Privacy Policy

Data Processor

Brand name: KubeIn

Company Name: Kube Ecosystem S.L. (from now on, Kube Ecosystem)

NIF: B67040998

Postal Address: Gran Via 41, 08015, Barcelona.

Correo electrónico: info@kubein.vc

Kube Ecosystem, as the Data Processor for the Website, in accordance with the provisions of Regulation (EU) 2016/679 of April 27, 2016 (GDPR) on the protection of natural persons with regard to the processing of personal data and the free movement of this data and other current regulations on the protection of personal data, and by Law 34/2002, of July 11, Services of the Information Society and Electronic Commerce (LSSICE), informs you that we have implemented the measures of necessary security, of technical and organizational nature, to guarantee and protect the confidentiality, integrity and availability of all entered data.

PURPOSE OF PERSONAL DATA PROCESSING

– We use your information sent through contacta form only for evaluating investment opportunities offered.
– You will not receive marketing communications.
– We use the information we gather, like cookies, to improve the browsing experience with the Online Services; analyze data to generally improve our Services and collect information about the travel destinations that interest you, so that you recieve relevant announcements and offers.
– From time to time, and normally after an interaction with us, we will ask you to send us feedback to ensure that we are providing services that meet your expectations.

Your personal data will only be used for the following purposes:

– To carry out the necessary administrative procedures with Web Users;
– To respond to queries and/or provide information requested by the User;
– To use your data to contact you, both electronically and non-electronically, to obtain more information about investments proposed
– To notify you about changes, important developments of the privacy policy, legal notices or cookies policy.
– Analysis of profiles and usability will be carried out.
– Client and/or suppliers data will be processed, within the contractual relationship that links them with the person in charge, in compliance with the administrative, fiscal, accounting, and working obligations that are necessary under the current legislation.

You can revoke your consent at any time by sending a letter with the subject “UNSUBSCRIBE” to info@kubein.vc.

In accordance with LSSICE, Kube Ecosystem does not partake in SPAM practices, therefore, it does not send commercial emails that have not been previously requested or authorized by the User. Consequently, in all the communications that you will receive from the provider, the User has the possibility of canceling his or her express consent to receive our communications.

We will not use your personal data for any other purpose than those described except by legal obligation or judicial requirements.

DATA RETENTION POLICIES

Your data will be kept for the duration of th relationship with us or until you exercise your right to cancellation or opposition, or limitation to processing. However, we will keep certain personal identification and traffic data for a maximum period of 2 years in case it is required by the Judges and Courts or to initiate internal actions derived from the improper use of the website.

Likewise, we inform you that our data retention policies comply with the terms established by the different legal provisions regarding legal expiry terms:

a) General Rule:

By virtue of the provisions of article 30 of the Commercial Code, and except for other criteria, all the documents and / or information of the company will be kept for 6 years.

This affects all accounting, tax, labor or commercial documentation, including mail.

b) Specific terms:

Our company must also set a minimum retention time depending on the type of data in question and according to the different legal prescription periods, which must be known by each of the departments.

This table lists the retention terms that affect or may affect our organization:

Theme	Retention terms	Provision
Labor for infringement purposes	3 years	Art. 4.1 RD 5/2000
Social Security for for infringement purposes	4 years	Art. 4.2 RD 5/2000
Labour Risk Prevention for infringement purposes	5 years	Art. 4.3 RD 5/2000
Fiscal for the purpose of tax debts	4 years	Art. 66 Ley 58/2003
Fiscal for the purpose of checking quote compensations or applied deductions	10 years	Art. 66 bis Ley 58/2003
Accounting and Commercial	6 years	Art. 30 del CC
Crimes against Public Finance and Social Security	10 years	Art. 131 LO 10/1995

Your data will not be subject to decisions based on automated processing.

LAWFULNESS OF PERSONAL DATA PROCESSING

a) Execution of the contract.
b) Consent of the interested party.
c) Compliance with legal obligations.
d) Legitimate interest: sending our own promotions.

