Update Date: 12 Dec 2024

1. Objective

Cubo World Inc.(hereinafter referred to as “Cubo World”, “Company”,“we” or “us”) takes your privacy very seriously, and we are committed to protecting and respecting your privacy. That value powers all of the decisions we make, including how we collect, use, share, store and respect your Personal Data. Please read this Privacy Policy carefully so that you can make appropriate decisions on an informed and freely given basis.

PLEASE NOTE, IF YOU CONTINUE USING OR ACCESSING OUR SERVICES, YOU WILL BE DEEMED THAT YOU HAVE FULLY UNDERSTOOD AND ACCEPTED, AND IS WILLING TO COMPLY WITH ALL THE FOLLOWING CLAUSES, AND THIS TERMS SHALL BECOME EFFECTIVE BETWEEN YOU AND US. IF YOU DISAGREE WITH THIS TERMS IN WHOLE OR PART, YOU SHALL IMMEDIATELY STOP USING OUR SERVICES.

Our services are currently available to users in North America and the EEA and the United Kingdom. If you are not a user in these regions, you may not receive adequate protection from this Privacy Policy, so please be aware of the privacy laws and regulations in your region. Cubo World Inc. will not discriminate against any user in regions where we are not yet able to provide services.

Children's Privacy

The Service are restricted to users who are over the age of 18 or the equivalent age as specified by law in your jurisdiction (In certain cases this age may be higher due to local regulatory requirements, please see your local privacy policy for more information). We do not knowingly collect any information about or market to children, minors, or anyone under the age of 18 or the equivalent age as specified by law in your jurisdiction. If you are less than 18 years old or the equivalent age as specified by law in your jurisdiction, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 or the equivalent age as specified by law in your jurisdiction has registered with us and provided us with personal information, we will take steps to terminate that person’s registration.

Your personal data, which you provided/will provide to our Company and/or obtained by our Company by any external means, may be processed by our Company as “Data Controller”;

● In the context of the objective of processing your personal data and in connection with this purpose, in a limited and measured manner,

● By maintaining the accuracy and up-to-date version of the personal data as reported or notified to our Company,

● May be recorded, stored, preserved, reorganized and be transferred to the institutions authorized to request such personal data by law and shall be transferred, classified and shared with third parties within the country or abroad under the conditions stipulated by legislation and upon your explicit consent if necessary, and they may be

processed by other means listed under the legislation and be subject to other procedures set forth in the legislation.

This Privacy Policy describes which data we collect, how we intend to use, store, protect and share the data we collect, how you can withdraw your consent for the processing of these data and how you can correct and revise the data.

Capitalized terms in this Policy shall have the meanings specified in the Terms and Conditions unless defined separately in this Policy.

2. How to collection of Personal Data

Cubo World may process your personal data for the purposes specified in this Privacy Policy.

The personal data of users collected and used by Cubo World in particular, are as follows: your order information if you make a purchase throughOfficial website purchase, and identifier for advertisers designated in your device used in accessing our services (The Identifier for Advertisers-IDFA), identifier for vendors/developers designated your device (The Identifier for Vendors-IDVF) and Internet Protocol Address-IP Address.

Data Categories and Data Types

Process Security

Internet traffic data (network movements, IP address, visit data, time and date information), device name, Token ID (when you allow notifications through your device), identifier for advertisers designated in your device used in accessing our services (if you give a permission, the Identifier for Advertisers-IDFA), identifier for

vendors/developers designated your device (The Identifier for Vendors-IDVF)

Customer Transaction

Order information

Marketing Data

IDFA, IDVF

We may collect your abovementioned data directly from you through electronic or physical mediums, your mobile device, Official Website ,third party Official website or third party sources which you can access our products, for the purposes of compliance with legal obligations, enhancing  our services, administering  your use of our services, as well as enabling you to enjoy and easily navigate our services.

We may collect your log data generated while you are using our services (through our products or third party products). This log data may include information such as your device’s Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service, the time/date of your use of the service, and other statistics.

