Privacy Policy

CUBE ONLINE PRIVACY POLICY

Last updated 12 August 2022

Digital Services Group Pty Ltd trading as Cube Online ABN 20 619 561 161 (referred to in this policy as “Cube”, “We”, “Our” or “Us”) is committed to protecting your Personal Information. This Privacy Policy explains how We collect, use and share information and outlines the security measures We have in place to protect that information. This policy covers all Personal Information you provide to Us as Our customer.

1. GENERAL

a. “Personal Information” referred to in this policy means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Examples of Personal Information are name, gender, date of birth, home address, home or personal telephone numbers, email address and workplace contact details. Personal Information may also include information We may collect about your individual preferences.

b. Cube has developed and implemented this Privacy Policy with respect to Personal Information to reflect best practice on privacy policies in accordance with the requirements to the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.

c. We are committed to safeguarding personal privacy. We recognise that you have a right to control how your Personal Information is collected and used. Unless given consent to do otherwise, We will only collect and use Personal Information in accordance with this Privacy Policy.

2. INFORMATION WE COLLECT

2.2 Information you provide to Cube

a. Contact Information: includes name, role at Our customer’s business, email address, phone number, mobile number and business address.

b. Correspondence Information: includes email or mail correspondence, call recordings and notes of conversations.

c. Experience Information: includes information about your experience in business, where you choose to provide this to Us.

d. Payment Information: When you provide credit card details to your account, We use a third-party service provider to collect and store your payment information.

2.2 Information We collect when customers use Our services

a. Usage Information: includes information about how you use Our website and services.

b. Technical Information: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the website.

c. Cookies: Our website uses cookies, pixel tags or similar technologies to distinguish you from other users of Our website. Our third-party suppliers collect information about your online activities over time. Cookies or similar technologies are a small files of letters and numbers that We store on your browser. Cookies contain information that is transferred to your computer’s hard drive.

d. Third-party information: where you link a third-party account to your customer account with Us, We may receive additional information about you.

e. Customer content: As part of Our offering, We provide a platform on which you can host data that is controlled by your organisation. In doing so, We act as a data processor only and Our obligations in respect of that are detailed in Our agreement with you and Our Terms and Conditions. You remain the controller of that information and it is your responsibility for determining how that data is used.

3. HOW WE USE YOUR PERSONAL DATA

We will only use the Personal Information collected, as the law allows Us to. Most commonly We will use your Personal Information in the following ways:

a. To provide, maintain and improve the functionality of the website and Our services to you, including the provision of information to you, relating to the content available;

b. To communicate with you in response to questions or queries and otherwise provide customer support;

c. To verify your identity;

d. To market Our products, services or updates of those products or services including promotions or advertising materials that may be useful or relevant or otherwise of interest to you;

e. To send you any technical, administrative or legal notices important to Our website or services;

f. To facilitate payment transactions;

g. For internal record keeping including website or service usage, maintaining databases and administration of Our products and services;

h. For compliance purposes as may be required by applicable laws and regulations or to enforce Our terms and conditions or other legal right, or as requested by any judicial process or government agency; and

i. For other purposes We may specify at the time the information is collected.

For the purposes described above, Personal Information may be shared with selected Cube service providers, promotional partners and their related bodies corporate, and other trusted third parties (and their directors, servants, contractors and agents) either in Australia or overseas. Failure to provide Personal Information may result in Cube being unable to provide you with certain services, content, information, upcoming opportunity, promotion, offer, event or product and/or accept contact (where applicable).

4. SENSITIVE INFORMATION

We will only collect sensitive information (as defined in the Privacy Act 1988 (Cth))with your consent and where you provide it to use directly. Where you provide Us with any sensitive information, We will only use this information for the purposes stated at the time of collection and will only share this information with Our trusted third parties in the manner stated on the website or in this Privacy Policy.

