Privacy Policy

PERSONAL DATA PRIVACY POLICY

Last update on July 14, 2021

 

The term “the website” means the website “https://www.cuberm.com/” which is owned and run by the Greek Private Company under the trade name “CUBE RM PRIVATE COMPANY”, herein referred as “we”, “our”, “us”, or “the company”.

The term “services” refers to all the services, information and consults provided by the company or the company allows to be provided through the website and in general anything offered by our company to you from time to time.

We will refer to you by using the terms “user”, “visitor”, “you”, “your”, “yours” in this Privacy Policy.

Within the framework of your visit and navigation on the website “https://www.cuberm.com/” and the use of its content, it is possible that you register individual information and Personal Data details of yours.

We are committed to protect and respect your privacy and personal data and to only use information legally collected from you. Please note that the use of our website is subject to this Privacy Policy as well as to the Terms of Use of our website. This Privacy Policy explains what data we collect, the purpose of collecting data, how we use it and / or share it and how these are stored. Please note that this Agreement applies only to data collected on this website and not to data collected or obtained in other ways or by other means. Please read this Privacy Policy carefully to understand our views and practices regarding your personal information and how we process them.

This Privacy Policy is in full compliance with the General Data Protection Regulation 2016/679/EU and Directive 2016/680/EU as well as the current e-Privacy Regulations.

We respect your privacy rights and personal data and acknowledge the importance of protecting the data collected from you. This Privacy Policy refers to what we collect, how we collect, store, share and use the personal data that you provide us with.

 

This Privacy Policy explains:

·         What Personal Data do we collect from you and for what purpose.

·         What about “cookies”? What are “cookies”?

·         How your Personal Data may be used.

·         Who we will share your Personal Data with.

·         Where we process and store your Personal Data.

·         How long we may hold your Personal Data.

·         Marketing opt-in and opt-out provisions

·         How you can access your Personal Data and keep it up to date.

·         Safeguarding your Personal Data.

·         Why we link to other websites/social media.

·         How we can make changes to this Policy.

·         Where and how to ask questions, complain or contact us about this Policy.

 

Age Disclaimer: In order to use our website and its content, you must provide explicit consent that you are over 18 years old. If you are under 18 years old you must not use the website. Those who have parental authority should protect juveniles from accessing and using websites that appeal to adults and are the only responsible for this.

 

·         WHAT PERSONAL DATA DO WE COLLECT FROM YOU AND FOR what PURPOSE

We may collect your Personal Data upon your registration to our website, with any other way you interact with us, as via social media, via posts or articles or by signing up for receiving newsletters. You must provide explicit consent independently, giving us this way the authority to process your personal data in the event of any of the above-mentioned actions by clicking on the box indicated on our website.

 

We declare that our website is in line with Data Minimization Principal and thus we collect the minimum possible amount of data for our services to be provided.

The data we collect and hold about you may include your full name or trade name of the company on behalf you are acting for, email, phone number, username, IP address, search criteria, responses to research panels and surveys, what  browser you use (a browser is the program you use to look at websites, such as Internet Explorer, Google Chrome, Firefox or Safari), how many times you access the site and for how long, your referring URL (the site you come from to reach our website), cell IDs (these are the unique identifiers of the telecommunications towers being used by your mobile phone when you use our locations-based services on your mobile phone or tablet) and other location information (for example, GPS measurements), content you share with us, details or answers to security questions.

Furthermore, we collect data, which is not intended to be associated or identified in connection with the individuals they concern, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or H/Y domain names of users on the internet, URI (Uniform Resource Identifier) of sources having been searched, duration of search, how the search request was submitted on the server, the size of the file obtained in response, the numerical code indicating the response status by the server (successful, error, etc.) and other parameters regarding the operating system and electronic environment. These data are only useful to obtain anonymous statistics on the use of the website and to check the correct functioning and is deleted immediately after processing.  This data may be used to ascertain responsibility in case of possible computer crimes against the site. 

In Particular:

We may additionally collect data in relation to the way you use the provided services, such as the time of access to a provided service and duration of such access, the site you visited before you come to a service or the site you will visit after leaving a service, choices and selections you make and preferences that you set when using a service as well as any data you input while conducting any assessment on the provided services.