COMMUNICATIONS

Any communication sent will be incorporated into the Information Systems of Kube Ecosystem. By accepting these conditions, terms, and policies, the User expressly consents to Kube Ecosystem carrying out the following activities and/or actions, unless the User indicates otherwise:

– The storage of personal data during the periods provided in the applicable provisions.

OFFICIAL MEANS OF COMMUNICATION

The User is informed that the means enabled by the company to communicate with customers and others affected are the corporate phone, corporate mobile phones, and corporate email.

If you send personal information through a means of communication other than those indicated in this section, the PROVIDER will be exempt from liability in relation to the security measures available regarding the medium in question.

ASSIGNMENTS OR TRANSFERS RECIPIENTS

Kube Ecosystem will carry out data transferring or communication to third parties that will process data within the EU. Nevertheless, there will not be any international transferring of data outside these boundaries. The User expresses hereby the consent of such transferring of data limited to the purpose stated in this document.

Kube Ecosystem will hand out data information to the authorities and to the police if there is a need to comply with a legal procedure, legal obligation, without prejudice of blocking or cancelling an account if there are signs of criminal offence. The information handed to the authorities in such an event will only regard the current information stored by the service provider.

The information that you provide us both through this website and through the application will be hosted on the servers of Kube Ecosystem.

Many tools we use to manage your data are contracted to third parties.

RIGHTS OF CONCERNED INDIVIDUALS

As a concerned User, you can request to exercise the following rights before Kube Ecosystem by submitting a letter to the postal address located in the letterhead or by sending an email to info@kubein.vc, indicating as Subject: “GDPR, Rights affected”, and attaching a photocopy of your National Identity Document (DNI) or any analogous document, as indicated by law.

Rights:

Access rights: allows the interested party to acknowledge and obtain information about their personal data submitted to processing.
Right to rectification or deletion: it allows to correct errors and modify the data that proves to be inaccurate or incomplete.
Right to cancellation: allows data that turns out to be inadequate or excessive to be deleted.
Right to opposition: the right of the interested party to not carry out the processing of their personal data or to cease it.
Limitation of personal data processing: involves the marking of personal kept data, with the purpose of limiting its’ future processing.
Portability of the data: facilitation of the data subject to processing to the interested party, so that he or she can transmit it to another person in charge, without impediments.
The right not to be subject to automated individual decisions (including the elaboration of profiles): the right not to be the subject of a decision based on automated processing that produces effects or significantly affects the User.

As a User, you have the right to withdraw consent given at any time. The withdrawal of consent will not affect the lawfulness of the process carried out before the withdrawal of consent.

You also have the right to submit a claim to the supervisory authority if you believe that your rights may have been violated in relation to the protection of your personal data (agpd.es).

ADDITIONAL INFORMATION

INFORMATION WE COLLECT:

The data collected by data controller is the following:

– Data provided by the users through the different services offered on the website.
– Data included in the different forms provided on the website.
– Data collected through “cookies” to improve the browsing experience as reported in the cookie policy.
– We engage collected data into profiles and usability analytics to improve the User’s experience through our platform.
– Data provided by the customers receiving the services, by any means.

Through this Privacy Policy we inform you that the photographs that are posted on the website are property of Kube Ecosystem, including those of minors, of which, in order to obtain these, prior consent of the parent, tutors, or legal representatives has been obtained by signing the forms made for that purpose by the centers in which matters regarding minors are regulated.

VIDEO SURVEILLANCE

In some vending point footage is captured for the sole purposes indicated in this Privacy Policy and / or at the request of the legal authorities.

We have informational documentation available at the request of anyone interested and a signal warning of the video-monitoring area ,located in a visible place prior entering the surveillance range to inform that the venue is a video-surveilled location.

All footage captured by the surveillance cameras will be limited to the inside of the establishment. No images of public roads will be captured except for a minimum strip of access to the venue.

The recording system will be located in a guarded or restricted access place. The images obtained will be accessed only by authorized personnel and will be kept for a maximum period of one month from their capture.

