Policies
Mobile App Privacy Notice
Effective Date: 01.01.2019 / Updated on: 09.06.2023
Your personal information
The protection of your personal information is important to us at Kubu Smart Ltd. We respect your privacy and want you to understand what we do with the information we hold about you. This privacy policy explains how we collect, protect, share and use your personal information.
This App is not intended for children and we do not knowingly collect data relating to children.
Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
Important information and who we are
Kubu Smart Ltd is the controller and is responsible for your personal data (collectively referred to as “Company“, “we“, “us” or “our” in this Policy).
We have appointed a data privacy manager. If you have any questions about this Policy, please contact us using the details set out below:
Contact email address: support@getkubu.com
Contact telephone number: 0330 555 9545
You have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Personal information we collect
We may collect the following types of personal information from you when you use Kubu® services or products. Our products and service are as follows:
App | User Submitted | Information Gathered |
---|---|---|
Kubu Smart | Phone no, email, password, product ID, user verification information | Device ID, IP address, images, activity logs, location |
Information we collect:
- Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account or order.
- Kubu account details: when you download and use the Kubu app, you will be asked to register with us and create an account. Your account details include your user name, password and your contact details, such as your name, address and email address.
- Transaction information: records of the products and services you purchase from us.
- Payment information: credit/debit card details and bank account details you provide to make payment for the products and services you purchase from us.
- Delivery information: information relating to the delivery of our products to you.
- Installation and service history: records relating to the installation of our products at your home or property and information relating to the servicing of that product.
- Door and Window system information: Information that allows us to provide you with detailed personalised installation instructions.
- Device information: information about the smartphones, mobiles, computers or other electronic devices you connect to our products, website or Kubu app, such as details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products and services. It can also include details of your internet service provider, mobile network and your IP address.
- Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
- Records of your discussions with our customer support teams: when you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails, phone our customer service team or contact us through social media such as through Twitter or our Facebook page. We may also monitor and record our phone calls with you to make sure we are living up to the standards we want, as well as relevant laws and regulations.
- How you use Kubu products: we will collect information about how you are using Kubu products and services in your home and their performance, what devices are connected to them and how those devices are being used with the Kubu products. For example, this includes information that Kubu devices you connect to your Kubu account collect about door and window status, the alarm setting you have put on those windows and doors and the status during the geofence proximity feature.
- How you use the Kubu app and our website: when you use the Kubu app or our website we collect information about the pages you look at and how you use them.
- Location information: we will collect information about your exact location when you choose to share that with us. For example, you may set up your Kubu app to notify you when you home is unsecure when you leave, to do this you will need to share the location of your mobile device with us.
You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services or the functionality of our products may be reduced.
Purposes for which we will use your personal data
Purpose / Activity | Type of data | Lawful basis |
---|---|---|
To install the App and register you as a new App user. To manage our relationship with you including notifying you of changes to the App. | Identity and contact information | Your consent for downloading the app. We are performing our obligations under the agreement we have with you to provide the services you have requested. We are unable to provide the services without processing your personal data. |
Answer queries and issues you may have and maintain and improve our products and services. | Personal information we collect | Using your personal data in this way is necessary for us to provide you with the service, so we can perform our obligations to provide a service you have requested. If we are prohibited from processing your information we will be unable to manage your account and our service may be terminated. |
Troubleshooting, data analysis and system testing | Personal information we collect | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) |
To send you communications about relevant products or services which may be of interest | Personal information we collect | For existing customers it is in our legitimate interest to provide you with information about products or services that may be relevant. For new customers we will only send information about products or services that may be relevant and adapted for you when you have elected to receive such information. I.e. Opted In. |
To comply with legal requirements which are subject to tac, accounting reporting, mandatory disclosures and law enforcements. | Personal information we collect | Using your personal information in this way is necessary for us to comply with our legal obligations. |
Sources we collect your personal information from
We will collect personal information from a number of sources. These include the following:
- Directly from you: for example, when you create your Kubu account with us, purchase products and services from us, complete forms we provide to you, enter our competitions and promotions, contact us by phone, email or communicate with us directly in some other way.
- Our website, app and Kubu products: provide us with information about how you use them and the devices in your home that you connect to them.
- Other companies we work with: provide us with information to help us deliver our products and services to you, and to understand you better.
- Installers and service engineers: who will provide us with information about the installation and maintenance of Kubu products in your home.
- Other companies’ apps and products: provide us with information when you connect them to Kubu products and approve their sharing of personal data with us. For example, when you connect to the IFTTT app, Google Home or Amazon Alexa, we will receive your information about how you use those apps with our Kubu products.
Who we share your personal information with
We share personal information with the following parties:
- Other companies’ apps and products: for the purpose of providing our apps, products & services.
- Installers and service engineers: so that they can book appointments with you and provide installation and product maintenance services.
- Delivery companies: to deliver products that you have ordered from us.
- Other service providers and advisors: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal or financial advice and generally help us deliver our services to you.
- Market research: occasionally we may ask our market research partners to contact our customers to help us find out how to improve our products and services.
- Third Party Partners: In some cases, you may have acquired a Kubu product through a third party partner, who may have bundled those products with its own features, such as applications or service offerings. Such associated features may require all or part of your personal data to provide you with all or part of their functionalities. With registration to the Kubu account for such products, you automatically opt-in and allow us to share your personal data with such third parties. This sharing of personal data will be provided with the possibility to opt-out anytime on simple request. In case of opt-out, you expressly acknowledge and agree to waive any claim against Kubu with respect to the disrupted operation of the third party’s associated features. In addition, you must be aware than once the sharing of information took place, the third party will be solely liable towards you for its own use of your personal data, either before or after you opt-out.
- The Government or regulators: where we are required to do so by law or to assist with their investigations.
- Police and law enforcement: to assist with the investigation and prevention of crime.
- Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
We do not disclose personal information to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.
Under no circumstances will we disclose data to third parties not specified here for advertising purposes.
Transferring personal information internationally
The personal information we collect may be transferred to and stored in countries outside of the UK and European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy policy and applicable European data protection laws and is respected and kept secure.
Privacy policies of other websites:
When you use the “Smart Integrations” feature in the App, you may be linked to third-party services and websites that you choose. Also, when using the App, you may use features that link you to social media websites, such as Facebook or Twitter. We are not responsible for the privacy practices or content of any of these third parties or the linked sites. Linked sites may collect personal data from you that is not subject to our control. We encourage you to review the privacy policies on any linked website you visit.
We take measures to protect all personal data transferred to a third party, or to other countries, in accordance with applicable data protection laws. A list of countries and recipient entities can be provided upon request, see Contact Us below.
How long will we store your personal information
We store personal data for as long as necessary to fulfil the purpose for which the data has been collected. This will also be in accordance with our internal record retention schedule. After you close your account with us we will keep your personal information for a reasonable period to maintain our records and legal obligations to you. Sensitive personal information such as location information is automatically deleted after 2 weeks even when your account is active.
Your have the right to:
- Request a copy of your personal data from our records;
- Ask that we correct or erase your personal data
- Ask us to stop processing personal data
- Withdraw your consent to us processing your personal data at any time
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
- Request to access your personal data https://gdpr-info.eu/issues/right-of-access/
- Request to correction of your personal data https://gdpr-info.eu/issues/personal-data/
- Request to erasure of your personal data https://gdpr-info.eu/issues/right-to-be-forgotten/
- Object to processing your personal data https://gdpr-info.eu/issues/processing/
If you wish to exercise any of these rights, please contact us at support@getkubu.com
Changes to this Policy and our duty to inform you of changes
We keep this Policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App.
We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.