Privacy Policy

Privacy Policy of www.cubeo.ai 

This Website collects some Personal Data from its Users.

Owner and Data Controller

CUBEO INNOVATION SRL, CIF: 44390444, J40/9826/2021
Address: Drumul Gura Calitei, District 3, Postal code: 032604, Bucharest, Romania
Owner contact email: contact@cubeo.ai

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; phone number; first name; last name; gender; date of birth; company name; profession; address; fax number; country; province; email address; city; field of activity; number of employees; geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
• User account data is stored as long as the user decides to maintain their account active.
• Conversations histories with AI Assistants are kept for a maximum of 90 days.
• Log data for troubleshooting and security purposes is retained for up to 30 days.
• Billing and transaction information is retained for the period required by applicable tax and accounting laws (typically 7 years).

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Contacting the User, Handling payments, Displaying content from external platforms, Managing contacts and sending messages, Managing landing and invitation pages, Location-based interactions, Platform services and hosting, Remarketing and behavioral targeting, Tag Management, User database management and Content commenting.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Information Security and ISO 27001 Certification

The Owner has implemented an Information Security Management System (ISMS) in accordance with ISO 27001:2022 standards and has obtained certification. This certification demonstrates our commitment to protecting your data through: 

• Comprehensive information security risk management
• Encryption of data in transit using HTTPS
• Encryption of data at rest in our storage systems
• Controlled access to systems and data with strict authentication requirements
• Regular security assessments and continuous monitoring
• Formal incident management procedures
• Secure development practices
• Regular security awareness training for all staff

Our ISO 27001 certification covers all aspects of our service delivery, including the development, operation, and support of our AI Assistant platform. This certification is reviewed annually by independent auditors to ensure ongoing compliance. 

In the event of a security incident involving personal data, we will notify affected parties without undue delay and no later than 72 hours after becoming aware of the incident, in accordance with GDPR requirements.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. 

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

PostHog (PostHog Inc)

PostHog is a product analytics tool that shows how users engage with the platform, where they fall out of the funnel and what the overall trends in behavior are.

Personal Data collected: Usage data, email address

Place of processing: EU – Privacy Policy.

Contacting the User

Phone contact (this Website) 

Users that provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.

Personal Data collected: phone number.

Contact form (this Website)

By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

Personal Data collected: address; city; company name; country; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; province.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Website. Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it. 

YouTube video widget (Google Inc.)

YouTube is a video content visualization service provided by Google Inc. that allows this Website to incorporate content of this kind on its pages.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

Handling payments

Payment processing services enable this Website to process payments by credit card, bank transfer or other means. To ensure greater security, this Website shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction. Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment. 

Stripe (stripe.com, Stripe Technology Europe, Limited)

Stripe is a payment service provided by stripe.com, Stripe Technology Europe, Limited.

Personal Data collected: various types of Data as specified in the privacy policy of the service. 

Place of processing: Ireland – Privacy Policy.

Location-based interactions

Geolocation (this Website)

This Website may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website. 

Personal Data collected: geographic position.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Calendly (Calendly, LLC.)

Calendly is a software company that develops a business communication platform used for teams to schedule, prepare and follow up on external meetings.

Personal Data collected: address; city; company name; country; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; province. 

Place of processing: US – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

WordPress.com (Automattic Inc.)

WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host this Website.

Personal Data collected: various types of Data as specified in the privacy policy of the service. 

Place of processing: USA – Privacy Policy.

CRM Integrations

These integrations allow users to connect their Customer Relationship Management (CRM) systems to enhance the functionality of our services. 

HubSpot Integration 

This integration allows users to connect their HubSpot CRM to enhance the functionality of our services.

Personal Data collected: contact information, customer data, and other CRM-related data as authorized by the user. 

Place of processing: US – Privacy Policy. 

Salesforce Integration 

This integration allows users to connect their Salesforce CRM to enhance the functionality of our services. 

