Privacy Policy
Published: 11th May 2020 Effective Date: 11th May 2020 Copyright 2020, Cubbit S.r.l.
We care about the security of your data and the protection of your privacy, so please read this policy carefully together with our Terms of Service. If you do not agree with the following terms, please do not access or use our Services or Website.
Cubbit Srl, (collectively “Cubbit”, “we” or “us“, “our“) with its registered office registered office in Via della Zecca 1, 40121 Bologna, VAT no. 03562001200, is the controller of the “Personal Data”, i.e. the information that identifies either directly or indirectly any potential candidates.
This Privacy Policy explains how Cubbit processes your data including personal information that may identify you as an individual and how you can control the collection, rectification, restriction and/or deletion of such information when you use our Software or browse our Website: www.cubbit.io, including on a mobile device, and/or our Web App and/or any other service to which this policy is linked, in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
Our website may contain links to third-party websites or services. This policy does not extend to those external sites or companies, so please consider their privacy policy directly.
If you have a Cubbit account as an individual person, for those to whom the GDPR applies, Cubbit is the “data controller” for processing of personal information as described below. In other cases, if you are a legal person (i.e. company or organisation), you will be considered as “data controller” and Cubbit will be a "data processor," acting on instructions given from the data controller.
With regard to the processing of files uploaded to our distributed cloud network by users, however, Cubbit is always to be considered the “data processor” and the user (person or company or organization) owning the Cubbit account is the data controller, until account termination.
However, since we believe in the potential of our community, being part of our network gives both rights and duties (please, again, refer to our Terms of Use). In this sense, users who are also Cubbit Cell holders are to be considered themselves as sub-processors on behalf of Cubbit under Art. 28 (4) GDPR.
You can find a legal definition of “data controller” and “data processor” according to the EU legislation at the following link here.
Thanks to an AES-256 key encryption system, the data you have chosen to store on our network is safe and secure.
Once encrypted, every single file is divided into 24 chunks, which are processed into 36 redundancy shards. Of the 36 shards, only 24 are needed to recover the original encrypted file. These chunks are then distributed globally and stored on the network using a peer-to-peer connection between the hosting cells and the user.
Only you, or eventually someone with whom you decided to share your account user-name and password, have the keys to decrypt and to access the encrypted content of your file.
We do not collect users passwords so we can’t have access to the files you stored in your account and therefore we are not even able to recover your password, but we allow users to reset the old password by correctly typing a secret code or sentence set at the creation of the account allowing them to create a new password.
Only you have access to and control over the content of your files within your storage space. Cubbit lets you share individual files and/or folders with anyone on the web in a simple, fast and safe way. By selecting the file sharing button, users have the option between creating "public" links which are directly accessible, i.e. through the generation of an integrated encryption key, or "private" links through the generation of a link and a separate decryption key.
However, even if we cannot access the content of your files and folders uploaded to the cloud, we may still need to process some of your personal information to provide you with our service.
We collect information that you provide to us directly or indirectly, from third parties and by automated means, when you interact with us:
01. Data you provide to us
02. Information that we collect from third parties
03. Information that we collect from third parties
When you use our service we may automatically collect certain information about and from your Cubbit Cell. This may include information about the software version, operating system, Internet protocol address, and the date and time of each request made to Cubbit. When you connect to the network, we may also receive information about the external drives connected, number and size of files transferred/stored.This information allows us to better meet user needs, diagnose service issues, provide more effective customer support, inform you about operating systems that we no longer support and ensure the continued functionality of our products.
If you are an individual (both a website visitor or a Cubbit user) located in the European Economic Area (“EEA”), we collect and process your personal information as described above only on the following legal basis: 1) Consent - we will normally collect your personal information only where we have your consent to do so; 2) Performance of contractual obligations - when it is necessary in order to provide our services; 3) Legal obligations - when we need to fulfill a legal obligation arising from European law, regulation or legislation; 4) Legitimate interest - when there’s a legitimate business reason behind; 5) Public interest - when it is necessary to pursue legitimate interests of the controller or of a third party, as long as interests or fundamental rights and freedoms of the data subject requiring the protection of personal data, in particular where the data subject is a minor, prevail.
For example, but not limited to:
If you have any questions or need further information regarding the legal basis on which we collect and use your personal information, please contact us using the contact details provided on our Help Page.
From time to time, Cubbit will communicate with you via email. There are two types of email you may receive:
Your personal data will be processed by our team and will never be sold to third parties. However, we may also need to share certain information, including personal data, with third parties, who, in accordance with this policy, will be required to follow, in any case, the specific instructions we provide to them to ensure the security and confidentiality of your data.
Your personal data is stored and processed by us primarily within the EEA territory.
However, we shall use the services offered by third parties, e.g. service companies, in particular in the development of marketing strategies, with technical companies (e.g. manufacturer and supplier of electronic components) or logistics companies (e.g. couriers) that may be based outside the EEA.
For this purpose it may therefore be necessary to transfer certain personal data to these Third Parties, who in such cases act as data controllers on our behalf. Such transfer and processing by third party companies, if based outside the EEA, takes place on the basis of an Adequacy Decision by the European Commission or by signing Standard Contractual Clauses adopted by the Commission.
Your encrypted personal and non-personal data will be split in several chunks and distributed over the peer-to-peer network and stored globally.
The data subject has the right to obtain the following from the data controller:
Any data subject has the right to withdraw his or her consent to the processing of his or her personal data (where such consent has been previously given), at any time, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal.In accordance with applicable law, if you wish to exercise such rights, please write to privacy@cubbit.io. We may ask you to verify your identity.
We also remind you that pursuant to Art. 77 GDPR you have the right to lodge a complaint to the National Authority for the Protection of Personal Data (please find a list of the Data Protection Authorities here) or bring an action to the court if you consider that your rights have been infringed as a result of the processing of your personal data pursuant to Art. 79 GDPR.However, in order to find a quick and friendly resolution of any issues related to the processing of personal data, please get in touch with us first and we will do our best to solve your issue.
In order to provide our users the highest possible standard of protection in the processing of personal data, we may change this Privacy Policy to cover new technologies, software features, industry practices, regulatory requirements or other purposes.We will inform you if such changes are made and, where required by applicable law, you will be asked for your consent.The notice may be sent by email to the address you provided to us during registration, posting the notice of such changes on our site and on our application, in accordance with applicable law.
If you have any further questions about this Privacy Policy, the practices of this site and service, please contact the Data Protection Officer at Via della Zecca 1, Bologna - 40121 (Italy). Or email privacy@cubbit.io.
Here you can browse the archive of previous versions of this Privacy Policy
