Privacy Policy
We, Cubyts Research Labs Inc. (“Cubyts”, “We”, “Company”) are the owners of the website www.cubyts.com (“Website ”), id.cubtys.com (the “Identity provider”) and a tech-debt resolution platform, app.cubyts.com (“the App”). The Website, the Identity provider and the App are collectively referred to as the platform (the “Platform”). The users can through the Platform integrate the software stack and discover, predict impact and resolve tech debt in real time(“Services”).
We respect data privacy rights and are committed to protecting personal information collected on this Platform. This privacy policy (“Privacy Policy”) sets forth how we collect, use and protect the personal information collected on this Platform.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY CONTINUING TO USE THE PLATFORM, PROVIDING US PERSONAL INFORMATION, YOU CONSENT TO OUR USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MAY WITHDRAW YOUR CONSENT OR ALTERNATIVELY CHOOSE NOT TO PROVIDE YOUR PERSONAL INFORMATION ON THE PLATFORM. SUCH AN INTIMATION TO WITHDRAW YOUR CONSENT CAN BE PROVIDED BY EMAIL TO COMMUNICATION DETAILS MENTIONED BELOW.
IF YOU ARE ACCESSING THE PLATFORM ON BEHALF OF A THIRD PARTY, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND SUCH THIRD-PARTY TO THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY AND, IN SUCH AN EVENT YOUR USE OF THE PLATFORM SHALL REFER TO USE BY SUCH THIRD PARTY. IF YOU DO NOT HAVE SUCH AN AUTHORITY (TO PROVIDE ANY PERSONAL INFORMATION OF A THIRD PARTY) OR DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, THEN YOU SHOULD REFRAIN FROM USING THE PLATFORM.
This Privacy Policy is an electronic record in the form of an electronic contract being compliant and construed in accordance with data protection laws of the jurisdictions such as The Indian Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 under The Information Technology Act 2000 (“Privacy Rules”) that require publishing of privacy policy for the collection, use, storage and transfer of sensitive personal data, the UK Data Protection Law, the applicable personal data protection laws and regulations of The United States of America (“US”), and The European Union (“EU”) general data protection laws (“the GDPR”).
Definitions
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“User(s)”, “you”, “your” shall mean and include business organizations, commercial establishments, and their permitted users that avail the Services through the App.
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“UK Data Protection Law” means the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing.
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“Visitor” shall mean individuals who visit the Website or may opt to share Personal Information to reach out to us.
Personal Information Collected
This Privacy Policy applies to Personal Information collected by the Company, through the Platform about the Users, for providing the Services. For the provision of the Services, the User is required to complete the registration/subscription formalities, after completion of such formalities, Company shall create an account for the User (“User Account”). For availing the Services and for connecting with us through our Platform, the User shall be required to share/upload certain Personal Information. For purposes of this Privacy Policy, “Personal Information” means information that can be used to personally identify the User, including but not limited to User’s name, photograph, company name, role, e-mail address.
We may also automatically collect certain information through cookies to improve our Platform, such as pattern of your use of the Platform, visits, material that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information, IP address and date and time when you access or use Platform. Cookies are small, encrypted files, that the Platform transfers to the device through which you access our Platform. For more information, please refer to our cookie policy.
Accuracy of information
User undertakes that he shall be solely responsible for the accuracy, correctness, or truthfulness of the Personal Information shared with us whether of its own or any third party. In the event the User is sharing any Personal Information on behalf of a third person, the User represents and warrants that he has the necessary authority to share such Personal Information with the Company, obtained a written consent from such third party and the Company shall not be responsible for verifying the same. The User understands and acknowledges that such Personal Information shall be subject to the terms and conditions of this Privacy Policy.
Use of Personal Information
We use the Personal Information for the following purposes:
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to inform you about our Services and to respond to your requests;
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for creation or development of business intelligence or data analytics in relation to the Services provided by us (for this purpose we may share the Personal Information with certain software or tools available online)
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to provide you with a better experience when you access our Platform and to improve the Services;
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to maintain and manage our Platform;
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to manage our relationship with you;
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for internal record keeping; and to comply with our legal or statutory obligations.
