Cubic Supply Chain Technologies Ltd. and its affiliates (“Cubic”, “Company”, “we”, “our” or “us”) respects the privacy of the visitors and/or users of its Site and/or Services (“User” or “you”), and is committed to protect the personal information that its Users share with Cubic. We believe that you have a right to know our practices regarding the information we may collect and use when you visit and/or use our Site and/or use our Services.

Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Use (“TOU”), into which this Privacy Policy is incorporated by reference.

1. Your Consent (PLEASE READ CAREFULLY!)

BY ENTERING, CONNECTING TO, ACCESSING OR USING THE SITE AND/OR USING THE SERVICES, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY (THE “PRIVACY POLICY”), INCLUDING TO THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE WITH ANY TERM PROVIDED HEREIN, YOU MAY NOT USE THE SERVICES AND/OR ENTER, ACCESS AND/OR USE THE SITE. 

FOR AVOIDANCE OF DOUBT, YOU HEREBY CONSENT TO THE COLLECTION, PROCESSING, TRANSFER AND USE OF YOUR PERSONAL INFORMATION. YOU ALSO ACKNOWLEDGE AND CONFIRM THAT YOU ARE NOT REQUIRED TO PROVIDE US WITH YOUR PERSONAL INFORMATION AND THAT SUCH INFORMATION IS VOLUNTARILY PROVIDED.

2. Which information we may collect on our Users?

We may collect two types of data and information from our Users:

a. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information which does not enable identification of an individual User, and which is available to us while such User is entering and/or using the Site and/or Services. Non-personal Information which is being gathered consists of technical information, behavioral information and aggregated information, and may contain, among other things, the activity of the User on the Site and/or Services, type of operating system, type of the User’s device and its version, User's ‘click-stream’ on the Site, product interaction, type of browser and keyboard features, the hardware specifications of such device (including screen resolution), time spent on various screens of the Site, User demographics, traffic patterns, etc. (collectively, “Technical and Behavioral Information”).

b. The second type of information is any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, first and last name,phone number, country of residence, company name and email address, or other contact information(“Personal Information”). This information may identify an individual or may be of a private and/or sensitive nature.

Information you provide voluntarily when you use the Site and/or the Services

Account: Personal Information is collected from the details the Users provide in the registration form in order to open an Account on the Site and/or Services which includes, inter alia, the User's name, phone number, e-mail address, username and password. To this end, we may require additional information from time to time. 

Demographic Information: you may provide us with your gender, and other demographic information.

Photos: you may provide us with photos. 

Activities on the Site and Services, including shipping details: we collect all Personal Information relating to Services that you may order via the Site and/or Services, whether provided directly to us or inferred from the Services that you order, including without limitation, shipping details, cargo details, locationsand dates. Please note: if in the scope of ordering Services via the Site or Services, you provide us with any information relating to a third party, you are fully and solely responsible for providing all necessary information notices to affected data subjects and obtaining the required consents under applicable privacy law from data subjects for the use, processing, sub-processing and storing of their information in accordance with this Privacy Policy.

Mailing lists: you may voluntarily join our mailing list by providing us with your email address.

Communications with Cubic: Personal information you provide to us as part of any communications with Cubic, by any means, including by approaching our customer service (such information may include marketing and communication data that includes your preferences in receiving marketing from us and your communication preferences).

Payment: in order to pay for Services, you may be required to use certain Online Payment Processors which will require you to fill out a billing form wherein you will be required to provide to such Online Payment Processors certain Personal Information (such as, a credit card number and other related billing information) (see Section 6 below regarding the payment method). We will not store such information on our servers. We only keep token information such Online Payment Processors provide us with, and such information is strictly secured.

Personal Information included in the User Generated Content 

• The Site may allow Users to upload, post, publish and make available through it, their own copyrightable materials such as literary works, text, images, text material, photos and any other proprietary materials, including without limitation commenting on the Services and other content available via the Site and/or Services (collectively, the “User Generated Content”).

