Welcome and congratulations for choosing to join Cubeler, a business development platform that provides you with products and services, at no-cost, to help you grow your business. This privacy policy (the “Privacy Policy”) describes the information Cubeler Inc. (“Cubeler”, “we”, “us” or “our”) collects when you register for, use, access or otherwise interact with any of our websites, applications, software, products or services, including the Cubeler Business Development Platform (collectively, the “Services”), why we collect it, and how we use and share it.

This Privacy Policy is designed to comply with applicable Canadian privacy laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and Québec’s Act respecting the protection of personal information in the private sector (the “Québec Private Sector Act”).

To provide you with access to the Services, we may collect certain personal information (as defined below) and business information (as defined below) from you, such as your name, address, phone number, and other identifiers (your “Contact Information”). In addition to your Contact Information, we may collect additional information about you and your business, including information on your business’s financial performance through the “Cubeler-Link™” as you use the Services, information you authorize us to collect from third parties, and information you submit to us directly or indirectly (collectively, including your Contact Information, the “Registered User Data”).  We collect, use, and disclose your personal information only with your knowledge and consent, except where otherwise permitted or required by law. We will inform you of the purposes for which your information is collected and obtain your consent before collecting, using, or disclosing your information, as required by PIPEDA and the Québec Private Sector Act.

The Services may include bulletin, message boards and user comment services, chat areas, rating systems, news groups, and other forums designed to enable you to communicate with and share information with other registered users (the “User Communication Features”). We collect all information posted, shared, or transmitted on or using the User Communication Features.

We will not share your Contact Information with anyone not employed by Cubeler or with any person or entity that has not entered into a confidentiality agreement with Cubeler consistent with this Privacy Policy. We may share your Contact Information with “Platform Lenders” (lenders that have entered into an agreement with Cubeler to provide prequalified loan offers to registered Cubeler users) only with your explicit consent and solely for the purposes of providing the Services. We will only use your Contact Information for the purposes of verifying your identity when you contact us to discuss something specific about your registered account, such as when you contact our technical support department to report an issue with your account.  We will not disclose your personal information to third parties for other purposes without your consent, except as required or permitted by law. You have the right to withdraw your consent to such sharing at any time, subject to legal or contractual restrictions.

In addition to the Registered User Data, we may use a variety of technologies, such as cookies and embedded scripts, that automatically collect certain information telling us how you access or interact with the Services (the “Service Usage Information”). The Service Usage Information we collect may include the following:

• Device and browser information. We automatically receive and record information that your browser sends when you are using our Services. This may include information such as your IP address or other device identifiers, browser type, browser language, the date and time you access the Services, and one or more cookies that may uniquely identify the device you use to access the Services.
• Log information. When you use the Services, we may use certain technologies and methods for collecting Service Usage Information about how you interact with the Services. For example, we may collect Service Usage Information through cookies, embedded scripts or other means.
• Location information. We will use your device’s IP address or other device identifiers to obtain the approximate location from where you are accessing the Services, such as your city, State, or Zip code, to enhance the Services and bring you offers from our marketing partners. We will not collect your specific location information without your consent.
• We may associate your unique device identifier or Service Usage Information with any Contact Information you provide, but we will treat the combined information as Contact Information as long as it is combined

No method of data transmission over the Internet or method of electronic data storage is 100% secure. While we use, and will continue to use, industry-standard technologies and practices to protect your information, we cannot guarantee its absolute security.  We have implemented physical, organizational, and technological safeguards appropriate to the sensitivity of your personal and of your business information. In the event of a security breach involving your personal or of your business information, or both, that creates a real risk of significant harm, we will notify you as required by PIPEDA and the Québec Private Sector Act. If you have any questions or inquiries about security on this website or about the Services, please contact us at privacy@cubeler.com.