SOCIAL NETWORKS

We inform you that Kube Ecosystem may have a presence on social networks. The processing of data that is carried out concerning the people who become followers on social networks (and/or carry out any link or connection action through social networks) of the official pages of Kube Ecosystem will be governed by this section, as well as those conditions of use, privacy policies, and access regulations that belong to the social network that is appropriate in each case and previously accepted by the User.

Kube Ecosystem will process your data with the purpose of correctly managing your presence on social networks, informing you of the provider’s activities, products, or services, as well as for any other purpose that the regulations of the social networks allow.

The publication of the following content is prohibited:

– That is unlawful by national, community, or international regulations or that they carry out activities that are presumably unlawful or contravene the principles of good faith.
– That threaten the fundamental rights of people, lack courtesy in the network, annoy or may generate negative opinions to our Users or third parties and in general whatever the content that Kube Ecosystem deems inappropriate.
– In general that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, consumer protection, and intellectual and industrial property rights.

Likewise, Kube Ecosystem reserves the right to remove, without notice from the website or the corporate social network, those contents deemed inappropriate.

Communications sent through social networks will be incorporated into a file owned by Kube Ecosystem, and may send you information of interest.

In any case, if you send personal information through the social network, Kube Ecosystem will be exempt from liability in relation to the security measures applicable to this platform, which is the Users’ responsibility to know, by checking the corresponding conditions particular to the network in question.

SECURITY MEASURES:

The information you provide will be processed confidentially. The Provider has adopted all the technical and organizational measures and all the levels of protection necessary to guarantee the security in the processing of the data and to avoid its alteration, loss, theft, processing or unauthorized access, according to the state of technology and nature of the stored data. Likewise, it is also guaranteed that the processing and registration in files, programs, systems or equipment, premises and centers comply with the requirements and conditions of integrity and security established in the current regulations.

LANGUAGE

The language applicable to this Privacy Policy is English. Therefore, in case there is any contradiction in any of the versions provided in other languages, the English version will have prevalence.

SENDING OF CV

In the event that the User submits his or her CV through any means established by Kube Ecosystem, we inform you that the information provided will be processed to make him or her participant in the selection processes that may exist, carrying out an analysis of the applicant’s profile in order to select the best candidate for the vacancy of the Company (Provider). We inform you that this is the only official procedure to accept your CV, so CVs submitted by another procedure will not be accepted. In case of any change in the data provided, please inform us in writing as soon as possible, in order to keep your data properly updated.

The data will be kept for a maximum period of one year, after which the data will be deleted guaranteeing a total respect to confidentiality both in the processing and in its subsequent destruction. In this sense, after the aforementioned deadline, and if you wish to continue participating in the selection processes of the Company (Provider), please re-submit your CV.

The data may be processed and/or communicated to the member companies of our group during the time of conservation of their curriculum and for the same purposes previously reported.

CHANGES IN THE PRESENT PRIVACY POLICY

Kube Ecosystem reserves the right to modify this policy to adapt it to new legislation or jurisprudence dispositions (case law).

LEGISLATION

For all purposes, the relationship between Kube Ecosystem and the Users of its telematic services, present on this Website, are subject to the Spanish legislation and jurisdiction to which the parties expressly submit to.

TERMS

Through our website www.kubein.vc (hereinafter, the “Website”) the public may access news, information and events organized by Kube Ecosystem S.L., as well as certain corporate information for our partners and investors.

By using this Website and its services, you agree to comply with and be bound by the following terms of use (the “Terms of Use”). Please read them carefully.

First – Terms of use

1.1 The use of our Website attributes the condition of user (hereinafter, the “User”). The fact of being a User implies the total acceptance without waiver of all the policies and policies published on the Website; including these Terms of Use and the Cookies Policy (hereinafter, the “Policies”). You also agree to use this Website in accordance with any applicable law. If you do not comply with these Terms of Use and all related Policies, refrain from using the Website. To the extent that you fully comply with the Terms of Use and the Cookies Policy (in the applicable version at any time), you are authorized to use the Website.