• You may, at your direction include Personal Information in the User Generated Content. Please note: if such User Generated Content includes information about others, you are fully and solely responsible for providing all necessary information notices to affected data subjects and obtaining the required consents under applicable privacy law from data subjects for the use, processing, sub-processing and storing of their information in accordance with this Privacy Policy.

• Please note that unless explicitly stated otherwise, all User Generated Content is publicly available. 

Personal Information collected via technology

• IP address: Users of the Site may automatically provide their IP address (or Mac Address, as applicable) mainly for enhancing the User’s experience and for geo-location and security purposes as further detailed below.

• Geolocation data: during your use of the Site, Cubic may access, collect, process, monitor and/or remotely store "geolocation data", including through the collection of Internet Protocol (IP) addresses and other similar information to determine your location for providing our services and for analytics, advertising and security purposes.

 • Identifiers: during your use of the Site, we may access, collect, process, monitor and/or remotely store online identifiers, such as Internet Protocol (IP) address, AD-ID or other unique identifiers, for the purpose of providing you with targeted advertising and for statistical and metric purposes.

• Technical and Behavioral Information: to the extent that the Technical and Behavioral Information will be linked to or associated with a specific individual then such information will be considered as Personal Information. 

We may cross-reference Personal Information with other Personal Information we have about you and any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

We do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your active acceptance of the TOU and the Privacy Policy.

3. How Do We Collect Information on Our Users?

There are a few main methods we use: 

a. We collect information through your use of the Services and entry, access and/or use of the Site. In other words, when you are using the Site or Services, we are aware of it and may gather, collect and store the information relating to such usage.

b. We collect information which you provide us voluntarily. For example, we collect Personal Information when you register and open an Account.

We may gather, collect and store such information either independently or through the help of our authorized third-party service providers, as detailed below.

4. What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:   

• Use it for statistical and research purposes and for customization and improvement of our Services and Site. This includes, for the avoidance of doubt, processing of User Generated Content and Technical and Behavioral Information in an anonymous and non-identifiable manner in order to recognize general trends and preferences that are not tied to any specific individual.

• Enhance the User’s experience while using the Services.

• For Security purposes. 

Personal Information is collected in order to:   

• Enable the overall operation of the Site and Services.

• Personalize your experience on the Site and Services.

• Improve the quality of the Site and Services and the Services by formulating, customizing and enhancing the User's experience.

• Allow us to contact Users with proposals and tailored information regarding new Services, products, events, offers, features, enhancements, special offers, and events of interest etc.

• Communicate with our Users, including by telephone, transactional text messages and emails.

• Send push notifications to Users. Users of the Services can deactivate push notification by changing their settings within our Services or by using their web browser/device’s settings.

• Verify the User's identity when he/she signs into the Site, as well as verifying User's identity for the purpose of dealing with inappropriate interactions of User and/or fraudulent use of our Services and Site.

• Be able to contact Users for the purpose of providing them with technical assistance and support.

• Keep the Site and Services safe and secured and for prevention of fraud and crime.

• Maintain our data processing records and general administrative purposes.

• Determine the User’s geo-location to provide the Services and to safeguard the Site and Services.

• Provide the Users who subscribed to our newsletter with updates about the Company’s developments, new offerings, news regarding the Services, etc.

• Enable our third-party advertising service providers to present you with our advertisements on websites and apps across the Internet and across devices. You may opt-out from such advertising activities by following the directions detailed below.

• Conduct internal operations, including troubleshooting, data analysis, testing, research and statistical purposes, including in order to improve our services. Please note that in general we analyze aggregate data for such purposes, rather than specific user data, however we may need to analyze a specific case to address a specific problem.

• Enable payment through third party Online Payment Processors. Please note that we do not collect and store credit card or other financial information.

• Comply with our legal obligations and have the ability to protect our rights and legitimate interests.

• Email tracking – we may use tracking technology within the email we may send you in order to improve interactions with you and to better understand whether our emails were opened and read, and such tracking may include capturing the time and date in which you opened our email messages and the type of device you use to open such emails.

