CubiCasa Ltd (referred to as “CubiCasa”, “we, or “our”) is committed to protect personal data we process. This privacy notice explains why we collect personal data and what we do with it when we are the controller of personal data. Within the CubiCasa and its entities, the data controller will be CubiCasa Ltd and/or the CubiCasa entities you have your relationship with.
We process individuals personal data for a number of reasons. When we write “you”, we mean you as, for example, our customer, a potential customer, our customer’s employee or other relevant parties, authorised representatives, corporate cardholders and associated parties.
By personal data we mean data defined under general data protection regulation (“GDPR”). According to GDPR, personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the economic or social identity of that natural person. Therefore, a definition of personal data is very wide – by personal data we don’t mean only direct identifiers such as name. We mean indirect identifiers such as online identifiers as well.
We may amend this privacy notice from time to time. If we make any changes we will post them on our websites, so that you will always be aware of the way we use your personal information.
1. What information do we collect?
Personal data is in most cases collected directly from you or generated as part of the use of our services and products. Sometimes additional information is required to keep information up to date or to verify information we collect. The categories of personal data processed depends on your relationship to us.
Personal data we may collect can be grouped into the following categories:
- Identification information, such as name
- Contact information: such as phone numbers and addresses, including postal address
- Financial information: such as type of agreement, transactional data, credit history, insurance history
- Information analyzed from visual material you provide to us, such as visual material of apartments
- Special Categories of Personal Data: such as location information
- Demographic data, such as observed data from the service use.
- Preferences and interest information provided by the user, such as observed data from the service use
- Permissions and consents, such as consent for processing of location information
- Information provided to surveys and research
- Any other information collected with the user’s consent
I) Information you provide to us
We collect information you provide directly to us. For example, when becoming a new customer, we collect personal data such as name, email address and phone number. We also collect information which you provide us with such as visual material, messages you have sent us, e.g. feedback or a request in our digital channels.
II) Information collected through observing the visual material you provide
We collect information from the target space which is scanned with the application Information can include geometry, appliance or other descriptive data from the scanned target space. For example, CubiCasa can extract basic indoor geometry from the visual material provided and have information on what appliances are in the target indoor space.
III) Information collected through observing the use of our service
We collect information about how you use our services, such as the types of content you view or engage with or the frequency and duration of your activities. We collect information from or about the computers, phones, or other devices, depending on the permissions you’ve granted. Permission can be granted by, for example, adjusting settings of your device.
We analyse data using tools such as Google Analytics. For more information on Google Analytics, please visit http://www.google.com/analytics/. you can prevent Google Analytics from collecting data by downloading and browser add-on at: https://tools.google.com/dlpage/gaoptout.
IV) Personal data we may collect from third parties
We may collect personal data from publicly available and other external sources, such as register held by governmental agencies and third party sources, such as social media platforms, third party data providers and our joint marketing partners.
We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
2. Purposes and lawfulness for the processing of your personal data
In these cases processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of prior to entering into a contract;
- To register you for our services, for example when you become a customer of CubiCasa
- To enable you to use our services, for example when you use app provided by us
In these cases processing is necessary for the purposes of the legitimate interests pursued by us or a third party or you have given us a consent for the processing;
- For communicating purposes; such as our newsletter.
- Analysing and developing service contents; For example processing information collected through observing the use of our service and the visual material you provide. In addition, we process personal data based on legitimate interest to enable you to take part in surveys and polls if you wish to. We conduct surveys and polls, test features in development, and analyze the information we have to evaluate and improve products and services, develop new products or features, and conduct audits and troubleshooting activities.
- Advertising and marketing purposes, we may advertise and market our services or the services of selected third parties to you. We may enhance or improve your experience of our website by collecting details of your visit to our websites using cookies and standard weblogs too.
You may give us a consent by, for example, adjusting settings of your device.
3. How long do we retain your information?
The storage period depends on the nature of the information and the purposes of processing. The maximum period may therefore vary per use.
CubiCasa retains personal data we collect from you where we have an ongoing legitimate business need to do so. Once you have ended your relationship with us, we will delete your account data, unless statutory retention requirements apply (such as for taxation purposes).
4. How is this personal data we collect shared?
By sharing personal data we mean situations where some service is processing personal data on behalf of us or we are disclosing personal data to some other entity. We may share your personal data on the following situations:
4.1 Service providers
We work with third party companies who help us to provide and improve our Service. We may share personal data with third parties in order to provide you Service, such as a payment service, for the purposes defined in this privacy notice. You may contact us to get a concise and updated list of third party services we are using.