General Principles Regarding Personal Data Processing

In accordance with this Privacy Policy, personal data are processed by Cubo World as a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

3. Purposes of Processing Personal Data and Legal Reasons

We will use the Personal Data we collect about you in accordance with the laws . The establishment of a contract or direct relation to the execution or performance of the contract and for the legitimate interests of Cubo World provided that your fundamental rights and freedoms are protected.

Because Cubo World Inc. is based in the United States, information collected in other countries/regions is usually transmitted to the United States for processing. Cubo World Inc. participates in the EU-US Privacy Shield frameworks II and Swiss-US Privacy Shield frameworks ( as to Frameworks ) regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom and Switzerland.

In the event of any conflict between this Privacy Policy and the Frameworks, the terms of the Frameworks shall govern.

a) Purposes of Processing Personal Data

In accordance with this text, your personal data is processed for the following purposes in accordance with the above general conditions:

Process Security

● execution of activities in compliance with legislation

● execution of company/product/service commitment operations

● execution of communication activities

● execution/auditing of business activities

● conducting after-sales support services for goods/services

● execution of goods/services sales processes

● conducting storage and archive activities

● execution of agreement processes

● execution of information security processes

● conducting audit/ethical activities

● execution/audit of business activities

● conducting activities to ensure business continuity

● providing information to authorized persons, institutions and organizations

Customer Transaction

● execution/auditing of business activities

● conducting after-sales support services for goods/services

● execution of goods/services sales processes

● conducting activities for customer satisfaction

● execution of agreement processes

Marketing Data

● conducting marketing analysis studies

● execution of advertising/campaign/promotion processes

Besides, the purposes of processing personal data may be updated in line with our obligations arising from our company policies and legislation; in particular,

● Creating user accounts for the service recipients,

● Customizing our Services, understanding our users and their preferences to enhance user experience and enjoyment using our Services and improve our users’

experience,

● Informing about new products, services and delivering you information regarding advertisements and promotions,

● Carrying out a digital subscription and purchase processes of service recipients,

● Carrying out the auto-renewable subscriptions for giving users access to content, services, or premium features in our service,

● Carrying out the processes of information security,

● Conducting activities in accordance with legislation,

● Fulfilling the demands of competent authorities,

● Conducting the processes of finance and accounting transactions,

● Conducting communication activities,

● Conducting the processes of contracts,

● Carrying out strategic planning activities,

● Following up requests and complaints.

b) Legal Reasons

Customer Transaction

● It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract

● We have to process data in order to establish a right for you, to exercise and protece this right you, to exercise and protect this right

Process Security

● The law explicitly stipulates the process by which we process your personal data

● Conditions that are necessary in order to fulfill our legal obligation

● It is necessary to process your personal data, provided that we establish a contractual relationship with you, or that it is directly related to our performance obligation arising from this contract

Marketing Data

● Your explicit consent (acquired via Apple and/or Google)

Third Party Websites

Copyowl.ai may contain links to other websites that are unknown to Cubo World andwhose content is not controlled. These linked websites may contain terms and conditionsother than Cubo World texts. Cubo World cannot be held responsible for the use or disclosure ofinformation that these websites may process. Likewise, Cubo World shall not have anyresponsibility for any links from other sites provided to Copyowl.ai owned by Cubo World.

We collect information by fair and lawful means, with your knowledge and consent. We alsolet you know why we’re collecting it and how it will be used. You are free to refuse ourrequest for this information, with the understanding that we may be unable to provide youwith some of your desired services without it.

Cookies

Cookies are little text files that are stored on the browser or hard drive of your computer ormobile device when you visit a webpage.  Cookies allow a website to run moreefficiently in addition to ensuring the presentation of personalized web pages in order tomake you live a faster visit experience which is more fit for your specific personal needs anddemands. Containing only data on your website visit history via the internet, cookies do notcollect any information, including your personal data/files stored on your computer or mobiledevice. We may use cookies when it is necessary for operating our services, to enhance ourservice performance and functionality, and to deliver content, including ads relevant to yourinterests, on our sites, or third-party sites. You can delete cookies which are already presenton your computer and prevent the recording/location of cookies on your internet explorer.

Internet browsers are predefined to automatically accept the cookies as default. As themanagement of cookies varies from browser to browser, you may look at the help menu ofthe browser to get detailed information.