5. CHILDREN

Personal Information will not be collected about any person who is known by Cube to be under the age of eighteen (18) without the consent of a parent or legal guardian. Persons under the age of eighteen (18) may only use Our website and services with the involvement and consent of a parent or legal guardian.

6. DISCLOSURES

We may share or otherwise disclose Personal Information We collect from you or about you, in accordance with clause 3 above, as described below or otherwise disclosed to you at the time of collection:

a. Our IT support and hosting companies, providing Us with IT services;

b. Google Analytics or similar, for analysis or website use;

c. Third-Party service providers retained in connection with the provision of Our website and services;

d. Third-party App Integrations that you choose to connect to your account on Our website or services;

e. Social networking platforms or other online services that you choose to connect to Our website or services (such as facebook, Instagram, Yelp). You understand and agree that use of such social networking websites will be governed by the privacy policies of those third-party websites.

f. Third parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them. If a change happens to Our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.

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

Some of Our third-party service providers have servers or operations based outside of Australia. Where they do, We ask that they have appropriate protections in place so that We know all Personal Information will be looked after as though it were subject to Australia’s privacy laws.

7. LINKS TO OTHER WEBSITES

Our website may, from time to time, contain links to the websites of other organisations which may be of interest to you. We do not own or operate these websites and their inclusion cannot be taken to imply any endorsement or validation by Us of the content of these websites. This Privacy Policy does not relate to these third-party websites.

8. COMMUNITY SITES

Our website and services may include sharing features, chat areas, messaging services, blogs, forums, wikis and similar. By using any of these community sites, you acknowledge and agree that information you post or otherwise make public may be available to the public and remain public even after you cancel your account. This Privacy Policy does not relate to these community sites.

9. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally list, used or access in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on Our instructions, and they are subject to a duty of confidentiality. However, as Our services are hosted electronically, We can make no guarantees as to the security of privacy of your information.

10. YOUR RIGHT OF ACCESS

You have the right to access and review your personal information that may be recorded on Our systems or database. Information may be reviewed by contacting Our privacy officer at the contact details contained in this Privacy Policy. We may charge a reasonable administrative fee for providing you access to the requested Personal Information. Please allow 30 days for this request to be processed.

11. CHANGING OR DELETING PERSONAL INFORMATION

a. Personal Information contained in Our systems or database may be amended or your preferences for contact from Us can be changed. You can change these details yourself in the Contact Data section of your account with Us, or you may contact Us in the contact details contained in this Privacy Policy. Please allow 30 days for any request to Us to be processed.

b. In the same way, a request may be made to delete or anonymise Personal Information and all reasonable steps will be made, except where it is required for legal reasons. Deletion or anonymisation may result in Us being unable to facilitate or provide you with information about certain transaction or inability to provide you with Our Services or access to Our website.

c. We are not responsible from removing your Personal Information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy.

12. CUBE CONTACT DETAILS

If you have any questions about Our Privacy Policy, or any problems or complaints about how We have collected, used, stored, handled and/or disclosed your Personal Information, please contact Our privacy officer via one of the following channels:

Address: Privacy Officer

Digital Services Group Pty Ltd t/as Cube Online

Suite 2, Level 2

61 Dunning Avenue

Rosebery NSW 2018

Telephone: 1300 423 618

Email: [email protected]

13. CHANGES TO THIS PRIVACY POLICY

In order to keep with changing legislation and best practice, We may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on Our Website, so We encourage you to check this Privacy Policy from time to time. If We materially change the way in which We use or disclose your Personal Information previously collected from you through the website or services, We will notify you by your contact details contained in your account with Us.

Privacy Policy

Cube Local’s Privacy Notice

We trade as “Cube Local” but our company name is Digital Services Group Limited (company number 13857570). At Cube Local, we respect your privacy and are committed to protecting your personal data. This privacy notice tells you about how we look after your personal data when you visit our website or any app that we operate under the Cube Local brand or otherwise when you work or communicate with us and it tells you about your privacy rights and how the law protects you.