In addition, our application can be downloaded through the online stores of mobile device providers such as the Apple App Store. The privacy policies of Apple apply in addition to this Privacy Notice. Users should familiarise themselves with the terms and privacy policies provided by device platforms.
4.2 Third-party Advertising and Marketing
We may work with third-parties for advertising and marketing purposes. We will never share any of the direct identifiers of you for advertising and marketing purposes.
However, under the very wide definition of personal data some of our deliverables fall under “personal data”, for example a floorplan with its real world address. In addition to providing a floorplan to You we may share floorplans we have for various use cases, for example to home insurance company or a re-financing services provider. Some other use cases for Deliverables that may be shared can be Home Report or the CubiCasa BIM. These floorplans still are not directly to you in any way, we will remove all direct identifiers.
At your consent, we may share your information with other selected third parties so they may contact you. We will also display certain details about you as a customer of Cubicasa.
4.3 For research purposes
In some cases, we may disclose data for scientific or other research purposes in compliance with the legislation on personal data protection.
4.4 For legal reasons
CubiCasa may disclose your personal data to third parties where access to or processing personal data is necessary to i) satisfy any applicable law and/or court order; (ii) detect, prevent, or otherwise address fraud, security or technical issues. CubiCasa will inform those concerned of this type of use of personal data when possible.
4.5 For other legitimate reasons
If CubiCasa is involved in a merger, acquisition or asset sale, we may transfer your personal data to the third party involved. However, we will continue to ensure the confidentiality of all personal data. We will give notice to all customers concerned before the personal data are transferred or become subject to a different privacy notice.
5. Transfer of personal information outside the European Economic Area (“EEA”)
In some cases, our services may also be carried out by operators and on servers located in third countries. In such cases, your personal data may also be transferred outside the EU or EEA in accordance with applicable legislation. In regards to transfers of personal data to countries where local data protection legislation does not provide an adequate level of data protection, transfers are protected utilizing appropriate safeguards, such as standard contractual clauses approved by the European Commission or a competent supervisory authority, or binding corporate rules. To learn more about the appropriate safeguards we use, please contact us by using the contact information provided below.
Our service requires you to be at least 16-years old or to have consent of guardian for the use of our services.
7. Your rights
The General Data Protection Regulation grants the data subject a number of rights with which the data subject can govern the processing of their personal data. The data subject may use the following rights in relation to us insofar as we act as the controller for the data subject’s personal data:
Right of access and right to rectification
you have the right to receive confirmation on whether we process personal data relating to you and the right to access any such personal data. We may ask you to specify your request where necessary, for example with regard to activities to which the request relates.
In addition, you have the right to request the rectification of incorrect personal data relating to you, or to supplement incomplete personal data that CubiCasa is processing.
Right to data erasure
you have the right to request erasure of your personal data from our data systems. CubiCasa will comply with your request, provided we do not have a legitimate reason not to delete the data, such as a statutory obligation to continue processing the personal data. Personal data may not be deleted instantly from backup copies and other such data systems, but will be deleted through regular database retention practices.
Right to object
you also have the right to object to the processing of your personal data if your personal data is processed for other purposes than the fulfilment of legal responsibilities or the provision of services. you may object to the processing of your personal data for purposes of direct marketing. Objecting to the processing of your personal data may lead to limitation of the usage of CubiCasa services
Right to restriction of processing
If you contest the correctness of the data which we have registered about you or lawfulness of processing, or if you have objected to the processing of the data in accordance with your right to object, you may request Us to restrict the processing of these data to only storage. The processing will only be restricted to storage, until the correctness of the data can be established, or it can be checked whether our legitimate interests override your interests.
If you are not entitled to erasure of the data which we have registered about you, you may instead request that we restrict the processing of these data to only storage. If the processing of the data which we have registered about you is solely necessary to assert a legal claim, you may also demand that other processing of these data be restricted to storage. We may process your data for other purposes if this is necessary to assert a legal claim or if you have granted your consent to this.
Right to data portability
you have the right to receive your personal data from us in a structured, commonly used format so that you may transfer your personal data to another controller, provided that the processing of your personal data is based on consent or a contract between you and CubiCasa.
8. Who is the controller and who can I contact?
You can use your rights by contacting us. The extent of your rights is subject to the legal basis for processing and exercising your rights requires identification.
Contact information: firstname.lastname@example.org
Right to lodge a complaint
If the processing of your personal data is in breach of applicable legislation, you have the right to lodge a complaint with the national supervisory authority. you can lodge the complaint with a competent supervisory authority. In Finland, this is the Data Protection Ombudsman, and the complaint must be lodged in accordance with instructions provided by the Office of the Data Protection Ombudsman. Please see http://www.tietosuoja.fi for more information.