Accessibility

By agreeing to this privacy policy, you authorize the use of the Accessibility (assistive) function for the PC AI Copilot feature. Please note that if you do not grant this authorization, you will not be able to access the AI Copilot feature on the PC.

How and Where we store your personal information 

Your data will be stored for the duration specified in the applicable legislation or for a reasonable time until the purpose of processing cease to exist, or during legal periods of limitation.

The personal information we collect from you may be stored on a server located in USA（“storage area”）, outside of the country where you live maybe.

If your location is not within the above range, your data may be transferred to our storage area through cross-border transmission. You need to be aware and agree that this cross-border transmission is allowed in accordance with the corresponding laws or policies of your region, and your consent has been obtained.  For example, if you are a user of an EU member state, you understand and are aware that this Cubo World will store your data in the United States, Cubo World will provide you with services based on the EU US Privacy Shield 2.0.

In cases that you allow Cubo World to store your personal data for additional time by giving your consent, such data shall be immediately deleted, destructed or anonymized upon the expiry of such additional time or once the purpose of processing no longer exists.

Technical and Administrative Measures

Cubo World stores the personal data it processes in accordance with relevant legislation for periods stipulated in relevant legislation or required for the purpose of processing. Cubo World undertakes to take all necessary technical and administrative measures and to take the due care to ensure the confidentiality, integrity and security of personal data. In this context, it takes the necessary measures to prevent unlawful processing of personal data, unauthorized access to data, unlawful disclosure, modification or destruction of data. Accordingly, Cubo World takes the following technical and administrative measures regarding the personal data it processes:

● Anti-virus application. On all computers and servers in Cubo World's information technology infrastructure, a periodically updated anti-virus application is installed.

● Firewall. The data center and disaster recovery centers hosting Cubo World servers are protected by periodically updated software-loaded firewalls; the relevant next generation firewalls control the internet connections of all staff and provide protection against viruses and similar threats during this control.

SSL-VPN defined on Firewalls. A separate SSL-VPN identification has been made for each supplier; with the identification made, the supplier only provides access to the systems that it should use or is authorized to use.

● User identifications. Cubo World employees' authorization to Cubo World systems is limited only to the extent necessary by job descriptions; in case of any change of authority or duty, systemic authorizations are also updated.

● Information security threat and event management. Events that occur on Cubo World servers and firewalls, are transferred to the “Information Security Threat and Event Management” system. This system alerts the responsible staff when a security threat occurs and allows them to respond immediately to the threat.

● Encryption. Sensitive data is stored with cryptographic methods and if required, transferred through environments encrypted with cryptographic methods and cryptographic keys are stored in secure and various environments.

● Logging. All transaction records regarding sensitive data are securely logged.

● Two-factor authentication. Remote access to sensitive data is allowed through at least two-factor authentication.

● Penetration test. Periodically, penetration tests are performed on servers in the Cubo World system. The security gaps created as a result of this test are closed and a verification test is performed to show that the relevant security gaps have been closed. Besides, Information Security Threat and Event Management System automatically performs penetration tests. Test results are recorded.

● Information Security Management System (ISMS). At the ISMS meetings made within Cubo World, the topics contained in the control forum are audited monthly by the director of information technology and the director of financial operations.

● Training. In order to increase the awareness of Cubo World employees against various information security violations and to minimize the impact of the human factor in information violation incidents, trainings are provided to employees at regular intervals.

● Physical data security. It ensures that personal data on papers is necessarily stored in lockers and accessed only by authorized persons. Adequate security measures (for situations such as electric leakage, fire, deluge, thievery etc.) are taken based on the nature of the environment where sensitive data is stored.

● Backup. Cubo World periodically backs up the data it stores. As a backup mechanism, it uses the backup facilities provided by the cloud infrastructure providers, as well as the backup solutions it develops when deemed necessary, provided that it is in compliance with relevant legislation and provisions of this Policy.

● Non-disclosure agreement. Non-disclosure agreements are concluded with employees taking part in sensitive personal data processing.

● Transfer of sensitive personal data. If transfer of sensitive personal data is required through email; such transfer is done through (i) encrypted  corporate email or (ii) Registered E-mail.

