Privacy Notice

Contents

1. Introduction
2. Explaining the legal bases we rely on
3. When do we collect your personal data?
4. What sort of personal data do we collect?
5. How and why do we use your personal data?
6. Your data for personalised direct marketing
7. How we protect your personal data
8. How long will we keep your personal data?
9. Who do we share your personal data with?
10. Where your personal data may be processed
11. What are your rights over your personal data?
12. Contacting the Regulator
13. If you live outside the UK
14. How to contact us if you have questions?

1. Introduction

This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.

There’s a lot of information here, but we want you to be fully informed about your rights, and how CubeCart Limited uses your data.

We hope the following sections will answer any questions you have but if not, please do get in touch with us.

For simplicity throughout this policy, ‘we’ and ‘us’ means CubeCart Limited.

It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.

2. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent. For example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

Contractual obligations
In certain circumstances, we need your personal data to comply with our contractual obligations. For example, if you order a product or service from us, we’ll collect your billing address, and pass them to our payment service provider.

Legal compliance

If the law requires us to, we may need to collect and process your data. For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example we may use your purchase history to build a list of promotional “Top Extensions”.

3. When do we collect your personal data?

• When you visit any of our “*.cubecart.com” websites, and use your account to buy products and services.
• When you create an account with us.
• When you engage with us on social media.
• When you download or install CubeCart scripts or extensions.
• When you contact us by any means with queries, complaints etc.
• When you enter prize draws or competitions.
• When you comment on or review our products and services.
• When you submit a live store submission.
• When you leave a testimonial.
• When you provide a CubeCart “Success Story”.

4. What sort of personal data do we collect?

• We will collect your name, gender, date of birth, billing address, orders and receipts, email address and IP address. For your security, we’ll also keep an encrypted record of your login password.
• Details of your interactions with us through website and support helpdesk. For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or downloaded, voucher redemptions, web pages you visit and when you contact us.
• Details of your visits to our websites and which site you came from to ours.
• Information gathered by the use of cookies in your web browser. Learn more about how we use cookies and what they are in the appendix at the end of this document.
• Your comments, testimonials, case studies, success stories and product reviews.
• To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country where your computer is located, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
• Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.

5. How and why do we use your personal data?

• To process any orders that you make by using our website. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
• To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
• To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest. For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
• To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
• To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice and legally required information relating to your orders. These service messages will not include any promotional content and do not require prior consent when sent by email. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
• To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
• To comply with our contractual or legal obligations to share data with law enforcement.

6. Your data for personalised direct marketing

We do not partake in direct marketing of any kind other than social media posts via Twitter and Facebook. We will not send promotional marketing emails and we do not keep or maintain a mailing list.

7. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites and apps using ‘https’ technology.

Access to your personal data is password-protected, and all data is secured by SSL encryption.

We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.

8. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning. When you place an order, we’ll keep the personal data you give us for five years so we can comply with our legal and contractual obligations.

9. Who do we share your personal data with?

We share your personal data with third parties when absolutely necessary and for legitimate interests. For example we will share your name and billing address with our card payment providers for fraud management purposes and track your IP address across page loads.

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Currently we use Stripe, PayPal, ZenDesk & Google who will process your personal data as part of their contracts with us.

10. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as the USA.

International orders

If you are based outside the UK and place an order with us, we will transfer the personal data that we collect from you to the us in the UK.

Protecting your data outside the EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

11. What are your rights over your personal data?

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• For example, when you withdraw consent, or object and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as contractual support obligations).
• That we stop using your personal data for direct marketing (either through specific channels, or all channels). This is not something we partake in anyway.
• That we stop any consent-based processing of your personal data after you withdraw that consent.

You have the right to request a copy of any information about you that the we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact our Data Protection Officer via the sales department of our support helpdesk. To ask for your information to be amended, please update your online account, or contact our Customer Services team.

If we choose not to action your request we will explain to you the reasons for our refusal.

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

12. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites)

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 14.

13. If you live outside the UK

For all non-UK customers and if applicable please contact your local information commissioner.

Australia: https://www.oaic.gov.au
Canada: https://www.priv.gc.ca/en/ 
HongKong: https://www.pcpd.org.hk 

14. How to contact us if you have questions?

We are happy to answer any questions you have. Please contact our sales department via our helpdesk.

Appendix

Cookies

Cookies by themselves cannot be used to discover the identity of the user. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This enables you to decide if you want to accept it or not.

Cookies Used

Cookie Name	Organisation	Expiration Time	Description
ccsession	CubeCart	1 Month	Essential session tracking cookie
eucookie	CubeCart	2 Years	Determines of EU cookie note should show or not.
ips4_hasJS	CubeCart Forums	1 Day	This cookie is set by javascript and then later read to determine if javascript is supported in the user agent.
ips4_IPSSessionFront	CubeCart Forums	1 Year	This is a session tracking cookie, used to track the user between page loads.
ips4_IPSTimeZone	CubeCart Forums	1 Year	This cookie is set by javascript to detect the user's local time zone so that the software can adapt the displaying of times automatically.
ips4_member_id	CubeCart Forums	1 Day	This cookie would contain the user's member ID, used to "remember" the user in case their session ends between visits.
ips4_login_key	CubeCart Forums	1 Day	A unique key to authenticate your member ID cookie. This cookie is set after you log in when you tick 'Remember Me' so you can be automatically logged in again in the future.
ips4_device_key	CubeCart Forums	1 Day	Information about the device from which you are browsing. e.g. Phone, tablet or computer.
__stripe_mid	CubeCart Helpdesk	1 Year	Essential session cookie used by Stipe to enable payment processing.
__stripe_sid	CubeCart Helpdesk	30 Minutes	Essential session cookie used by Stipe to enable payment processing.
jqCookieJar_options	CubeCart Helpdesk	1 Year	Holds functional information about your session.
SWIFT_client	CubeCart Helpdesk	1 Year	Used by our helpdesk to deliver the correct page layout.
SWIFT_sessionid40	CubeCart Helpdesk	1 Year	Essential session cookie used by our helpdesk to track user between page loads.
CCS_C1E7E907CE	CubeCart Demo Store	1 Week	Essential session cookie used by our demo store to track user between page loads.
accept_cookies	CubeCart Demo Store	2 Years	This cookies is set after the user has consented to the cookie acceptance dialogue to prevent the message showing on subsequent page loads.
ccScroll	CubeCart Demo Store	1 Year	This is used to memorise how far the user has scrolled in order to display the same on return.
product_view	CubeCart Demo Store	1 Year	This is used to memorise if the products should be displayed as a list of grid.
_ga	Google	2 years	Used to distinguish users
_gat	Google	10 minutes	Used to throttle request rate
_gid	Google	24 hours	Used to distinguish users.
__zlcmid	ZenDesk Chat	1 Year	Stores visitor's machine-id for widget's authentication
__zlcprivacy	ZenDesk Chat	1 Year	Stores visitor's decision on CookieLaw
__atuvc	AddThis Widget	2 Years	Share count cache
__atuvs	AddThis Widget	2 Years	Undocumented