This policy covers all information you provide us as our customer. It does not relate to data that you or your organisation hold about other individuals. Please see section 6 below for further information about that.

1 .Important information and who we are

This privacy notice aims to give you information on how Cube Local collects and processes your personal data through your use of our website, any app that we operate under the Cube Local brand, or otherwise when you communicate or interact with us in the course of business.

Digital Services Group Limited (trading as Cube Local) is the data controller of your personal data. We are responsible for its security and for ensuring that we use it only for the purposes outlined in this Privacy Notice.

If you have any questions about this Privacy Notice, including any requests to exercise your legal rights referred to at section 10 below, please contact us using the details set out below.

Contact details

We are: Digital Services Group Ltd, with a registered office at Suite 5 Corum 2 Corum Office Park, Crown Way, Warmley, Bristol, England, BS30 8FJ.

If you need to get hold of us for any reason in connection with your personal data, please email us at c[email protected].

Although you have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), we would, of course, appreciate the chance to deal with your concerns about data protection directly so please contact us in the first instance.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Contact Data includes name, role at business, email address, phone number, address.
Correspondence Data includes email correspondence, notes of conversations.
Business Experience Data includes information about your experience in business where you choose to provide this to us.
Usage Data includes information about how you use our website.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

3. How is your personal data collected?

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

Direct interactions. We collect the majority of your data when you choose to give this to us on our website, by email, over the phone, in person at meetings or otherwise.
Cookies. We may collect Usage Data and Technical Data about your browsing actions and patterns. Pleases see our separate cookie policy about this.
Publicly available sources. We may collect professional information about you from publicly available databases or websites such as Companies House or your work website.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

in anticipation of or in accordance with the contract that we have with you – in order to provide our services; or
where it is necessary for our legitimate interests (or those of a third party) in the operation of our business and we have made an objective assessment that your interests and fundamental rights do not override those interests (for example to manage our relationship with you or to improve the service that we offer).
where we need to comply with a legal or regulatory obligation.

Please contact us if you need details about the specific legal ground we are relying on to process your personal data.

5. Cookies

Our website uses cookies 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 also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

We use different types of cookies for different reasons. You don’t have to accept our use of NON-ESSENTIAL COOKIES (i.e. Google Analytics) and you can choose to disable these if you wish by adjusting your browser settings. We use Google Analytics to allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

6. Our Services to you – where we act as a “data processor”

This policy is in respect of our obligations to you as data “controller” of the personal information that you provide to us.

As part of our offering to our customers, we provide a platform on which your organisation can host data that is controlled by your organisation. In doing so, Cube Local acts as a data “processor” and our obligations in respect of that role are set out in our [Terms and Conditions]. Your organisation will remain a data “controller” of that personal data and will be responsible for determining how that data is used.

7. Disclosures of your personal data

We will need to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.

Our IT support and hosting companies, providing us with IT services.
Google Analytics or similar – for analysis of website use
Our professional advisors.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

8. International transfers

Our sister company in Australia has access to certain personal data collected through Cube Local in order that we can streamline our services globally. Your data is treated in Australia under the standards as if it were subject to the UK’s laws on data protection.

In addition, some of our third party service providers have servers or operations based outside the UK. Where they do, we ask that they have appropriate protections in place so that we know all data will be looked after as though it were subject to the UK’s laws on data protection. Should you need further details on which third party processors we use that are based outside the UK, please let us know.

9. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

10. Data retention

How long will you use my personal data for?

We 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.

In some circumstances you can ask us to delete your data: (see below for further information).

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

11. Your legal rights

You have the right in certain circumstances to:

Request access to your personal data (a "data subject access request").
Request correction of the personal data that we hold about you.
Request erasure of your personal data.
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.
Request restriction of processing of your personal data.
Request the transfer of your personal data to you or to a third party.

For more information on these rights and when they apply is available here:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).

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.

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.