CUBEAC - Privacy Policy


Last Updated: January 12th, 2017


At Avansys Consulting Ltd. (“CUBEAC”, “we”, “us”, or “our” which include our group and affiliated companies), our most important asset is our relationship with our user community. We are committed to maintaining the confidentiality, integrity and security of information about our users and their organizations. This Privacy Policy describes how we treat personal and company information when you visit the CUBEAC Website www.cubeac.com (“the Site”) or use the CUBEAC Service.

In this privacy policy, “you” and “your” refers to individual users of the CUBEAC Service, and “CUBEAC Service”, “User”, “Corporate User”, “Application” and other capitalised terms not defined in this privacy policy are defined in the CUBEAC General Terms and Conditions currently located at www.cubeac.com/terms. If you have questions or complaints regarding our privacy policy or practices, please contact us at help@cubeac.com.

Important – Transfer of Data to the US of European personal information Information that our European users submit through the CUBEAC Service or the Site may be transferred by us to our other offices and/or to the third parties (such as our Partner Companies), who may be situated in the United States of America or elsewhere outside the European Economic Area (EEA) and may be processed by staff operating outside the EEA. The US and other non-EEA countries do not have similar data protection laws to the European Union, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe. Where we transfer your information we will take all reasonable steps to ensure that your privacy rights continue to be protected consistent with our obligations under local law. By submitting information via the Site, you agree to this storing, processing and/or transfer.

This Privacy Policy is incorporated into, and considered a part of, the CUBEAC General Terms and Conditions, currently located at www.cubeac.com/terms. Any terms not defined herein have the meanings ascribed to them in the General Terms and Conditions.

1. User CONSENT By submitting or making available Personal Data (as defined below) through our website, the CUBEAC Software or the CUBEAC Service, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Data in accordance with this Privacy Policy.

2. TYPES OF PERSONAL DATA WE COLLECT CUBEAC collects Personal Data and Anonymous Data from you when you visit our Site, when you send us information or communications in connection with your use of the CUBEAC Service, and/or when you download and use the CUBEAC Software. “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, geographic location of your computer or mobile device, telephone number, credit card number, email address and bank account information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data about you that is not associated with or linked to your Personal Data; Anonymous Data does not permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Personal Data You Provide To Us We collect Personal Data from you, such as first and last name, email and mailing addresses, telephone number, professional title, company name, and password, when you register for the CUBEAC Service. In addition, we (or our third-party credit card or payment processor on our behalf) might collect Personal Data including your credit card number or account information when you upgrade to a paid account. We also retain information on your behalf, such as the Personal Data described above and any correspondence. If you provide us feedback or contact us via email, we will collect your name and email address, IP address, as well as any other content included in the email, in order to send you a reply, and any information that you submit to us, such as a resume. If we conduct a survey in which you participate, we may collect additional profile information. We may also collect Personal Data at other instances in the Site or Application user experience where we state that Personal Data is being collected.

If you choose to use our referral service to tell a colleague about our site, we will ask you for your colleague’s name and email address. We will automatically send your colleague a one-time email inviting him or her to visit the site. If your colleague is a resident of the European Union, please make sure they are happy to be contacted by us.

Your colleague may contact us at help@cubeac.com to request that we remove this information from our database.

Personal Data Collected by Third Parties We may receive Personal Data about you from companies that distribute the CUBEAC Service by way of a co-branded or private-labeled website, companies that offer their products and/or services via the CUBEAC Service, or companies that provide services (such as payment processing services) in connection with the CUBEAC Service (collectively, “Partner Companies”). Our Partner Companies may supply us with Personal Data, such as your name and email and mailing address information or your login credentials for such Partner Company’s website or service, in order to help us establish the account or fulfill orders. We may add this information to the information we have already collected from you via our website in order to perform and improve the CUBEAC Service.