Disclosures
We do not sell, rent, share, distribute, lease or otherwise provide your Personal Information to third parties, without your prior consent. Keeping this in mind, we may disclose your Personal Information in the following cases:
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Affiliates: We may provide your Personal Information to our affiliates to enable them to improve the Offerings, provide feedback and respond to their queries.
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Service Providers: We may share your Personal Information with the service providers who work with us in connection with operating the Platform and/ or providing the Offerings. All such service providers are subject to stringent confidentiality restrictions consistent with this Privacy Policy.
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Merger or Acquisition: We may transfer your Personal Information if we are acquired by another entity, or if we merge with another company or transfer a part of our business, including the Platform, to a third party. Any such third party or resultant entity that receives your Personal Information shall have the right to continue to use your Personal Information in line with the purposes set out herein. In the event of such a sale or transfer, we may notify you.
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Legal and Regulatory Authorities: We may disclose your Personal Information in order to comply with our legal obligations/ court orders/ requests by Govt. authorities.
Third Party Tools
Company or third parties may make available on the Platform third-party tools along with the Services (“Third Party Tools”). Services may contain features designed to interoperate with Third Party Tools. To use such features, User may be required to obtain access to such Third Party Tools from their Third Party Service Providers. You are allowed to copy third party URLs (Uniform Resource Locators) provided by platforms like Google, Microsoft, Dropbox, Figma and others; you can collaborate with other Cubyts users using the collaboration functionalities offered by the Platform.
We use the URL for the following purposes:
(i) You are provided with an explicit option to copy openly accessible and protected (authorization enabled) URLs from third party websites and save them in the Platform.
(ii) If the URL is protected (i.e. needs your authorization) then we seek your explicit authorization before we save the URL in the Platform, the scope of authorization is provided to you when you authorize the Platform.
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Note: In the case of protected URLs, You have the right to deny authorization.
(iii) The platform saves the URL in order to improve the quality of outcomes (in the case of files from Google drive; the platform does not retain the data obtained through Google Workspace APIs therefore user data is not used to create/develop, improve or train, a generalized machine learning or artificial intelligence model).
(iv) The Platform renders the content in the URL as an IFRAME, a standard technology (or HTML element) that allows embedding another document within the current HTML document delivered by the Platform.
(v) You may delete this URL stored by the Platform to remove any references.
(vi) You may also delete the authorization provided by you by directly going to the provider’s administration page/account management page (e.g. you may go to Google’s account management page to remove access to the Platform).
(vii) The Platform does not share the URL unless approved by you with any other user of the Platform.
(viii)The Platform adheres to the terms and conditions & user data policies enforced by the provider. In a case where the Platform uses provider’s APIs then the Platform adheres to the Provider’s APIs terms of service.
(ix) You may reach out to support@cubyts.com if you have any questions about this section.
Data Retention
We will retain User’s Personal Information as long as it is required to be retained for the purpose of provision of the Services. We may also retain and use User’s Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
In the case of Google drive files; We do not retain the data obtained through Google Workspace APIs, therefore user data is not used to create/develop, improve or train, a generalized machine learning or artificial intelligence model.
Security
Your Personal Information is stored on public cloud infrastructure hosted on AWS (Amazon web services). We have implemented algorithms to encrypt Personal Information. Although we provide appropriate firewalls and protections, we cannot warrant the security of Personal Information transmitted as these systems are not hack proof. Data pilferage due to unauthorized hacking, virus attacks, technical issues is possible, and we will take necessary measures to mitigate such events.
Your Rights
Visitors of the Website that have shared Personal Information with us through the Website have the right to access Personal Information in our possession, right to have us rectify or modify any such Personal Information, right to have us erase/delete your Personal Information, right to restrict us from processing such Personal Information, right to object to our use of Personal Information, withdraw consent at any time where we are relying on consent to process Personal Information Depending on the nature of the request, we may ask Visitor of the Website to complete a Personal Information request form or seek certain details to verify the request. In certain cases, we may charge a fee for this service, and we will inform at the time. All requests for Personal Information will be handled within a reasonable period of time. If such Visitor would like to exercise ANY of these rights, please contact support@cubyts.com. For any further issues related to the App Users may reach out to their admin, if the issue is not resolved through the admin they may reach out to us at the above-mentioned email address.