In the event that the personal data is damaged as a result of attacks on Copyowl.ai or on the Cubo World system, despite Cubo World taking the necessary information security measures, or the personal data is obtained by unauthorized third parties, Cubo World notifies this situation to Users immediately and, if necessary, to relevant data protection authority and takes necessary measures.

Cubo World may also transfer your personal data to services providers of our Company, third parties such as Stripe etc.

      ● Stripe. Stripe is a platform that allows individuals and businesses to accept and manage online payments.

For more information about how Stripe collect and use your Personal Data, please refer to its privacy policies by the following link:

https://stripe.com/privacy

4. Your Rights as the Data Subject

You may request the following regarding your personal data by applying to Cubo World:

● Learn whether or not your personal data have been processed;

● Demand for information as to if your personal data have been processed;

● Learn the purpose of the processing of personal data and whether data are used in accordance with their purpose;

● In case the personal data is processed incompletely or inaccurately; requesting notification of the transactions made under this scope to third parties to whom personal data have been transferred;

● Request deletion, destruction or anonymization of personal data if the reasons for the processing have disappeared and request notification of the transactions made under this scope to third parties to whom personal data have been transferred;

● Object to occurrence of any result that is to your detriment by means of the analysis of personal data exclusively through automated systems;

Where General Data Protection Regulation (GDPR) is applicable, data subjects have the following rights:

● Right of access - Learning whether personal data is being processed and, if so, accessing your personal data and the information regarding the processing of your personal data,

● Right to correction -To request the correction of information that you believe is inaccurate or the completion of information that you believe is incomplete by Cubo World,

● Right to delete – To request deletion of personal data under the conditions stipulated in GDPR,

● The right to restrict processing - To request the restriction of the processing of personal data under the conditions stipulated in the GDPR,

● Right to object to processing - To object to the processing of personal data under the conditions stipulated in the GDPR,

● Right to data portability - To request the data collected by Cubo World to be transferred directly to another organization or under certain conditions,

● Objection to the occurrence of a result against the person himself/herself, by analyzing the processed data exclusively through automatic systems, including profiling.

If you are using the Service in California, the following additional terms apply. If any conflict arises between the main Privacy Policy, the following terms shall prevail: 

California Consumer Privacy Act. For Users who are California residents, you have the following extra rights under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used, and shared your personal information over the past 12 months.

2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

3. We did not sell personal information and therefore did not process requests for opt-out of sale.

California “Shine The Light” Law. For users located in California, we do not share your personal information with third parties for those third parties’ direct marketing purposes. 

In addition, under California law, operators of online Service are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online Service, to the extent the operator engages in that collection. At this time, we do not track our users’ personal information over time and across third-party online Service. This law also requires operators of online Service to disclose whether third parties may collect personal information about their users’ online activities over time and across different online Service when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual user’s online activities over time and across different online Service.

In the Official website that includes your explanations about the right you have as the data subject and exercise your rights stated above and that you request to exercise; your request must be explicit and understandable, if the subject of your request is related to you or if you are acting on behalf of someone else, you must be specially authorized in this regard and your authority must be documented, the Official websitemust contain identity and address information and documents proving your identity must be attached to the Official website. Our Company will enable you to file such requests through the “Data Subject Official website Form” at [email protected]. 

If you believe that we or someone with whom we have transferred your data is violating your rights, you can file a complaint to the data protection authority in your country and to other competent supervisory authorities.

Changes To This Privacy Policy

We reserve the right to update or modify this Policy from time to time to reflect the changes in our business, technology and applicable law and practice. In case of any modification of this Policy, we will notify you of the latest Policy here, or by posting it on our official website or sending you separate notifications. Please pay attention to this website and the notifications we send to you for the latest updates of this Privacy Policy. Although this Privacy Policy may be modified, your rights under this Policy will not be diminished without your explicit consent.

We will ask for your explicit consent again in accordance with applicable laws before we collect additional personal information from you or when we use or disclose your personal information for new purposes. Your continued use of the Service on websiteconstitutes your agreement to the updated Privacy Policy.

Company Title: Cubo World Inc.    

Address: 16192 Coastal Highway, Lewes, DE 19958  

E-mail:  [email protected]

Tel: 9175421724