PRIVACY POLICY
Summary
1) This privacy policy has been drafted for the purpose of complying with the General Data Protection Regulation that goes in effect starting from 2018/05/25
2) Cube Intelligence processes your cookies and ‘Know Your Customers’ information (name, address, telephone number, email address, your pictures holding a form of national identification certificate)
3) For current members, we process your information based on the consent you have previously given us during registration. For new members, we will ask for consent.
4) We process your cookies to enhance our website services.
5) We process the ‘Know Your Customers’ information for confirming your identity to successfuly fulfill our contracted transaction, and to comply with the Anti-Money Laundering laws.
6) We do not provide or expose our collected information to third parties.
7) Section 7 of our privacy policy shows what rights you have as a data subject under the GDPR..
8) This summary show the key points of how, why, what information we process. The complete version of our privacy policy includes the legal basis of our data use, the actions we took to comply with the GDPR, and how we retain your data.
9) Contact us for further inquiries. See section 11, our details.
1. Introduction
We are committed to safeguard the privacy of Cube Intelligence website visitors and service users. This policy applies where we are acting as a data controller, with respect to the personal data of the Cube Intelligent website visitors and service users. This policy has been recently updated in compliance with the General Data Protection Regulation(GDPR) that goes in effect May 25th, 2018.
In our privacy policy, we disclose what kind of information we collect for what kind of purposes, how we store and administer your data, and other actions we took to satisfy the requirements of the GDPR.
1) Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. Please note that all information excluding partial cookies information is essential to providing our services. You can access the privacy controls via contacting us through the information presented in section 11.
2) You can request for a Summary of your data through contacting us through section 11.
3) In this policy, “we”, “us” and “our” refer to Cube Intelligence Ltd. For more information about us, see Section 11.
2. How we use and collect your personal data
For our services we collect 1) cookies 2) email addresses 3) KYC identification information.
2.1 In Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
2.2 We may process data about your use of our website and services or “usage data”.
The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is consent OR our legitimate interests, namely monitoring and improving our website and services OR to provide information that you request OR to carry out our contracts with you OR allow you to use our interactive services if you want to OR inform you on our charges. If you already are our customer, we will only contact you electronically.
If you are a new customer, you will only be contacted if you agree to it. Please note: We don’t identify individuals to our advertisers or share your data with any external party for marketing.
2.3 We may process your “account data”. The account data may include your email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent OR our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4 KYC(Know Your Customers) & AML(Anti-Money Laundering) Regulations
We may process your information included in your personal profile on our profile data. The profile data may include your name, address, telephone number, email address, your pictures holding a form of identification certificate (passport, drivers licenses, national identification card), gender, date of birth, and photocopies of legitimate identification certificates. The profile data may be processed for complying with applicable law, regulations or guidance for money services businesses operating in the United Kingdom or any other Jurisdictions. The legal basis for this processing is consent OR our legitimate interests, namely the compliance with record keeping requirements(KYC) OR compliance with Anti- Money laundering regulations OR for carrying out contracts between you and us and/or taking steps, at you request, to enter into such a contract.
2.5 We may process information contained in any enquiry you submit to us regarding services as “enquiry data”. The enquiry data may be processed for the purposes of enhancing our services to you. The legal basis for this processing is consent OR our legitimate interests such as the proper administration and enhancement of our services.
2.6 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters as “notification data”. The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.7 We may process information contained in or relating to any communication that you send to us as “correspondence data”. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms(email, phone inquiries, etc.). The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely he proper administration of our website and business and communications with users.
2.8 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9 We may process any of your personal data identified in this policy where necessary for the purposes of managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1 Currently, the personal information we collected through our website has not been provided to any third parties. The collected personal data is only used for the purposes stated in section 2.
3.2 However, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 Also, we may disclose your personal data if we want to sell our business or our company, to potential buyers. The legal basis for this disclosure is our legitimate interests.
4. International transfers of your personal data
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA). Please note that any case of our overseas data transfer will not be a transfer to a 3rd party.
4.2 In the case when our offices and facilities expand to other countries that are not currently noted in our terms, we will update the terms and conditions but not notify you. It is advised to check our privacy policy from time to time.
4.3 We have offices and facilities in the United Kingdom and Republic of Korea. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which can be obtained from
[http://www.law.go.kr/%EB%B2%95%EB%A0%B9/%EA%B0%9C%EC%9D%B8%EC%A0%95%EB%B3%B4%EB%B3%B4%ED%98%B8%EB%B2%95] , The Private Information The Personal Information Protection Act of Republic of Korea
AND you may request for a english translated summary by contacting us through informations on section 11.
4.4 The hosting facilities for our website are situated in the United Kingdom and Republic of Korea. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the GDPR and the Private Information Protection Act of Republic of Korea, a copy of which you can obtain from
AND you may request for a english translated summary by contacting us through informations on section 11.
4.5 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.
5. Retaining and deleting personal data
5.1 This Section 5 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
5.2 All data collected are encrypted and stored on our private server.
5.3 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
5.4 We will retain your personal data as follows:
(a) The personal data collected via “know your customers” will be retained for the purpose of complying with Anti-money laundering laws, and for finishing the contract between you and us. It is difficult to specify the exact period of data retainment concerning kyc. See sections 5.5 for more information.
5.5 Due to the nature of our business, it is essential to certify the identification of our contributors. The legal basis for retaining the kyc data is to protect your vital interests or the vital interests of another natural person AND to comply with anti-money laundering regulation requirements. Thus, it is not possible for us to specify in advance the periods for which your personal data will be retained.
6. Amendments
6.1 We may update this policy from time to time by publishing a new version on our website.
6.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.3 We may OR will notify you of changes OR significant changes to this policy via electronic means such as email.
7. Your rights
7.1 In this Section 7, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
7.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
7.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data] by contacting us through information set on section 11.
7.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
7.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
7.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
7.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13 You may exercise any of your rights in relation to your personal data by written notice to us OR by contacting us through information set on section 11.
8. About cookies
8.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
8.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
8.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9. Cookies that we use
9.1 We use cookies for the following purposes:
(a) authentication – we use cookies to identify you when you visit our website and as you navigate our website.
(b) status – we use cookies to help us to determine if you are logged into our website.
(c) personalisation – we use cookies to store information about your preferences and to personalise the website for you.
(d) security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally.
(f) analysis – we use cookies to help us to analyse the use and performance of our website and services.
(g) cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally.
10. Managing cookies
10.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) http://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) http://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) http://support.apple.com/kb/PH21411 (Safari); and
(f) http://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
10.2 Blocking all cookies will have a negative impact upon the usability of many websites.
10.3 If you block cookies, you will not be able to use all the features on our website.
11. Our details
11.1 This website is owned and operated by Cube Intelligence Ltd.
11.2 We are registered in London, UK, and our registered office is at 18 Finsbury Square, London, EC2A 1AH.
11.3 Our principal place of business is at 18 Finsbury Square, London, EC2A 1AH AND Office #3402, YoungdongDaero 511, Gangnam-Ku, Seoul, South Korea
11.4 You can contact us:
(a) by post, to the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time;
(d) by email, using the email address published on our website from time to time.
12. Data protection officer
We are not obligated to appoint a data protection officer under GDPR standards. Yet, we conduct basic training to our employees on the matter of privacy protection, record the processing of private information.