We may collect data about the computer or other electronic device you use to connect to the services provided such as details about the type of device (which can include unique device identifying numbers), its operating system, browser and applications connected to the services provided through the device, your Internet service provider or mobile network, your IP address and telephone numbers to your devices (if applicable).

We do not collect data about your actual location, other than an approximate location (usually no more precise than city level) which can be determined from your IP (Internet Protocol) address. In certain instances, and upon your explicit consent, we may use cookies and similar technologies to store and access data we collect through the provided services. We may collect your IP (Internet Protocol) address to diagnose errors on our server and to administer our website. The IP address is a number given to your computer when you are on the Internet.

 

·         WHAT ABOUT “COOKIES”? WHAT ARE “COOKIES”?

We use technologies such as cookies and pixel tags to provide, improve, protect and promote our services. In this way we collect data in relation to your use of our services.  Cookies are very small files that are sent by us to your computer or other device which we can access when you visit our site in future. Cookies help us remember who you are and other information about your visits. They can assist in displaying data on a website in a way that matches your interests. The use of session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to transmitting session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site. For example, cookies assist us in cases such as to remember again your username at your next visit, to understand how you interact with our services, to improve our services on the basis of that information and to not allow acquisition of personal identification data by third parties.  You can set your browser to not accept cookies, but this may limit your ability to use the services. Exception to this rule is cookies which serve functional needs of the website only (functional cookies) and are necessary for the appearance and the effective function of the webpage on your computer.

 

·         HOW your personal data MAY BE USED

 

Whenever you provide us with your personal data, we will use it in accordance with the applicable privacy laws and for the purposes set out in this Policy, on the data entry forms you complete, on any relevant terms and conditions and on sites or emails which link to the data entry forms.

 

When you use our services: If you use any of our services, subscribe, peruse or change your account details we will record your personal details. We will initially use your details to provide the services or information you have required. We hold the information you provide and may use it for several purposes, mainly : (i) for financial / tax audits or reporting or billing of products, if necessary; (ii) authentication and identity checks; (iii) upon your explicit consent for participating in contests; (iv) for insurance cover, educational purposes, administrative and legal purposes; (v) upon your explicit consent for comparing data and deleting duplicates, for statistical and market analysis and promotional information; (vi) for developing, testing and maintaining systems; (vii) upon your explicit consent for customer surveys; (viii) upon your explicit consent for customer care and to help us in any future dealings with your, for example by identifying your requirements and preferences; (ix) where required by law or in connection with legal proceeding or extrajudicial disputes; and (x) any other uses set out in the terms and conditions for use of our services. For these purposes we may disclose your data to one or more of the other organizations listed in the section called “who we will share your personal data with”. For these purposes we may disclose your information to one or more of the other organizations listed in the section called “who we will share your personal information with”.

 

Customization of our services and advert targeting: We may use your personal data and the data we collect via cookies when you use our services to build up a picture of your interests. We may then use this information to try to make sure that when we send marketing communications to you and when you visit our website or use our services, you don’t miss offers and information that might interest you. This information may also be used, meeting always our company’s obligations deriving from the provisions of the General Data Protection Regulation (679/2016/EU) and the Greek applicable laws, by our third party contractors, i.e.  collaborating advertising agencies to advertise our own products and services or third party products and services to you when you visit third party websites and services. This is called advert targeting or interest-based advertising.

 

Comments and reviews submitted to our services: If you wish to submit a comment or feedback on a blog or article featured on our services, we may (but are not obliged to) publish your comment online or offline to promote our business and services. We will be able to collect your name or username which will be displayed next to your comment and your e-mail address, which will be published upon your explicit consent and which we may use to contact you in relation to your comment.

 

Mobile services: When you navigate on our website and request our mobile services, we may keep your mobile phone number, the make and model of your phone, the operating system used by your phone and details of your network operator, and we will link a unique identifier to your mobile phone number. We’ll store your device language, app language and country. We need this information in order to provide the features and mobile services and to administer our services via mobile phones.

 

Direct marketing: For information on how we may market to you, please read the section called “Marketing opt-in and opt-out provisions”.

 

Customer surveys: Every now and then, we may ask you for your opinion on our services and for contests you have declared your participation. When we do research or surveys, we may use cookies and may combine the data collected by those cookies with your answer.

