1.3 We shall process your personal information in different scenarios based on different legal reasons, such as performing contracts and providing products and/or services to you, based on legitimate business interests or with your prior consent, as further detailed below. You will always have the right to object to the processing of your personal information on grounds relating to your particular situation.
In any scenario in which you interact with us, we are likely to ask you to provide personal information. If you do not provide the relevant information, you may in certain situations not be able to achieve the specific purpose for a particular scenario. For example, you cannot purchase a Cubot product; our call center cannot reach you and provide you with pre-sales and after-sales service; or you cannot download updated software systems and/or applications.
Here are some of the scenarios where we collect your personal information:
2.1 When you register for an account and purchase a Cubot product, you shall provide relevant personal information, such as user name, gender, phone number, email, mailing address, zip code, consignee information, method of payment and bank account information, etc.
2.2 Where permitted by law, Cubot shall also obtain data about you from third-party sources. For example, when you use a third-party network account to register for an account in Cubot or login to our website, Cubot will obtain your account information from a third-party network service company. Depending on your choice of third-party network account, we may collect your Facebook account or Google account information. In such case, only the account information, such as Account ID, e-mail address, and profile picture, will be obtained.
2.3 When you activate and use a Cubot product, we shall also collect information about your device or software, such as device name and model, device ID (such as IMEI and SN), operating system version number, language selected for the device, time zone, information of telecom operator (such as operator name, MCC/MNC), serious error log of system and other basic system/device information.
2.4 Network information: for example, the type and version of browser used when you login to the Cubot online store, language, OS version, resolution, website operating elements, your web IP address and web browsing information, as well as user behavior and other information collected by Cubot through cookies and other similar technologies.
2.5 Location information: information from you or other users, including your geographic location, such as the region contained in the account information you have provided; country information displayed by the telecommunications carrier code you use. Some pre-loaded, location service-based apps such as maps, navigation and weather service apps will collect your location information with your consent.
2.6 When you call our customer service center for assistance, we shall ask for your name, phone number, product information and receiving time, and record your number of calls, date of call, problem encountered and the solution we give to you.
2.7 If you participate in one of Cubot offline product experience events, we will also ask for information such as your name, gender, email address, and phone number.
2.8 Your information shared through Cubot Community, such as your personal photos uploaded at a Shot On Cubot event; your thoughts and experiences shared through forums and friends, etc.
2.9 We may legally obtain information about you from other sources, and combine this data with information we already have about you. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
Cubot will use your personal information based on the following purposes. One or more purposes may be applied at the same time. If we use your personal information beyond the following purposes or the scope allowed by the law, we will obtain your consent again on the basis of special purpose needs.
3.1 Used for authentication, security, fraud monitoring, archiving and backup purposes to ensure the security of products and services provided to you by Cubot. The legal basis for such processing is our legal obligation to implement appropriate technical and organizational measures to ensure a level of security of such processing.
3.2 Provide you with services such as order processing; receipt and delivery of goods; refund of payment for goods; after-sales maintenance; implementation of electronic security plans; push system upgrade information, and other similar purposes. The legal basis for such processing is the proper performance of the contract we enter with you when you purchase our products and/or services
3.3 Contact you directly. In the process of providing products and services to you, we may contact you directly based on the contact information you have provided us. For example, if you post content on the Cubot website indicating that you have a complaint about a Cubot product or service, or need technical assistance from Cubot, we will contact you to obtain further information and provide you with assistance. The legal basis for such processing is the proper performance of the contract we enter with you upon your purchase of our products and/or services.
3.4 Help Cubot to improve products and services. For example, Cubot will analyze and study the collected data to make user-friendly adjustments to its operating system and interface design in accordance with user characteristics. When you choose to send error details to Cubot, Cubot can modify the software according to the specific error information, which helps to ensure that the similar software errors will not happen again. The legal basis for such processing is our legitimate interest in improving our products and services.
