U.S. Privacy Policy

Cubitts KX Group Limited ("we", “our”, or “us”) are committed to protecting and respecting your privacy.

This policy (together with our terms of use and any other documents linked to in our terms) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This privacy policy (the “Policy”) applies to personal data that we collect from you. We do not knowingly collect data relating to children.

It is important that you read this Policy so that you are fully aware of how and why we are using your data. This Policy complies with the requirements of the European Union (EU) General Data Protection Regulation (“GDPR”). Furthermore, our use of your information may be subject to the requirements of the United States’ (“US”) Health Information Portability and Accountability Act (“HIPAA”).  Your rights, if applicable, under HIPAA are outlined in our Notice of Privacy Practices. If you have questions regarding application of HIPAA or GDPR, please get in touch with us.  

Note: visitors to any of our retail locations in the UK should refer to the UK privacy policy available at: https://www.cubitts.com/privacy, which applies in lieu of this policy with respect to such visitors.

The Policy consists of the following sections:

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. CHANGES TO THIS POLICY AND YOUR DUTY TO LET US KNOW OF CHANGES
  3. PERSONAL DATA WE MAY COLLECT FROM YOU
  4. HOW WE COLLECT YOUR PERSONAL DATA 
  5. USES MADE OF YOUR PERSONAL DATA
  6. DISCLOSURE OF INFORMATION
  7. SECURITY
  8. MAINTENANCE AND RETENTION OF PERSON DATA 
  9. CALIFORNIA PRIVACY RIGHTS
  10. OTHER WEBSITES
  11. CHANGES TO THIS POLICY 

1. IMPORTANT INFORMATION AND WHO WE ARE


The data controller who is responsible for your personal data is Cubitts KX Group Limited, 97 Caledonian Road, London, N1 9BT (collectively referred to as: “Company”, “We”, “Us” or “Our” in this Policy). 

If you have any questions or concerns relating to your personal data or this Policy, please contact us using the following contact details:

Email: info@cubitts.com

Postal address: 97 Caledonian Road, London, N1 9BT

If you are a EU citizen or are based in the European Economic Area (“EEA”),  you have the right to make a complaint at any time on the bases outlined in this Policy to the Information Commissioner’s Office (www.ico.org.uk). We would like to have a chance to deal with any concerns before you approach the ICO, and so please contact us in the first instance. 


2. CHANGES TO THIS POLICY AND YOUR DUTY TO LET US KNOW OF CHANGES


We keep this Policy under regular review. This Policy was last updated on 7th May 2019. We may need to make updates or changes to this Policy from time to time. We will inform you of any such changes.

Please let us know if your personal data changes during your relationship with us so that we can update our records.


 3. PERSONAL DATA WE MAY COLLECT FROM YOU


Personal data means any information about an individual from which that person can be identified. It does not include data where the individual’s identity has been removed (anonymous data). We may collect, use, store and process the following types of personal data about you:

Identity Data includes your name, username (or similar identifier), title, date of birth, audio visual recording and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Special Categories of Personal Data includes data concerning an individual’s health such as prescription details, lifestyle details, facial measurements and photographs, and any other health information related to your eyes and/or sight.

We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data as it does not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.


4. HOW WE COLLECT YOUR PERSONAL DATA


We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you

  • purchase our products or services;
  • create an account on our website;
  • subscribe to our service, mailing list and any other publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see below for further details.

COOKIES

Cookies are small amounts of information which we may store on your computer. Cookies make it easier for you to log on to and use the site during future visits. They also allow us to monitor website traffic and to personalize the content of the Site for you. You may set up your computer to reject all or some cookies although, in that case, you may not be able to use certain features on the Site. 

The following cookies are used by us:

  • Google Analytics
  • Intercom
  • Hotjar
  • VWO
  • AdRoll
  • OptinMonster
  • DoubleClick
  • Facebook Pixel
  • Session Cookie
  • Rubicon Project


THIRD PARTIES 

We may receive personal data about you from various third parties:

(a) We may receive Technical Data from:

  • analytics providers such as Google Analytics, AdRoll and Hotjar
  • advertising networks such as DoubleClick and Rubicon Project

(b) We may receive Contact Data from providers of technical services:

  • chat software providers such as Intercom
  • newsletter sign-up providers such as OptinMonster
  • Search providers such as Algolia

(c) We may receive Identity Data from Verisure Services (UK) Limited who is the provider of our instore CCTV monitoring service.