Choice and Opt-Out
We may send you communications including but not limited to (a) notices about your use of our Platform and Services, including those concerning violations of use, (b) updates, (c) promotional information regarding our Services, and (d) newsletters. You may opt out of receiving promotional emails and newsletters from us by following the unsubscribe instructions provided in those emails. Alternatively, you can opt out, at any time, by emailing support@cubyts.com with your specific request.
Information for EU and UK Visitors
Residents of the European Union (“EU”) and United Kingdom (“UK”) should note that this Privacy Policy has been updated in accordance with the requirements of the EU General Data Protection Regulation (the “GDPR”) and the UK GDPR, the United Kingdom Data Protection Act 2018, the Privacy and Electronic Communications Regulations, and any regulation superseding any of the foregoing (“UK Privacy Laws”). As per the provisions of the GDPR and UK Privacy Laws we shall be considered the Controllers of the Personal information collected as a result of your use / access of the Website and Processors of the Personal information collected as a result of your use / access of the Platform.
Legal Basis (for EU residents and UK residents): We will not process your Personal Information without a lawful basis to do so. We will process your Personal Information only on the legal bases of consent, contract, or on the basis of our legitimate interests, provided that such interests are not overridden by your privacy rights and interests.
Transfer of your personal information across borders (for EU Residents): The Personal Information we collect (of EU and UK residents) is stored on servers located in the EU region. Personal Information might be processed outside the EU and UK. We collect and transfer Personal Information outside the EU and UK in accordance with the provisions of the GDPR and UK Privacy Laws. If you have questions, please contact legalqueries@cubyts.com.
Your Rights (For EU and UK Residents):
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You have the right to request us,
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to let you know what Personal Information belonging to you,
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we hold in our possession,
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withdraw consent at any time where we are relying on consent to process your Personal Information,
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right to have us rectify or modify any such Personal Information,
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right to have us erase/delete your Personal Information,
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right to restrict us from processing such Personal Information,
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right to object to our use of your Personal Information,
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you have the right to lodge a complaint with a data protection authority.
UK residents have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. We may need to request specific information from you to help us confirm your identity or also contact you for further information in relation to your request. If you would like to exercise ANY of these rights, please contact legalqueries@cubyts.com.
Governing Laws: For any EU and UK residents, this Privacy Policy shall be governed respectively by the provisions of the GDPR and UK Privacy Laws.
California resident rights
If you are a California resident, you have the rights as mentioned below;
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Access- You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. If we have disclosed your Personal Information for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient. If we have sold your Personal Information over the past 12 months, we will identify the categories of Personal Information purchased by each category of third-party recipient.
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Deletion- You have the right to request that we delete the Personal Information that we have collected from you.
Exercising Your Rights – To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Information and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Information provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request. We will respond to your Valid Request within 45 days of receipt. We will not charge you with any fees for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants any fees, we will notify you of the fees and explain that decision before completing your request. You may submit your Valid Request at [insert email address]
No Discrimination
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our Offerings, charge you different prices or rates, or provide you a lower quality of our Offerings if you exercise your rights under the CCPA.
Links to other Websites
Our Platform may contain links to other Platforms/applications of your interest. Please note that we do not have any control over such other Platforms/applications, and you will be accessing these Platforms/applications at your own risk. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such Platforms/applications and those are not governed by this Privacy Policy. You should exercise caution and look at the privacy policy applicable to such Platforms/applications.
Limitation of liability
To the extent permissible under the law, we shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages, including but not limited to, damages for loss of profits, goodwill, data, information, or other intangible losses (even if we have been advised of the possibility of such damages), arising out of this Privacy Policy.
Governing laws
This Privacy Policy shall in all respects be governed by and construed and enforced in accordance with the laws of State of Delaware, USA and the courts of Delaware shall have an exclusive jurisdiction to adjudicate any subject matter under this Privacy Policy.
Changes to this place
Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the Website and indicate the date of the latest revision. If such modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change via email or through our Website.
This Privacy Policy was last modified on 25th June 2024.
Contact us
If you have any questions or concerns or grievances regarding this Privacy Policy, or wish to withdraw your consent in relation to the processing of your Personal Information you can reach out to our appointed grievance redressal officer Raghu Sarangarajan via email at raghu@cubyts.com.