3.5 Cubot may know about the regional distribution of Cubot products through the receiving address of the user and the country in which the SIM card operator is located, and adjust our after-sales service network layout, personnel, language and other details, so as to make it easier for users to purchase Cubot products and experience Cubot services. The legal basis for such processing is our legitimate interest in improving our products and services.
3.6 With your consent, Cubot may send you our latest product and service information, and may also send you holiday greetings. You may choose to unsubscribe at any time if you do not wish to receive such information. The legal basis for such processing is your consent.
4.3 In addition to cookies, Cubot also uses other similar technologies such as local storage, web beacons, and pixel tags on its website. Like local storage of HTML5, this can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between different web pages of the Cubot website. For another example, an email sent to you may contain a click URL linked to the content of the website. If you click on the link, this click will be tracked to help Cubot better understand your product and service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or e-mails. With the help of the pixel tags in emails, Cubot can know whether the email content is effectively served to the user.
5.1 We will disclose your personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for your personal information between affiliates and subsidiaries.
5.2 Cubot will disclose your personal information to its service providers under certain circumstances. For example, when you purchase Cubot products through Cubot’s online store, Cubot will disclose your product purchase and shipping information to our authorized logistics service provider. As another example, when you purchase Cubot products through Cubot’s online store, your payment information will be processed by our contracted payment service providers. Cubot requires such service providers to comply with relevant cybersecurity laws and regulations (such as PCI DSS, ISO 27001 certification).
5.3 In addition, Cubot shall disclose your information to public authorities with jurisdiction over the territories in which we operate to provide personal information of our users in compliance with the law or in the performance of legal procedure. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
5.4 In any case of sharing your personal information with third parties, we endeavor to disclose it to such third parties only to the extent permitted by law and we require data recipients to process and protect your personal information in compliance with applicable laws and regulations
5.5 Cubot promises not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law.
6.1 Cubot will take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other personal information provided when using Cubot services. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.
6.2 You are also entitled, to restrict under certain circumstances the processing of your personal information and to request a copy of the personal information you provided us in a structured, commonly used and machine-readable format.
6.3 You can control your own personal information. For example, you can turn off the location sharing button to stop sharing your device's location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make the above choice, you may not be able to enjoy the related services.
6.5 You shall have the right to lodge a complaint with the data protection supervisory authority of your habitual residence, as applicable, in case you believe that the processing of your personal information infringes any applicable regulation.
7.2 Cubot uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, Cubot uses encryption technology (such as TLS) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access Cubot services may be subject to problems that are beyond Cubot’s control.
7.3 If Cubot is informed that the security of data it has acquired and stored is compromised or the user's nonpublic information is disclosed to an unrelated third party due to external acts (such as cyber attack), Cubot will take reasonable actions. These actions may include internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies, and other actions Cubot may consider appropriate to reduce the impact of data leakage accidents on users, notwithstanding any disclaimer in this Policy. In parallel, Cubot will take legal and reasonable steps it may deem appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations.
7.4 Cross-border data transfer: your personal information may be transmitted and transferred across borders (regions), and stored and processed in the target country (region). Depending on the laws in your country and region, the receiving country and region of these data may not meet the requirements. We promise that we will have the right security and privacy safeguards to ensure that the protection level of data can meet the full requirements of the laws and regulations of your country and region.
8.1 Our products and services are primarily designed for adults. Anyone who is identified to be a minor customer under the laws of the country in which (s)he is located must obtain the consent of his or her parents or guardians before using our products and services upon purchase.
8.2 We value the privacy protection of minors and encourage parents to always play an active role in their child's online experience.
9.2 We are not responsible for how third parties collect, use, share, transfer and protect user's personal information, and cannot control how it is processed.
11.1 Any notice from Cubot will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of Cubot product, or pushed directly through mobile phone system. If sent via electronic methods, notice shall be deemed served when your device or the used electronic system receives the message; if sent by courier, it shall be deemed served on the third day after sending out.
Last updated date: April 10, 2020.