For the purposes of this Policy, “personal information” means information about an identifiable individual. This includes, for example:

• Title (Mr., Ms.)
• First Name, Middle Name (optional), Last Name
• email, phone number
• Account credentials
• Information relating to an individual’s role within a business (e.g., director, officer, guarantor)
• Age group

Business information that does not relate to an identifiable individual is not considered personal information under applicable PIPEDA and the Québec Private Sector Act. This includes, for example:

• Annual Revenue
• Number of employees
• Type of Business Entity (i.e. Partnership, Corporation)
• Trade Name
• Business Registration Number (Federal / Provincial)
• Member of an association
• Industry Type
• Business Category
• Provinces where your business operates
• Business Start date
• Accounting Software used
• Company website
• Company Bio
• Company Logo

All of the information that we collect is stored in our servers. We use the information we collect primarily to provide, maintain, protect, optimize and improve the Services, and to provide customer service related to the Services. We ensure that only those employees responsible for the Services’ operations have physical or technical access to your Contact Information and only where such access is required to perform work authorized by their supervisors.

Although we use the financial information collected by the Cubeler-Link™ about your business to match your business with the Prequalified loan offers criteria of the Platform Lenders, only aggregate period values for revenues and expenses, such as monthly and quarterly revenues and expenses, are shared with Platform Lenders. Most of the other financial information about your business collected by the Cubeler-Link™ is either combined and presented to Platform Lenders in the form of financial ratios or is presented to Platform Lenders as confirmation that your business has either reached or not reached certain thresholds included in the Platform Lenders’ qualifying criteria.

We also have marketing and data analytics partners who respectively sell advertising space on the website on our behalf and aggregate and analyze data for various statistical purposes. We use and share part of your Registered User Data with our marketing and data analytics partners to ensure that the ads you see on the website are ads that are relevant to you and to be included as part of statistical studies. We may provide our partners with statistical information that contain your Registered User Data, but only in aggregate terms and without providing any information that personally identifies you.

We may access, use, preserve, transfer and disclose part or all of your Registered User Data to certain third parties to satisfy any applicable law, regulation, subpoena, governmental request, or legal process if such action is required by law, and to enforce the Cubeler Business Development Platform’s General Terms and Conditions, including investigation of potential violations thereof. Furthermore, we may use IP addresses or other device identifiers to identify you in cooperation with third parties such as internet service providers, wireless service providers, and law enforcement agencies, including disclosing such information to the above-mentioned third parties, all in our discretion and without notice to you.

Any information you post, share or transmit on or using the User Communication Features will be deemed to be public information and may be reproduced, published, distributed, or otherwise used online or offline in any media or format (currently existing or hereafter developed) by us or by any other registered user of the Services. We do not control who will have access to the information you post, share, or transmit on or using the User Communication Features or where that information may ultimately end up. We, therefore, recommend that you think carefully before deciding what information you post, share or transmit on or using the User Communication Features, and we strongly advise you not to post, share or transmit sensitive personal or business information on or using the User Communication Features.

We will retain your Registered User Data only for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements, as required by law. When your Registered User Data is no longer required for these purposes, we will securely delete, destroy, or anonymize it in accordance with our data retention and destruction policies. You have the right to request access to, correction of, or deletion of your personal information, subject to legal and contractual restrictions.

We have extensive security measures in place to protect against the breach, loss, misuse, and alteration of the information stored in our databases. These measures include administrative access to website data, as well as other proprietary security measures which are applied to all repositories and transfers of Registered User Data.

We implement industry best practices appropriate to protect your Registered User Data. We use administrative, technical, and physical safeguards to protect your Contact Information against loss, theft, and unauthorized access, use, disclosure, copying, modification, disposal, or destruction in accordance with applicable legal requirements and industry best practices.

We implement encryption and security controls to protect against unauthorized access to Registered User Data during electronic transmission, and we train our employees to follow privacy and security practices specific to the Services. We also undertake security assessments, implemented robust intrusion prevention and intrusion detection systems, and run regular network vulnerability scans to ensure that we maintain strong security controls of our systems and networks.

In accordance with the Québec Private Sector Act, Cubeler has designated a person responsible for the protection of personal information, who may be contacted at support@cubeler.com. Your personal information may be stored or processed outside Québec or Canada; in such cases, Cubeler conducts privacy impact assessments and implements appropriate safeguards to ensure adequate protection. Cubeler may also use automated processing to match your business with financial products, and you have the right to request information about such decisions and to have them reviewed. In addition, subject to applicable legal limitations, you may request that Cubeler cease disseminating your personal information or de-index any hyperlink associated with your name.