5. USES MADE OF YOUR PERSONAL DATA


Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

1. Identity
2. Contact

Performance of a contract with you

To process and deliver your order including:
1. Manage payments, fees and charges
2. Designing and producing our products and delivering them to you
3. Refining and developing our internal eyewear product development design process
4. Collect and recover money owed to us

1. Identity
2. Contact
3. Financial
4. Transaction
5. Marketing and Communications
6. Special Category Data

1. Performance of a contract with you
2. Necessary for our legitimate interests (to produce our products in accordance with your requirements and deliver them to you and to recover debts due to us)
3. In respect of Special Category Data only, on the basis that you have given your explicit consent to our use of your data for this purpose

To manage our relationship with you which will include:
1. Notifying you about changes to our terms or this Policy
2. Asking you to leave a review or take a survey

1. Identity
2. Contact
3. Profile
4. Marketing and Communications

1. Performance of a contract with you
2. Necessary to comply with a legal obligation
3. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a prize draw, competition or complete a survey

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications

1. Performance of a contract with you
2. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

1. Identity
2. Contact
3. Technical

1. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
>2. Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

1. Identity
2. Contact
3. Profile
4. Usage
5. Marketing and Communications
6. Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

1. Technical
2. Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

1. Identity
2. Contact
3. Technical
4. Usage
5. Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to (a) our use of Special Category Data to produce our products; and (b) sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to our use of this data at any time by contacting us.

We have set out below a description of all the ways we may use your personal data, and the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

SPECIAL CATEGORY DATA

We use health data solely in connection with the processing and delivery of your order, specifically in connection with the production of our products. We process this data on the basis that you have given explicit consent to such processing for this purpose. You have the right to withdraw your consent to our use of this health data, as explained in further detail below. 

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

MARKETING AND OPTING OUT

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you. For the avoidance of doubt health data is only used for the purposes of processing product orders. 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you signed up to our mailing list or newsletter, entered a competition or registered for a promotion. 

We will get your express opt-in consent before we share your personal data with any company outside the Cubitts group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration or other transactions.

Payments using our Site are made through our secure payment solution providers to whom you will be providing credit/debit or other payment method information for payment processing.


6. DISCLOSURE OF INFORMATION


We may have to share your personal data with the third parties set out below for the purposes set out in the table above.

  • Delivery and fulfillment service providers such as UPS
  • Glazing companies 
  • Analytics service providers such as Google Analytics, AdRoll and Hotjar
  • Intercom who provide chat software
  • OptinMonster for newsletter sign-up
  • Advertising networks such as DoubleClick and Rubicon Project
  • Providers of online services such as VWO and Facebook Pixel
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. 

We require all third parties within and outwith the EU  to respect the security of your personal data and to treat it in accordance with the law. 

We may disclose information if legally required to do so, if requested to do so by a governmental entity or regulatory authority, or if we believe in good faith that such action is necessary to comply with legal requirements or process, prevent a crime or protect national security.

If you engage, or we reasonably suspect that you are engaging, in any illegal activity, we may disclose your personal information, to the extent we determine in our sole discretion is necessary to cooperate with appropriate authorities.


7. SECURITY


Although the transmission of data over the internet may be subject to intrusion, we protect your personal data by ensuring we have implemented appropriate physical, electronic and procedural safeguards to avoid unauthorised access or disclosure, accidental loss, use, alteration or destruction of such Information.

Where we engage third-party contractors, as far as is necessary, we may share Information in order for such parties to perform services on our behalf and in accordance with enforceable confidentiality obligations. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


8. MAINTENANCE AND RETENTION OF PERSONAL DATA

You have certain rights in relation to your personal data. Please contact us by email, should you wish to: 

  • Request access to your personal data – enables you to receive a copy of the personal data we hold about you and check that we are lawfully processing it.
  • Request correction of your personal data – you may correct any inaccuracies or incomplete data although we may need to verify the accuracy of the new data you provide
  • Request erasure of your personal data - where there’s no good reason for us to continue to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your data unlawfully or where we are required to erase your personal data to comply with local law.
  • Object to processing of your personal data – where we are relying on a legitimate interest and you object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You may also object where we are processing your data for marketing purposes.
  • Request restriction of processing your personal data - This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request transfer of your personal data – you may request that we transfer data to you or a third party. This only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent to our use of your personal data – where we are relying on consent. This will not affect the lawfulness of processing that we carried out before you withdraw consent. If you withdraw consent, we may not be able to provide products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to exercise any of these rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex in which case we will let you know and keep you updated.

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 unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

We retain Special Category Data which we collect as a result of performing an eye-test instore for 10 years based on advice from the College of Optometrists. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

IP ADDRESS

We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.


9. CALIFORNIA PRIVACY RIGHTS 


If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. 

(i) “Do Not Track” under the California Online Privacy Protection Act (CalOPPA) of 2014. We are not aware of any processes for others collecting personal information about your activities on the Cubitts websites over time and across third party websites, apps, or other online services (behavioral tracking), nor do we knowingly collect information about your activities over time across third party sites and services.  