5. Sharing Information with Third Parties    

The Company may share your Personal Information with relevant third-party service providers, as necessary to provide the Services you order. Other than that, the Company does not share Personal Information, except in the following cases: (a) to satisfy any applicable law, regulation, legal process, subpoena or governmental request; (b) to enforce the TOU including investigation of potential violations thereof; (c) to detect, prevent, or otherwise address fraud, security or technical issues; (d) to respond to User’s Site or Services support requests; (e) to respond to claims that any Content violates the rights of third-parties; (f) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; (g) to protect the rights, property, or personal safety of the Company, its Users, or the general public; (h) when the Companyis undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of its assets (while such purchaser or investor may be located in a country that does not have the same data protection laws as your jurisdiction); (i) to collect, hold and/or manage your Personal Information through the Company’s authorized third parties service providers (including, as applicable, their affiliates as necessary to provide us with the requested services), as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction; (j) to store or process your Personal Information through the Company’s affiliated companies, which may be located in a country that does not have the same data protection laws as your jurisdiction; (k) for legitimate business purposes, including without limitation, enhancing the User’s experience; and/or (l) pursuant to your explicit approval prior to the disclosure. 

For avoidance of doubt, the Company has the unrestricted right to use Non-personal Information, including any aggregated non-identifiable information, for any purpose and to transfer and disclose Non-personal Information to third parties at its own discretion. 

6. Payment

We may accept certain online payment methods, using our Online Payment Processors, which enable Users to render payments securely online using a credit card number or bank account. We may add or change the Online Payment Processors at our sole discretion. Cubic is not affiliated with such Online Payment Processors (for more information please see our TOU, as each is an independent contractor, neither is the agent or employee of the other and neither is responsible in any way for the actions or performance (or lack thereof) of the other. The use of the Online Payment Processors is at the User’s discretion and sole liability and risk. It is the User’s responsibility to abide by all the terms specified by the Online Payment Processors in their terms of use and privacy policies. You acknowledge that you are fully assuming the risks of conducting any transactions via the Online Payment Processors.

7. How You Can View, Update or Delete Your Personal Information

Cubic acknowledges you have the right to access and change the Personal Information we collect and process. You can access, amend and delete your Personal Information, directly through your Account page on the Site. If you are unable to independently access your Personal Information, and for any other inquiries relating to the exercise of your rights under applicable privacy laws, please send us an email to [email protected] and we will respond within a reasonable timeframe, but in any event no later than permitted by applicable law. 

Note that unless otherwise explicitly specified herein and/or unless you instruct us otherwise we may retain your Personal Information for as long as reasonably required for the purposes of which such Personal Information was collected, all as permitted under any applicable privacy laws. Aggregate and/or anonymous information derived from your use of the Services may remain on the Company servers indefinitely.     

8. Minors

The Site and/or Services are intended for Users over the age of eighteen (18). Therefore, The Companydoes not intend and does not knowingly collect Personal Information from minors under the age of eighteen(18) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Site and Services. If we learn that we collected Personal Information from minors under the age of eighteen (18) we will delete that information as quickly as possible. If you have reasons to suspect that the Company collected Personal Information from minors under the age of eighteen (18), please notify us through the means indicated in the “Contact Us”section below, and we will delete that information as quickly as possible.

9. How We Protect Information

We take reasonable measures to maintain the security and integrity of our Site and/or the Services and User information and prevent unauthorized access to it or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.     

THE COMPANY SHALL NOT BE RESPONSIBLE OR LIABLE FOR UNAUTHORIZED ACCESS, HACKING, OR OTHER SECURITY INTRUSIONS OR THE THEFT, DELETION, CORRUPTION, DESTRUCTION, DAMAGE, OR LOSS OF ANY DATA.   

10. Third Party Service Providers 

We may be using third party software or service in order to collect, host, store and/or process the information detailed herein for the purposes specified herein. Such third parties may be located in a country that does not have the same data protection laws as your jurisdiction. The Company engages with third parties that abide by the same lawful obligations as the Company and that post a privacy policy governing their collection, processing and use of non-personal and personal information. However, the Company does not control such third party service providers. Please read their terms of use and privacy policies to understand their privacy practices.