Personal Data collected: contact information, customer data, and other CRM-related data as authorized by the user.

Place of processing: US – Privacy Policy.

LLM Integrations

These integrations with Large Language Model (LLM) providers power AI-based features in our application.

OpenAI

OpenAI provides large language model services that power AI-based features in our application.

Personal Data collected: conversation content, queries, and context information provided by the user.

Place of processing: US – Privacy Policy.

Anthropic

Anthropic provides large language model services that power AI-based features in our application.

Personal Data collected: conversation content, queries, and context information provided by the user.

Place of processing: US – Privacy Policy.

Fireworks AI

Fireworks AI provides large language model services that power AI-based features in our application.

Personal Data collected: conversation content, queries, and context information provided by the user.

Place of processing: US – Privacy Policy.

Cohere AI

Cohere AI provides large language model services that power AI-based features in our application.

Personal Data collected: conversation content, queries, and context information provided by the user.

Place of processing: US – Privacy Policy.

Azure AI

Azure AI provides large language model services that power AI-based features in our application.

Personal Data collected: conversation content, queries, and context information provided by the user.

Place of processing: EU – Privacy Policy.

Data Storage Services

These services are used for storing and processing data.

Azure Cloud

Azure Cloud is used for hosting our infrastructure and storing data.

Personal Data collected: all application data including user information and content.

Place of processing: EU – Privacy Policy.

Zilliz Cloud

Zilliz Cloud is used for storing vectors in a vector database for AI-related functionality.

Personal Data collected: vector representations of user content and queries.

Place of processing: EU – Privacy Policy.

Log Management

These services are used for system monitoring and troubleshooting.

Azure Logs 

Azure Logs is used for system monitoring and troubleshooting. 

Personal Data collected: error logs, performance metrics, and system diagnostics that may incidentally contain user identifiers.

Place of processing: EU – Privacy Policy.

Langsmith

Langsmith is used for monitoring and analyzing AI model performance.

Personal Data collected: query logs, performance metrics, and system diagnostics.

Place of processing: US – Privacy Policy.

Sentry

Sentry is used for error tracking and performance monitoring.

Personal Data collected: error logs, performance metrics, and system diagnostics. 

Place of processing: US – Privacy Policy.

Remarketing and behavioral targeting

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. In addition to any opt out offered by any of the services below. 

Google Ads Remarketing (Google Inc.)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google’s use of cookies for ads personalization by visiting Google’s Ads Settings. 

Personal Data collected: Cookies; Usage Data. 

Place of processing: US – Privacy Policy – Opt Out.

Google Ad Manager Audience Extension (Google Inc.)

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Inc. that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them. 

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy – Opt Out.

Google Ads (Google Inc.) 

When you connect with your Google Account for the Google Ads integration, our app requests some permissions listed in the popup. 

Personal Data collected: Cookies; email address. 

Place of processing: US – Privacy Policy – Opt Out.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion. This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data. 

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies; Usage Data.

Place of processing: US – Privacy Policy.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Website. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website. 

HubSpot CRM (HubSpot, Inc.) 

HubSpot CRM is a User database management service provided by HubSpot, Inc.

Personal Data collected: email address; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: US – Privacy Policy.

International Data Transfers

For data transfers outside the European Union, the Owner relies on Standard Contractual Clauses (SCCs) approved by the European Commission to ensure adequate protection of personal data. These SCCs are contractual commitments between companies transferring personal data that are binding upon the parties to provide appropriate data protection safeguards.

For transfers to the United States or other non-EEA countries, we implement additional technical and organizational measures as recommended by the European Data Protection Board to ensure a level of protection essentially equivalent to that guaranteed within the EU. 

Users can request a copy of these safeguards by contacting the Owner using the contact details provided in this document.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following: 

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users can exercise these rights by contacting the Owner through the support channels provided.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Website uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Website and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User’s device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document. 

Latest update: March 19, 2025