Cubits Privacy Policy

Last updated: 19th July 2016

Dooga Ltd. company number 4430228, whose registered office is 6 Agar Street, WC2N 4HN, London, United Kingdom, trading as Cubits (We) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents referred to herein) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices in processing your data, as well as your rights regarding your personal data and how we will treat it.

By visiting www.cubits.com (“Website”) and submitting information to us you are accepting and consenting to use of your personal data as described in this policy. If you do not agree with the terms of this Privacy Policy please do not use the Website or otherwise provide us with your personal information.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is Dooga Ltd.

Information we may collect from you

We may change our privacy policy from time to time. Any changes we may make to our Privacy Policy in the future will be posted on this page and any such changes will become effective upon posting of the revised Privacy Policy. Please check back frequently to see any updates or changes to our privacy policy.

If we make any material or substantial changes to this Privacy Policy we will use reasonable endeavours to inform you by email.

We may collect and process the following data about you:

• Information you give us. You may give us information about you by filling in forms on the Website) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register on the Website, and use our services and to purchase Bitcoin, or when you report a problem with the Website. The information you give us depends on the type of transaction, but may include your name, address, e-mail address and phone number, financial and credit card information, personal description/ID and photograph.
• Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
• Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

Uses made of the information

We use information held about you in the following ways:

• Information you give to us. We will use this information:
  • to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
  • to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
  • to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please let us know at [email protected] and we will update our records;
  • to notify you about changes to our service;
  • to ensure that content from our site is presented in the most effective manner for you and for your computer;
• Information we collect about you. We will use this information:
  • to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  • to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
  • to allow you to participate in interactive features of our service, when you choose to do so;
  • as part of our efforts to keep our site safe and secure;
  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
  • to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
• Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
• Information we verify. As part of our due diligence process you agree for us to send to third parties your personal data to be verified for identification purposes, this personal data shall include sensitive personal data such as a picture of your passport. You expressly agree for your data to be used in this way. The third parties we work with may be outside of the European Union, in which case, you expressly agree to your data being sent outside of the European Union for this purpose. If you have any queries about this process please do not hesitate to contact us at [email protected]

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them.
• Analytics and search engine providers that assist us in the improvement and optimisation of our site.
• Credit reference agencies or ID verification agencies for the purpose of verifying your identity where this is a condition of us entering into a contract with you.

We may disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
• If Dooga Ltd. or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Dooga Ltd., our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Where we store your personal data

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at [email protected]

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.

Cookies Policy

The Cubits website (the "Website") uses cookies to deliver a better and more personalised service to users.

This Cookies Policy explains what cookies are, how they are used on the Website and how to manage their use.

What is a Cookie?

Cookies are small text files containing small amounts of information which are sent to and stored on your computer, smartphone or other device when you access a website. Cookies are then sent back to the originating website on each subsequent visit or to another website that recognises that cookie. Cookies are useful because they allow a website to recognise a user's device.

You can find more information about cookies at www.allaboutcookies.org.

Use of Cookies on the Website

Cookies are used on the Website for a number of reasons. This includes, but is not limited to, the following:

• to allow users to log on to their Cubits account;
• to allow users to choose log-in preferences;
• to monitor and collect information about transactions placed on the Website; and
• for fraud prevention purposes and generally to safeguard privacy.

Cookies are generally used to improve and enhance the user experience. Some of the cookies we use are essential for the Website to operate.

Cubits’s use of cookies on the Website falls into the following categories:

Session Management - these cookies are essential to enable use of the Website, they manage session information and enable users to navigate through the Website.

Functionality - these cookies store information which enables us to remember user preferences e.g. preferred language, sort types, media settings. They are also used to improve users' experience by, for example, stopping users from being shown the same message twice.

Fraud Prevention - these cookies store information which helps us stop fraudulent use of the Website.

Tracking - these cookies enable us to store information about how users landed on the Website. We need to record this so that we can appropriately pay our affiliates.

Analysis – these cookies allow us to recognise and count the number of users and to see how users move around our Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily and to deliver adverts and information which are more relevant to each user and their interests and to monitor the effectiveness of such adverts and information.

Where links are provided on the Website to third party websites it is important to remember that those websites will have their own cookies and privacy policies which will govern any information you may submit. If you decide to use any linked third party websites please read their cookies and privacy policies before doing so.

Managing Cookies

If you want to delete any cookies already stored on your computer or stop the cookies that keep track of your browsing patterns on the Website, you can do so by deleting your existing cookies and/or altering your browser's privacy settings (the process you follow will differ from browser to browser). If you would like more information on how to disable cookies or change your privacy settings, please visit www.allaboutcookies.org. Your browser's 'help' function should also tell you how to do this.

Please note that deleting our cookies or disabling our future cookies means that you may not be able to access certain areas or features of the Website. For example, if your browser is set to disable 'session' cookies, you won't be able to log on to your Cubits account.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to [email protected]