1.2 The Terms of Use or Cookies Policy may be modified by Kube Ecosystem at any time, and it is the sole responsibility of the User to verify its content. Please review the Policies regularly to ensure that you are informed of any changes that may have been made. The use of the Website implies that you agree to be legally bound by the Policies, in their current or modified versions. In case of discrepancy between previous versions of the Policies and their updated versions, the latter will prevail.

Second – Use of the website.

2.1 The maintenance of this Website is due to our desire to improve public access to information, news and events related to Kube Ecosystem, as well as certain information of a corporate nature for our partners and investors. Our goal is that the content of the Website is at all times adequate and correct. If you are aware of the existence of errors in the content of the Website, we will try to correct them as soon as possible. However, we decline any obligation or liability with respect to the accuracy of the content posted on the Website.

2.2 We reserve the right to update or delete any content of the Website, as well as to limit or deny access to any User, temporarily or permanently. Notwithstanding the foregoing, this disclaimer is not intended to limit our liability in case of breach of any obligation imposed by applicable national law, nor exclude our liability in matters in which it cannot be excluded under such legislation.

2.3 All content published on the Website, including, but not limited to, copyright, similar or related rights to copyright or sui generis right on databases, patents, utility models, industrial designs, graphics, source code, texts, images, photographs, trademarks, trade names, logos, slogans, domain names, social profiles, interfaces, musical and/or audiovisual works, trade secrets and know-how, regardless of whether they have been registered, have been requested to register or are not registered (hereinafter, the “Content”) are owned by Kube Ecosystem or have been transferred through a license for its exploitation and are protected by all applicable laws on intellectual property and industrial law, including antitrust laws.

2.4 Unless otherwise specified in the Policies, Users may not reproduce, distribute, transform or make the Content public. While expressly authorized, all use of the Content will have to comply with these Terms of Use and all applicable Policies.

2.5 The Website may include links to external and independent third party websites of Kube Ecosystem (hereinafter “Third Party Websites”). Kube Technologies includes these links to offer Users the possibility of accessing other websites that they believe may be of interest to you. Third Party Web Sites are outside our control and we decline any responsibility as to their content. Therefore, the fact that the Web Site includes links to Third Party Websites does not imply in any way that Kube Technologies has approved or that it agrees with the content or the information published in the same. Consequently, we do not assume any obligation with respect to the content or the information published by Third Party Websites and therefore, access to Third Party Websites will be under the exclusive responsibility of the User.

2.6 You are not authorized and should not use the Website to: (i) post, upload, email or otherwise transmit material that is rude, defamatory or obscene that may annoy, disquiet or disturb any person and/or infringe upon rights or prevent their use and enjoyment of the Website; (ii) posting, uploading, emailing or otherwise transmitting unsolicited or unsolicited materials, promotions or advertisements, junk mail, spam, chain letters, pyramidal frames or any other means other form of offer or commercial exploitation; (iii) create an electronic or other database that includes material downloaded or obtained from any other form of the Website; (iv) transmit or proceed to the transmission to a third party of any material obtained from the Website, without complying with the applicable Policies published on the Website; (v) obtain or attempt to obtain materials, documents or information from the Website by any method that is not available on the Website through automatic devices such as deep-links, scrapes, robots, spiders or other similar devices; (vi) access, copy or track any part of the Website, or reproduce or circumvent in any way the navigation structure of the Website or any content; (vii) upload or transmit any material that includes malicious software (virus) or any other code, file or computer program designed to interrupt, restrict, destroy, limit the functionality of, or compromise the integrity of any software or hardware or telecommunications by any means. We reserve the right to prohibit any activity or material of this nature; or (viii) use any part of the Website to link, through any means, with an internal or secondary page of the Website located at one or several levels below the home page (deep link) or to submit Content of the Website on another web page (framing).