This Privacy Policy applies only to the use and disclosure of Personal Data that we collect while you use the CUBEAC Service or the Site. Our provision of a link to any other website or location is for your convenience and does not signify our endorsement of such other website or location or its contents. When you click on such a link, you will leave the CUBEAC Service or our Site and go to another site. During this process, a third party may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on a link to a third party. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

Personal Data Collected via Technology The CUBEAC Service (which may be hosted by a third-party service provider) collects Personal Data from you, such as browser type, your approximate geographic location of your mobile device or computer (from your Internet Protocol (IP) address), operating system and version, Internet Protocol (IP) address, domain name, information about your application, operating environment and hardware profiles and/or a date/time stamp for your visit. We may also use Identifiers (as defined below) and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit and/or access to the CUBEAC Service and your activity on the Site and the Application. Like most Internet services, we automatically gather this Personal Data and store it in log files each time you visit the Site, use the Application or access your account on our network.

When you interact with the Site or the Application, we try to make that experience simple and useful. We use industry standard identifiers, such as cookies and mobile device identifiers which perform a similar role, like the IDFA used by Apple devices and the UDID used by Android devices. Cookies are small pieces of information which are issued to your computer or mobile device (as the case may be) when you visit a website or access or use a mobile application and which store and sometimes track information about your use of the Site or Application (as the case may be). A number of cookies we use last only for the duration of your web or Application session and expire when you close your browser or exit the Application. Other cookies are used to remember you when you return to the Site or Application and will last for longer. We refer to cookies and the mobile device equivalents as “Identifiers”.

We use Identifiers to:

  • remember that you have visited us before; this means we can identify the number of unique visitors we receive;

  • customise elements of the promotional layout and/or content of the pages of the Site or Application;

  • collect anonymous statistical information about how you use the Site or App (including how long you spend on the Site or Application) and where you have come to the Site or Application from, so that we can improve the Site and learn which parts of the Site and which functions of the Application are most popular with users; and

  • Our affiliates use Identifiers to monitor performance and usage on the Site and the Application for internal analytics. The use of Identifiers by our affiliates is not covered by our privacy policy. We do not have access or control over these cookies.

  • Our Site can include Social Media Features, such as the Facebook Like button and Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it. Some of the Identifiers used by the Site are set or accessed (as appropriate) by us, and some a by third parties who are delivering services on our behalf.

Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser or mobile device. Please note, however, that by blocking or deleting cookies used on the Site or Application, you may not be able to take full advantage of the Site or Application (as the case may be).

In addition to cookies, web beacons may be set by us or third parties in respect of your use of the Site or Application. Web beacons are small image files within the content of the Site or Application for analytics purposes so we or third parties can understand parts of the Site or Application are visited and which functions of the Site or Application are used and whether particular content is of interest.

3. USE OF YOUR PERSONAL DATA CUBEAC uses your Personal Data in the following ways:

  • to facilitate the creation of and secure your account on our network; identify you as a user in our system;

  • to provide improved administration of the CUBEAC Service;

  • to improve the quality of experience when you interact with the CUBEAC Service;

  • to send you a welcome email to verify ownership of the email address provided when your account was created;

  • to send you administrative email notifications, such as security or support and maintenance advisories

  • to respond to your inquiries related to employment opportunities or other requests;

  • to send with your consent (or where a colleague has referred you to us) promotional communications;

  • to provide you with hardcopy or electronic newsletters, or surveys;

  • to send with your consent (or where a colleague has referred you to us) upgrades and special offers related to the CUBEAC Service and for other marketing purposes of CUBEAC or our Partner Companies; and

  • to make telephone calls to you, from time to time, as a part of secondary fraud protection or to solicit your feedback.

We may create Anonymous Data records from Personal Data by excluding information (such as your name and email) that render the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content and functionality of the CUBEAC Service. CUBEAC reserves the right to use for other purposes and to disclose Anonymous Data to third parties in its discretion.

If you provide feedback on the CUBEAC Service, we may use such feedback for any purpose, provided we will not associate such feedback with your Personal Data. CUBEAC will collect and store any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.