(ii) California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to: info@cubitts.com or write us at: 97 Caledonian Road, London, N1 9BT

(iii) CALIFORNIA CONSUMER PRIVACY ACT NOTICE 

This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California in the United States. We adopt this policy to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. 

INFORMATION WE COLLECT 


Cubitts collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, Cubitts has collected the following categories of personal information from its consumers within the last (12) months.

Category

Collected?

Information Collected

A. Identifiers.

YES

 A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

YES

 A name, physical characteristics or description, address, telephone number, credit card number, debit card number, or any other financial information, and medical information

C. Protected classification characteristics under California or federal law.

YES

Medical condition, physical or mental disability, and sex.

D. Commercial information.

YES

 Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric information.

NO

F. Internet or other similar network activity.

YES

A consumer’s interaction with a website.

G. Geolocation data.

YES

Physical location or movements (IP addresses).

H. Sensory data.

NO

Audio, electronic, visual, thermal, olfactory, or similar information.

I. Professional or employment-related information.

YES

Current or past job history or performance evaluations.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

NO

K. Inferences drawn from other personal information.

NO


Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information. 
  • Information excluded from the CCPA’s scope.
  • personal information covered by certain sector-specific privacy laws.
  • Cubitts obtains the categories of personal information listed above from the following categories of sources:
  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly when you use our services (i.e. cookies when using our website)


USE OF PERSONAL INFORMATION 

We may use, sell, or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

To provide, support, personalize, and develop our website, products, and services.

To create, maintain, customize, and secure your account with us.

To process your requests, purchases, transactions, and payments and prevent transactional fraud.

To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).

To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.

For testing, research, analysis, and product development, including to develop and improve our website, products, and services.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cubitt’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cubitts about our website users is among the assets transferred.

Cubitts will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

SHARING PERSONAL INFORMATION 

Cubitts may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.


We share your personal information with the following categories of third parties:

  • Service providers.
  • Data aggregators.

DISCLOSURES OF PERSONAL INFORMATION FOR A BUSINESS PURPOSE

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected classification characteristics under California or federal law.

Category D: Commercial information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Delivery and fulfillment service providers such as UPS
  • Glazing companies 
  • Analytics service providers such as Google Analytics, AdRoll and hotJar
  • Intercom who provide chat software
  • OptinMonster for newsletter sign-up
  • Advertising networks such as DoubleClick and Rubicon Project
  • Providers of online services such as VWO and Facebook Pixel
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy. 
  • Any other third parties you have permitted us to disclose your personal information to. 


 YOUR RIGHTS AND CHOICES 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS

You have the right to request that Cubitts disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

DELETION REQUEST RIGHTS

California residents have the right under the CCPA to request that we delete any of their personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) relevant personal information from our records, unless an exception applies.

We may deny California residents’ deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with the requesting individual, or otherwise perform our contract with a requesting individual. 
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.


EXERCISING ACCESS, DATA PORTABILITY, AND DELETION RIGHTS

To exercise the access, data portability, and deletion rights under the CCPA described above, please submit a verifiable consumer request to us by either:

Calling us (Toll free): 187-7672-4040

Visiting: www.cubitts.com/us

Only a California resident, or a person registered with the California Secretary of State that a California resident has authorized to act on their behalf, may make a verifiable consumer request related to their personal information. A California resident may also make a verifiable consumer request on behalf of their minor child.

A verifiable consumer request for access or data portability can only be made twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify the California resident about whom we collected personal information or an authorized representative.
  • Describe the request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to a California resident’s request or provide personal information if we cannot verify that resident’s identity or authority to make the request and confirm the personal information relates to you.
  • Making a verifiable consumer request does not require you to create an account on our website. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

RESPONSE TIMING AND FORMAT

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

PERSONAL INFORMATION SALES OPT-OUT AND OPT-IN RIGHTS

Cubitts does not sell the personal information of its customers to third parties.

NON-DISCRIMINATION 

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

CONTACT INFORMATION  

If you have any questions or comments about this notice, the ways in which Cubitts collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone (Toll free): 187-7672-4040

Website: www.cubitts.com/us

Email: info@cubitts.com


10. OTHER WEBSITES


This Policy applies to our services only. The Site may contain links to third-party websites, plug-ins and applications over which we have no control. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We are not responsible for the privacy policies or practices of such other websites and we encourage you to review the privacy policies, if any, on all such websites.


11. CHANGES TO THIS POLICY 


We reserve the right to modify this Policy from time to time. When we make changes to this Policy, we will post the updated notice on our website and update the notice’s effective date.

Dated 21 May 2019