Third – Privacy

3.1 The simple visit to our Web Site does not include the obligation to provide information of any kind. Your privacy and the safeguarding of your privacy is the most important thing for us. In case you provide through the Website some personal information, the data collected through the present will be used in the form, for the purpose, and with the limitations and rights contained in Organic Law 15/1999, of 3 (“LOPD”) and Royal Decree 1720/2007, of 21st December, which approved the Regulations for the development of the LOPD (the “RLOPD”).

3.2 By entering your data in a contact form included in the Website, you consent to the storage of your personal data in our files, in order to attend your query and, if necessary, contact you. All data marked with an asterisk in the forms must be filled in as a mandatory requirement so that your query, request or commentary is admitted. No data considered as specially protected by current regulations will be requested, as well as any type of economic data.

3.3 Kube Ecosystem guarantees that the data provided will not be accessible by anyone other than Kube Technologies and that they will only be shown at the request of its own owner, provided that it is duly accredited. Kube Technologies will not transfer your personal data to third parties.

3.4 You will have the right to access at any time your data stored in our files, as well as the rectification, cancellation or opposition to the processing thereof (“ARCO Rights”). You can exercise your ARCO Rights through the email hello@kubein.vc or by letter sent to the following address: Calle Gran Vía 4, 28013, Madrid, España. In all cases, to exercise your ARCO Rights you must prove your identity by photocopy of your identity document or valid passport.

Fourth – Exclusion of Liability

4.1 Kube Ecosystem is in no way obliged to keep the website accessible or to provide the content stored on it. Both the hosting of the website and the provision of content may be canceled, interrupted or suspended temporarily at any time without prior notice. Kube Ecosystem does not guarantee the absence of errors, faults or viruses in the website or the content, nor the absence of interruptions in its supply. Kube Technologies does not assume any liability for direct or indirect damages suffered by the user as a result of the suspension or cancellation of the website and / or the removal of its total or partial content.

4.2 The content of the website is general informational and therefore could be insufficient for the user to adopt a personal or business decision. Kube Technologies is not obliged, in any case, to demonstrate the truthfulness, accuracy, adequacy, integrity and validity of the content. The user agrees that the use of the website and/or the content will be at his own risk and that the website is offered to users as is available. Therefore, no warranty, express or implied, as to the site or the content, including, but not limited to, merchantability, infringement or suitability for a particular use or purpose is made. Insofar as applicable law so permits, Kube Ecosystem assumes no responsibility for the decisions taken by the user based on the information provided on the website, or for direct or indirect damages that may suffer as a result of actions based on the site or the contents.

4.3 Kube Ecosystem will not assume any liability for damages that may be suffered by the user’s hardware, software and / or data from any virus or malicious content or software. The user will be solely responsible for installing the necessary tools to detect and prevent your equipment, hardware, software and/or data from being damaged in any way.

4.4 Kube Ecosystem shall not be liable in any way to users for indirect or direct damages (including incidental, consequential, special, punitive or exemplary damages, if accepted by applicable law) arising from the use or inability to use the site web or content, including, without limitation, lost profits or loss of business. Limitations of liability in some territories are prohibited, so this limitation applies only to the extent permitted by applicable law.

4.5 Kube Ecosystem assumes no liability for damage to your computer equipment, software or information from any virus or any other malicious content or software. It is the responsibility of the user to install the tools necessary to detect and prevent any damage to their equipment, software or information on their computer equipment.

4.6 Under no circumstances will Kube Ecosystem be liable to the user for any direct or indirect (including incidental, consequential, special, punitive or exemplary damages, if permitted under applicable law) arising from the use of the site web or content or the inability to access the website or content, including without limitation any loss of profit or business. Some jurisdictions do not allow liability limitations so this limitation will only apply to the extent permitted by applicable law.

Fifth – Applicable legislation & jurisdiction

These terms shall be governed under Spanish law, to which the parties expressly submit. All conflicts deriving from or relating to the use of the Website will be resolved by the competent courts and tribunals in accordance with applicable legislation.

In the event that any of the terms of this document be declared null, they will be removed or replaced. Should this occur, the validity of the rest of the terms included in this document will not be affected.

Sixth – Data & Privacy Policy

We respect your privacy.

Kube Investments