Privacy Policy for Cubb under the incorporated company Skills of the Modern Age Pty Ltd

Your privacy is important to us. It is Skills of the Modern Age's policy to respect your privacy regarding any information we may collect from you across our websites, http://dashboard.cubb.apphttp://cubb.app, and other sites we own and operate.

This Privacy Policy sets out our commitment to protecting the privacy of Personal Information provided to us or otherwise collected by us, offline or online including through this website (the “Services”) for logged in and identified users.

In this User Privacy Policy “you” means any party that provides Personal Information to us and “we” or “us” means Skills of the Modern Age Pty Ltd (ABN 84 615 270 025).

Please read this User Privacy Policy carefully. By providing Personal Information to us, you consent to our collection, holding, use and disclosure of your Personal Information in accordance with this User Privacy Policy. Please contact us if you have questions, our contact details are at the end of this User Privacy Policy. If you do not wish to provide Personal Information to us, then you do not have to do so.

How this Privacy Policy works

As an Australian business, this User Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles. In addition to the Australian laws, individuals located in the European Union (“EU”) may also have rights under the General Data Protection Regulation 2016/679 (“GDPR”). Appendix 1 outlines the details of the additional rights of individuals located in the EU as well as information on how we process the personal information of individuals located in the EU.

Definitions

Throughout this User Privacy Policy:

User means any person who has registered an account on our Services, either through creating a new workspace themselves or being invited to an existing workspace by a Customer.

Personal Information is as defined in the Privacy Act 1988 (Cth) (“Privacy Act”). The Privacy Act defines ‘Personal Information’ as “Information or an opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not.”

Collection means any collection of artefacts (ie. Persona, Journey Map, Survey) created by a User on the Services.

Customer Data means any content added by a User to the Services.

 

Personal information

What information you provide to us

As a User of the Services, you provide information to us. This includes:

  • profile information like your name, email address, and profile photo;
  • content you provide through the Services, for instance collections, journey maps, tags, files;
  • when you subscribe to our paid services, your billing details including your address;
  • details of services we have provided to you or that you have enquired about;
  • your responses to questionnaires, surveys, or requests for feedback; and
  • additional Personal Information that you provide to us directly or indirectly through your use of our Services, associated social media platforms or accounts from which you permit us to collect information.

What information we log about you

We log information about your access and use of our Services. This includes:

  • your communications with our Services;
  • your behavior through analytics events;
  • your Internet Protocol (IP) address;
  • your approximate geographic location;
  • the storage of Internet cookies;
  • the type of browser you are using;
  • the type of device you are using; and
  • the type of operating system you are using.

Collection and use of information

We collect and use your information:

  • to enable you to access and use our Services;
  • to enable you to create Collections via the Services;
  • to enable you to add Data to Collections via the Services;
  • to process your payments where you have signed up to a paid service;
  • to contact and communicate with you;
  • to improve our Services through research and development;
  • to prevent and address technical problems;
  • to provide you with support services if requested;
  • for internal record keeping; and
  • for advertising and marketing, including to send you information about our products and services

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

How we share information we collect

We share information we collect about you in the ways discussed below, including in connection with possible business transfers, but we are not in the business of selling information about you to advertisers or other third parties.

Where we disclose your Personal Information to third parties for the purposes listed below, we will confirm that the third party’s privacy policies and procedures are in accordance with the Privacy Act.

Disclosure of personal information to third parties

We may disclose personal information to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • our employees, contractors and/or related entities; and
  • third parties to collect and process data.

Sharing with other users

Certain information will be shared with other members of a collection. These people are usually colleagues you work with day-to-day, or clients you have added to a collection.

The information shared with other users in a collection includes:

  • profile information like your name, email address, and profile photo; and
  • content you add to the Services, for example artefacts, research and tags.

International transfers of personal information

The personal information we collect is stored and processed in Australia and Singapore, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

Skills of the Modern Age Data Controller
Nate Sturcke
hello@soma.academy

This policy is effective as of October 12, 2020.

Cookie Policy

We use cookies to help improve your experience of http://dashboard.cubb.app and http://cubb.app. This cookie policy is part of Skills of the Modern Age's privacy policy, and covers the use of cookies between your device and our site. We also provide basic information on third-party services we may use, who may also use cookies as part of their service, though they are not covered by our policy.

If you don’t wish to accept cookies from us, you should instruct your browser to refuse cookies from http://dashboard.cubb.app and http://cubb.app, with the understanding that we may be unable to provide you with some of your desired content and services.

What is a cookie?

A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognize your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.

Cookies are used to enable certain features (eg. logging in), to track site usage (eg. analytics), to store your user settings (eg. timezone, notification preferences), and to personalize your content (eg. advertising, language).

Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing. We use essential cookies to enable certain functions on our website.

Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services. We use performance cookies on our site.

Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and time zone settings). With this information, websites can provide you with customized, enhanced or optimized content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service. We use functionality cookies for selected features on our site.

Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service. We use targeting/advertising cookies on our site.

Third-party cookies on our site

We may employ third-party companies and individuals on our websites—for example, analytics providers and content partners. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by Skills of the Modern Age's cookie policy.

Our third-party privacy promise

We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.

How you can control or opt out of cookies

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.

Appendix 1: Additional rights for individuals located in the European Union

Under the GDPR individuals located in the EU have extra rights. Personal Information under the GDPR is referred to as ‘personal data’ and is defined as: “means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person” (Personal Data).

This Appendix sets out the additional rights we give to individuals located in the EU, including how we process Personal Data lawfully, transparently and fairly.

Legal bases for processing (for EEA users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:

  • we need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
  • it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
  • you give us consent to do so for a specific purpose; or
  • we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.

Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Data Retention

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘access, erasure and data portability’ below for further information.

In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymized information indefinitely without further notice to you.

Data Transfers

The countries to which we send data for the purposes listed above may not have the same data protection laws as the country in which you initially provided the information. If we transfer your Personal Data to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred Personal Data in accordance with the Privacy Policy, as supplemented by this Appendix.

Special rights for EU individuals

Objecting to processing: You have the right to object to processing of your Personal Data that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your Personal Data.

Restricting processing: You have the right to request that we restrict the processing of your Personal Data if (i) you are concerned about the accuracy of your Personal Data; (ii) you believe your Personal Data has been unlawfully processed; (iii) you need us to maintain the Personal Data solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Access, erasure and data portability: You may have the right to request details of the Personal Data we hold about you, or to request that we erase the Personal Data we hold about you, or that we transfer this information to a third party.

Rectification: If you believe that any Personal Data we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, incomplete, misleading or out of date.

For questions and notices, please email nate@soma.academy