 

We mainly use your personal data to make sound scientific conclusions, to develop new services, and upon your explicit consent, to send you newsletters and information about events, contents and / or other services which we believe you may be interested in, as well as for statistical, survey and research purposes. 

 

More precisely, we use the data we collect in the following ways:

 

(a)       to manage your Account and provide you with the features of the provided services in a functional and effective way, to be able to confirm and keep your personal data accurate. For this purpose, we will use data we collect directly from you.

 

(b)       to ensure that the content of the provided services is presented in the most effective manner for you and for your device and to display content and features that are tailored to your needs, your interests and to the way you use the provided services.  To this effect, we will use data we collect directly from you, which relates to information for the way you use the provided services and data about how you connect to the provided services.

 

(c)        to provide you with information about services you require from us or which we think may interest you (in accordance with your marketing preferences).  To this effect, we will use data we collect directly from you, upon your explicit consent by ticking the relevant box (opt-in policy) in our website.

 

(d)       to determine and predict information that may be of interest or relevant to you. To this effect, we will use data we collect directly from you, information about how you use the provided services and information about how you connect to the provided services.

 

(e)       to make sound scientific conclusions, to conduct surveys, for statistical and research purposes.  To this effect, we will use data we collect directly from you upon your explicit consent by ticking the relevant box (opt-in policy) in our website.

 

(f)        to notify you about changes to the provided services and to respond to any complaints, comments and issues you have in relation to your use of the provided services.   To this effect, we will use data we collect directly from you.

 

(g)       to prevent, detect and investigate illegal activities, breaches of any agreements between you and us and threats to the security of the provided services.  To this effect we will use data we collect directly from you, about how you use the provided services and information about how you connect to the provided services.

 

(h)       to produce aggregate statistical information and analysis about you and of your submissions to the provided services.  To this effect, we will use data we collect directly from you upon your explicit consent by clicking on the relevant box (opt-in provision).

 

 

·         WHO WE WILL SHARE YOUR PERSONAL data WITH

We may share data, as discussed below, but we won’t sell it to advertisers or third parties. In order for us to be able to share your data you must provide your explicit consent by ticking the relevant box indicated in our website.

We are able to share the personal data you provide us with, at our sole discretion, meeting always our company’s obligations deriving from the provisions of the General Regulation Data Protection (679/2016/EU) and the Greek applicable laws, in the following cases:

To third parties working for our website and our online means. We collaborate with specific trustworthy third parties (for example, customer support and IT providers, accounting and legal services) to help us provide, improve, protect, and promote our Services. These third parties will access your data only to perform tasks on our behalf in compliance with this Privacy Policy and will remain responsible for their handling of your data as per our instructions.

Law & Order: We may disclose your data to third parties in absolutely necessary cases, for example : (a) if required by Law, by court order or decision or required by any other competent governmental, judicial, police, administrative or regulatory authority, upon legitimate request and according to the pertinent laws; (b) to protect any person from death or serious bodily injury; (c) to prevent fraud or abuse of our users; or (d) to legally protect our website property rights.

 

·         WHERE WE PROCESS AND STORE YOUR PERSONAL data

The data collected from you is stored on a third party Server on the servers of the hosting provider (Microsoft Azure servers) where the company’s website is hosted – which may be outside of the European Union and the European Economic Area – as well as at the company’s facilities in Greece. The Company may designate third party service providers for the processing of data (Data Processors) as well as for the administration and operation of certain functions of the website.  The Company guarantees that it takes the appropriate organizational and technical measures to protect your data.

 

·         HOW LONG WE MAY HOLD YOUR PERSONAL DATA

Your Personal Data will be retained until it is deleted, and for a maximum period of five (5) years. The retention period of your personal data is always in compliance with the General Data Protection Regulation and the domestic legislation. If you delete your account, your Personal Data will also be deleted.  Also, upon a written request from you sent to email address [email protected], if so required, we will delete or destroy any personal data provided to us.  But please note: (1) there may be some latency in deleting this data from our servers and back-up storage; and (2) we may retain some necessary data to comply with our legal obligations, resolve disputes, or enforce our agreements. Keep in mind that we are in line with the Data Minimization Principal and thus we require, process and store the minimum personal data possible to uninterruptedly provide our services.

