This is the privacy policy of Cubby BV, hereinafter also referred to as “Cubby”, “we”, or “us”. Cubby is committed to protecting your personal data in accordance with the General Data Protection Regulation, hereinafter referred to as the “GDPR”. We recommend that you read this privacy policy carefully whenever you interact with Cubby through scanning a QR code, our website, or any other means.Our privacy policy forms an integral whole with our general terms and conditions.
This privacy policy describes which personal data Cubby processes and how such processing takes place. In addition, this policy explains the safeguards that apply when we process your personal data.
This privacy policy may be amended unilaterally as a result of software updates, an expansion of our activities, or changes to our legal, administrative, or contractual obligations.Regulation, hereinafter referred to as the “GDPR”.
Cubby BV is responsible for the processing of your personal data. Our company registration number is 1017.176.246 and our registered office is located at Kerkstraat 108, 9050 Ghent, Belgium.
You can contact us through our website (cubby.be) or via email (arne@clubcubby.be).
Cubby collects personal data when you interact with a smart locker. After scanning the QR code, you enter your name, email address, and phone number yourself. In addition, Cubby stores all transaction-related data, including the location of the locker, the time the locker is opened, and the time it is closed again.
Users may also be asked to take a photo before and after using an item. In addition, you have the option to verify yourself through Google.
You can contact us through our website or by email using a contact form. We process all information entered into this form. In addition, data such as your (first) name, email address, and possibly your organization are processed.
As an “ambassador” within our system, we process your email address, name, and any information you provide during our contact with you. Ambassadors are individuals selected by us who supervise and replace damaged toys for a specific locker in their neighborhood. They also act as the contact person for that locker.
We use Stripe and MultiSafepay as payment service providers for locker usage. The latter processes the transaction data. We only receive confirmation of payment.
In accordance with the GDPR, we only process accurate and necessary data.
For every processing activity, we rely on a legal basis. These include:
The data collected through photos are used to monitor the correct use of lockers and materials.
The data collected through photos and the request for your name and phone number are used to establish misuse, damage, loss, or vandalism.
The collection of email addresses and phone numbers aims to allow us to contact users regarding usage or follow-up.
The content of your correspondence with us, as well as the name of your organization, are used by Cubby to facilitate communication and answer any questions you may have.
The email addresses of users and members are processed by Cubby for the operational and technical management of the UrbanCubby system. Processing this data is necessary for the functioning of our system.
Where consent is the legal basis for processing, such consent is always freely given and may be withdrawn by the data subject at any time.
Cubby is selective regarding the parties with whom it shares your personal data and carefully chooses such parties. In all cases, we strive to ensure adequate safeguards for the protection and confidentiality of your data.
Cubby may disclose personal data to third-party service providers and other parties that perform certain (processing) services on our behalf, such as:
Certain data may be stored or transferred outside the European Economic Area (EEA) for the purposes described above. Such transfers may occur through service providers located outside the EEA, through storage on servers outside the EEA, or because data is accessible from outside the EEA.
In this context, UrbanCubby undertakes to ensure an appropriate and adequate level of protection for your data by implementing suitable safeguards as provided for in Chapter V of the GDPR.
Cubby takes reasonable security measures to protect your personal data against destruction, loss, alteration, or any other unauthorized processing.
To safeguard our legitimate interest in adequately securing our business assets, all incoming and outgoing emails are monitored, particularly for the detection of spam, viruses, and ransomware.
Cubby does not retain your personal data longer than necessary for the purposes described in this privacy policy. Longer retention periods may apply if required by law, contractual obligations, or in the event of a dispute.
For example, we apply the following retention period:
You have several rights regarding the processing of your personal data. You have the right:
If you wish to exercise your rights, you may submit a request by contacting us via email at arne@clubcubby.be. Cubby will respond to your request within one month from the submission thereof.
Our services are not intended for children below the minimum age for digital consent, which in Belgium is 13 years old.
No person under this minimum age may provide information to or through the services, in accordance with national legislation and/or the GDPR.
We do not knowingly collect personal data from children under the minimum age. If we become aware that we have collected or received personal data from a child below the legal minimum age for digital consent, we will delete the account and erase the associated
personal data.
We reserve the right to modify the contents of this privacy policy at any time. The most recent version is always available on our website, which we recommend consulting regularly.
For questions or complaints, you can contact us through our website (cubby.be) or via email at arne@clubcubby.be