Any information, including Personal Data, which you elect to make publicly available on the CUBEAC Service will be available to other Users. If you remove information that you have made public on the CUBEAC Service, copies may remain viewable in cached and archived pages of the CUBEAC Service, or if other Users have copied or saved that information.

We collect information for our clients, if you are an employee of one of our Corporate Users and would no longer like to be contacted in conjunction with one of our Corporate Users that use our service, please contact the Corporate Users that you interact with directly.

4. DISCLOSURE OF YOUR PERSONAL DATA We may share your Personal Data with Partner Companies to provide technical support or to provide specific services, such as hosting of your applications, maintenance services, database management or payment processing for purchases, reimbursements or other payments (including but not limited to PayPal and the Bancorp). Partner Companies will have access to your Personal Data only to perform these services on our behalf and are obligated not to disclose or use it for any other purpose. They may be located, or their data processing activities may take place, in the United States of America or elsewhere outside the European Economic Area (EEA). The US and other non-EEA countries do not have similar data protection laws to the European Union, and you should be aware in particular that the law and practice in the United States in respect of law enforcement authority access to data is significantly different from Europe.

Any subsidiaries, joint ventures, or other companies under common control with us (collectively, “Related Entities”), may share some or all of your Personal Data, in which case we will require our Related Entities to honor this Privacy Policy and your Personal Data will only be used for the purposes set out in this Privacy Policy.

CUBEAC may sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Personal Data may be among the items sold or otherwise transferred in these types of transactions, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.

Regardless of any choices you make regarding your Personal Data (if applicable), CUBEAC may disclose Personal Data if it believes in good faith that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants or lawful requests from government authorities served on CUBEAC; or (b) protect or defend the rights, reputation or property of CUBEAC or users of the CUBEAC Service.

Except as otherwise stated in this policy, we do not sell, trade, share, or rent the Personal Data collected from our services to third parties. You expressly consent to the sharing of your Personal Data as described in this policy.

Service Provider, Sub-Processors/Onward Transfer CUBEAC may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreements with our Clients

5. CHOICE/OPT-OUT CUBEAC offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via email. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also contact us at help@cubeac.com with your request.

6. PERSONAL DATA CHANGES You may change aspects of any of your Personal Data in your account by editing your profile within the registration portion of the Site or by sending an email to us at help@cubeac.com. You may request deletion of your account information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). We will respond to your request to access within 30 days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Access to Data Controlled by our Corporate Users Where a User accesses the Application or the CUBEAC Service because their employer is a Corporate User, CUBEAC has no direct relationship with that User. In that situation, a User who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the CUBEAC’s Corporate User (the data controller). If the Corporate User requests CUBEAC to remove the data, we will respond to their request within 30 business days.

Data Retention CUBEAC will retain data we process on behalf of our Corporate Users for as long as needed to provide services to our Corporate User. CUBEAC will retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Blog / Forum Our Web site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at help@cubeac.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

7. SECURITY OF YOUR APPLICATION AND PERSONAL DATA CUBEAC is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We also require you to enter a password to access your account information. Please do not disclose your account password to unauthorized people. Despite these measures, you should know that CUBEAC cannot fully eliminate security risks associated with Personal Data.

8. CONTACT INFORMATION CUBEAC welcomes your comments or questions regarding this Privacy Policy. Feel free to email comments or questions to us at info@cubeac.com or Avansys Consulting Ltd., Nadorliget u.8/B, 1117 Budapest, Hungary.

9. CHANGES TO THIS PRIVACY POLICY If CUBEAC makes changes to this Privacy Policy, these changes will be posted on the Site and Application in a timely manner. CUBEAC reserves the right to modify this Privacy Policy at any time, so please review it frequently. You can determine when this Privacy Policy was last revised by referring to the “Last Updated” legend at the top of this page. Any changes to this Privacy Policy will become effective upon our posting of the revised Privacy Policy on the Site and Application. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. Use of the CUBEAC Service following such changes constitutes your acceptance of the revised Privacy Policy then in effect.