 

·         MARKETING OPT-IN AND OPT-OUT PROVISIONS

We offer you the possibility to receive news and newsletters relevant to your preferences, in which case we will communicate with you by online message, SMS and / or email. These include alerts for new products, articles, improvements, special offers, upgrade special offers, contests, events of interest, and one-off marketing promotions. Our website is in full compliance with the current legislation and the personal data regulations and is in line with a strict opt-in policy with reference to these updates, when receiving explicit consents by ticking the box indicated in our website.

You have the right to change your mind at any time and to require that we do not use your personal data for marketing purposes anymore. In any event, we will offer you the opportunity to unsubscribe from any service or update you have subscribed.  Whenever you receive direct marketing from us, we will tell you how to unsubscribe. Alternatively, you can change your marketing preferences by logging into “Customer Account”, and – opting out by sending us a direct email to [email protected].

 

·         HOW YOU CAN ACCESS YOUR PERSONAL data AND KEEP IT UP TO DATE

You have the right to review what Personal Data we hold about you. If you like a copy of your personal data, please contact us at [email protected]

You have the right to review and update your personal details. If for any reason you are concerned that the personal data we hold is not correct, please visit our online services and, after logging into the site on the home page (using any available “Sign In” option), your personal data will be made available for review and change in the “Settings” section. Only you or, upon your request, our Customer Care team, may access your personal data on our online services via your username and password. If you prefer, you may contact us by email at [email protected] and we will amend your personal details, as per your instructions.

 

·         SAFEGUARDING YOUR PERSONAL DATA

We will take all necessary steps to maintain appropriate precautions to ensure the security, integrity and privacy of the data you have provided to us. We have set up technology and security policies which are designed to protect the personal data we hold about you. We are also in line with the security procedures which are required according to the applicable privacy laws. These, cover storing, processing, using and releasing any data you have provided us with, as well as measures designed to prevent unauthorized access or use.  We want you to rest assured that our team is dedicated to keeping your personal data secured and testing for possible vulnerabilities. Also, we are continuously working on technical features to keep your data safe, not only on two-factor authentication mechanism, but also on encryption of files at rest, and on alerts when new devices and applications are linked to your account.

Keep in mind that where we have given you (or where you have chosen) a password enabling you to access certain areas of the provided services, you are the only responsible for keeping this password confidential. If the password has been stolen or might otherwise has been subject to misuse, it is your responsibility to notify us immediately for further action.

  

·      WHY WE LINK TO OTHER WEBSITES/ SOCIAL MEDIA

Our services may include hyperlinks to websites that are owned and operated by other organizations. These websites have their own privacy and cookies policies, and we urge you to read them. They control how your personal data is used when provided to these other organizations or collected via cookies.  We do not control or approve any other websites and we are not responsible for any data, material, products or services that are on or accessible through those websites or for the privacy policies thereafter.

If you follow us or interact with us on any of our pages on third party social media platforms, such as Instagram, Facebook, Twitter, Pinterest and Google+, any data you provide will be subject to the third party’s privacy policy, as well as to its privacy policy.

 

·    HOW WE CAN MAKE CHANGES TO THIS POLICY

If a reorganization takes place or we are participating in a reorganization, merger, acquisition or sale of our assets, your data may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices as appropriate. You may be required to update your consents in the context of our capabilities and the way we process your personal data.

We may revise this Privacy Policy from time to time and will post the most current version on our website. Any amendment in this Privacy Policy will be valid once the amended Privacy Policy is uploaded on the website. We recommend you to regularly visit our website’s Privacy Policy in order to be informed about all the amendments that have been made.

If a revision meaningfully reduces or alters your rights, we will notify you, and you might be required to update your consents in the context of our capabilities and the way we process your personal data.

  

·      WHERE AND HOW TO ASK QUESTIONS, complain OR CONTACT US ABOUT THIS POLICY 

For any questions regarding our Services and Privacy Policy, contact us by email on [email protected] or / and on telephone +30 210 28 32 032.

In case you wish to lodge a complaint regarding the processing of your personal data,  we hereby notify you that the Competent Authority is the Personal Data Protection Authority, which is located at 1 – 3 Kifisias Avenue, P.C. 115 23, Athens, Tel. contact : +30 210 64 75 628 and email [email protected] and / or [email protected].