Such software may include without limitation:

11. International Data Transfer 

We may transfer information collected about you, including Personal Information, to affiliated entities, or to other third-party service provides across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information.

12. Links to Third Party Websites  

The Site and/or Services may contain links to third-party websites, applications or services. The Company is not responsible for the privacy practices or the content of such resources. Most of such linked resources provide legal documents, including terms of use and privacy policy, governing the use thereof. It is always advisable to read such documents carefully before using those resources, inter alia, in order to know what kind of information they are collecting.

13. Cookies and Other Tracking Technologies

When you access or use the Site, we and/or our third party service providers may use industry-wide technologies such as cookies, web beacons, pixels, clear gifs and other similar tools (or other similar technologies), which store certain local information on your device (“Local Storage”) which may enable us, inter alia, to recognize your device from those of other Users of the Site, to improve the Site’s performance, to deliver a better and more personalized service according to the User’s individual interests and the device or browser used, to track Users’ use of the Site and/or Services, to gather information about the Users’ approximate geographic location (e.g. city), to prevent fraud and/or abuse, to estimate our audience size and usage pattern and perform other analytics, to develop our Site and/or Services and to serve targeted advertisements.  

Such information is locally stored in the User’s device. Cubic and/or our authorized third party service providers may access such information. Cubic and/or our authorized third party service providers may use both session cookies (which expire once you close the web-browser) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Site may store non-personal information (such as the different pages viewed by a User within the Site and/or Services) as well as User persistent identifier, which will be collected in accordance with the terms specified herein. 

Most devices and browsers will allow you to erase cookies from your device’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, your experience of the Site may be limited. Please note that unless you block the acceptance of cookies, the Sitewill utilize cookies upon your use of the Site. If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Site from placing further cookies on your device unless and until you adjust your settings as described above.  For detailed instructions regarding the blocking of cookies, please refer to your browser ‘help’, ‘tool’ or ‘edit’ section or see http://www.allaboutcookies.org/manage-cookies/. Below are links to instructions regarding the blocking of Cookies on commonly used web-browsers:

• Chrome

• Internet Explorer and Microsoft Edge

• Mozilla Firefox

• Safari

It is possible to opt-out of having your browsing activity within the Site recorded by performance cookies. Please note that we use Google Analytics as our service provider in order to track Users' activities on the Site, including by use such services’ persistent cookies. Google provides a browser-add on which allows users to opt-out of Google Analytics across all websites, which can be downloaded here: https://tools.google.com/dlpage/gaoptout.

You may obtain information about how you can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. You can visit the Internet Advertising Bureau’s consumer advice site at http://www.youronlinechoices.com/uk/your-ad-choices, which will provide you further information, a list of all Cookies that are currently set on your device and instruction on how to opt-out of each of them. 

14. Direct Marketing 

You hereby agree that we may use your contact details for the purpose of informing you of products, services and other updates and new features which may be of interest to you, as well as for sending you other materials to the e-mail address provided by you in the registration process. You may withdraw your consent by following the instructions for removing yourself from the mailing list which are available in the e-mail transmitted to you, or by contacting us as provided in the “Contact Us” section below.

15. Changes to the Privacy Policy 

The terms of this Privacy Policy will govern the use of the Site and/or Services and any information collected with respect thereto. The Company reserves the right to change this policy at any time, so please re-visit this page frequently. In case of any material change, we will make reasonable efforts to post a clear notice on the Site or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us with. Such substantial changes will take effect seven (7) days after such notice was provided on our Site or sent by e-mail, whichever is the earlier. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Site and/or Servicesafter the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes. In the event that the TOU should be amended to comply with any legal requirements, the amendments may take effect immediately, or as required by the law and without any prior notice. Changes to this Privacy Policy will not be applied retroactively

16. Contact Us

If you have any questions (or comments) concerning this Privacy Policy, you are most welcome to send us an email to the following address: [email protected] and we will make an effort to reply within a reasonable timeframe.