Cubby Privacy Policy

Posted: April 15, 2024

Effective: April 15, 2024

Here we describe how Cubby NYC, Inc. (“Cubby”), a Delaware corporation, will collect, use, and handle your personal data when you use our websites, software, and services (“Services”).

What & Why

We collect and use the following information to provide, improve, protect, and promote our Services.

Account information. We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account, upgrade to a paid plan, and set up two-factor authentication (like your name, email address, phone number, payment info, and physical address).

Your Data. Our Services are designed as a simple and personalized way for you to store your files, documents, photos, comments, messages, and so on (“Your Data”), and collaborate with others. To make that possible, we store, process, and transmit Your Data as well as information related to it. This related information includes your profile information that makes it easier to collaborate and share Your Data with others, as well as things like the size of the file, the time it was uploaded, collaborators, and usage activity.

Contacts. You may choose to give us access to your contacts to make it easy for you, and your users, to do things like share and collaborate on Your Data, send messages, and invite others to use the Services. If you do, we’ll store those contacts on our servers.

Usage information. We collect information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, creating and moving files or folders, and sending and receiving electronic signature requests and other transactions). We use this information to provide, improve, and promote our Services, and protect Cubby users.

Device information. We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. For example, we use device information to detect abuse and identify and troubleshoot bugs.

Cookies and other technologies. We use technologies like cookies and pixel tags to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services. If our systems receive a DNT:1 signal from your browser, we’ll respond to that signal. We may also use third-party service providers that set cookies and similar technologies to promote Cubby services.

Bases for processing your data. We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.

With Whom

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

Others working for and with Cubby. Cubby uses certain trusted third parties (for example, providers of customer support and IT services) for the business purposes of helping us provide, improve, protect, and promote our Services. These third parties will access your information to perform tasks on our behalf, and we’ll remain responsible for their handling of your information per our instructions. For a list of trusted third parties that we use to process your personal data and more details on the categories of personal information that we’ve disclosed, please contact us via email at support@cubby.nyc.

Other users. Our Services are designed to help you collaborate with others. If you register your Cubby account with an email address on a domain owned by your employer or organization, or collaborate with other Cubby users, we may suggest you or your team as a potential collaborator to other users or teams. For example, if you interact with a person at a company, and that person frequently works with one of their coworkers, we may suggest you as a potential collaborator for that coworker. Collaborators and potential collaborators may see some of your basic information, like your name, profile picture, device, email address, and usage information. This helps you sync up with teams you can join and helps other users share files and folders with you.

Certain features let you make additional information available to others. For example, if you view a file or folder, we will share your identifying information such as name and email address, information on the device you used to view the content, and for how long you viewed content and what portion of the content you viewed with the owner of the file or folder.

Other applications. You can choose to connect your Cubby account with third-party services––for example, via APIs. By doing so, you’re enabling Cubby and those third parties to exchange information about you and data in your account so that Cubby and those third parties can provide, improve, protect, and promote their services. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.

Team Admins. If you are a user of a company account, your administrator may have the ability to access and control your account. Please refer to your organization’s internal policies if you have questions about this. If you aren’t a company account user but interact with a company account user (for example, by joining a shared folder or accessing stuff shared by that user), members of that organization may be able to view information about you (such as your name, email address, and profile picture) and your interaction with the company account user (such as your IP address). If you share Your Data with a company account user, the administrator of the team account may have the ability to access and edit what you share.

Law & Order and the Public Interest. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Cubby or our users; (d) protect Cubby’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.

Stewardship of your data is critical to us and a responsibility that we embrace. We believe that your data should receive the same legal protections regardless of whether it’s stored on our Services or on your home computer’s hard drive. We’ll abide by the following principles when receiving, scrutinizing, and responding to government requests (including national security requests) for your data:

• Be transparent
• Fight blanket requests
• Protect all users, and
• Provide trusted services.

How

Security. We have a team dedicated to keeping your information secure and testing for vulnerabilities. We continue to work on features to keep your information safe in addition to things like two-factor authentication, encryption of files at rest, and alerts when new devices and apps are linked to your account. We deploy automated technologies to detect abusive behavior and content that may harm our Services, you, or other users.

User Controls. You can access, amend, download, and delete your personal information by logging into your Cubby account and going to your account settings page.

Retention. When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account exists or as long as we need it to provide you the Services. If you delete your account, we’ll initiate deletion of this information after 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain this information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Use of Data from Google APIs. Cubby’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Where

Around the world. To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. Data may also be stored locally on the devices you use to access the Services.

Data Transfers. When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, Cubby relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, the Swiss-U.S. Data Privacy Framework, and the European Commission's adequacy decisions about certain countries, as applicable.

Data Privacy Frameworks. Cubby complies with the EU-U.S. and Swiss-U.S. Data Privacy Frameworks, as well as the UK Extension to the EU-U.S. Data Privacy Framework, as set forth by the U.S. Department of Commerce regarding the processing of personal data transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States. If there is any conflict between this Privacy Policy and the Data Privacy Framework Principles, the Principles shall govern. In accordance with the Principles, Cubby shall remain liable for onward transfers if a processor processes personal data in a manner inconsistent with the Principles. To learn more about the Data Privacy Framework, and to view our certification, visit https://www.dataprivacyframework.gov.

Cubby is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Data Privacy Framework compliance—free of charge to you. We ask that you first submit any such complaints directly to us via support@cubby.nyc. If you aren’t satisfied with our response, please contact JAMS at https://www.jamsadr.com/dpf-dispute-resolution. In the event your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration as set forth in Annex I of the Data Privacy Framework Principles.

Your Control and Access of Your Data

You have control over your personal data and how it's collected, used, and shared. For example, you can:

• Delete Your Data in your Cubby account.
• Change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account settings page.
• Access and take your data elsewhere. You can access your personal data from your Cubby account and you can download a copy of Your Data in a machine readable format. You can also ask us for a copy of personal data you provided to us or that we’ve collected, the business or commercial purpose for collecting it, the types of sources we got it from, and types of third parties we’ve shared it with.
• Object to the processing of your personal data. Depending on the processing activity, you can request that we stop or limit processing of your personal data.

If you would like to submit a data access request or object to the processing of your personal data, please email us at support@cubby.nyc. To request that your personal data be deleted, please contact us at support@cubby.nyc.

Cubby as controller or processor.  Cubby acts as your service provider.

Changes

If we’re involved in a reorganization, merger, acquisition, or sale of our assets, your data may be transferred as part of that deal. We’ll notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.

We may revise this Privacy Policy from time to time, and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Contact

Have questions or concerns about Cubby, our Services, and privacy? Contact our Data Protection Officer at support@cubby.nyc. If they can’t answer your question, you have the right to contact your local data protection supervisory authority.