online services. We currently do not have the ability to honor these requests. We may modify this Notice as our abilities change.

12. California residents’ data protection rights.

The CCPA has extended California residents’ data protection rights. However, we have already guaranteed all these rights and described them precisely in this Notice as well as a means of rights exercising. Please refer below to investigate.

Right to be informed. Please find a list of personal data we collect about you and your activity, sources and business purposes of personal data collection, and third parties we may share your personal data with in Section 3 - 6 of the Notice.

Your Right of access, Data portability, and Right to delete are prescribed by Section 7 of the Notice.

You can exercise these rights any time by contacting us via email at [email protected].

Notice, the CCPA envisages some specific requirements related to the exercising of these data protection rights. Considering them we may:

● respond to your request within forty-five (45) days of receiving the request;

● provide you with personal data we collected about you no more than twice in a 12-months period (categories and specific pieces of collected personal data, business purpose and sources of collection, categories of third parties personal data is shared with);

● NOT provide you with personal data if we cannot verify your identity. You shall provide us with sufficient information allowing us to verify you as the person about whom we collected personal data. However, we do consider requests made through your Account sufficiently verified.

● NOT transmit your personal data to another entity.

Also, please be aware that we are allowed to maintain personal data after the deletion request is received as permitted by the CCPA (for instance, for the purposes of detection of security incidents, repair errors, compliance with legal obligations, transaction completion).

We want to specifically note that Cubios Inc. does not sell, rent, or trade your personal data to anyone.

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Learn more about who we are, how you can contact us, and how we process personal data in our Privacy Policy.

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