Privacy Policy

Key Definitions

“Policy” refers to this Privacy Policy.

“Rubiktalk”, “we”, “us” and/or “our” refers to Rubiktalk Network, Inc. and any of our corporate affiliates.

“Services” refers to, individually and collectively, our video conferencing, collaboration, and related services, support, professional services, websites (including www.rubiktalk.com), and end user software on any platform. The Services are not intended for personal or consumer use.

“you” and “your” refer to individuals using or otherwise interacting with our Services.

“information” refers to data about you and your use of Services, that may be retained in electronic or paper format, and may include personal information as defined by the California Consumer Privacy Act of 2018 and personal data as defined by the General Data Protection Regulation and/or as defined by Section 2(1) of the Singapore Personal Data Protection Act 2012, as applicable.

Reasons We Process Your Information

We may process your information if:

· You, or the company you work for, or the company which provides you access to the Services, are a customer or a supplier of ours.

· You, or the company you work for, or the company which provides you access to the Services, use our Services.

· You work for one of our suppliers, resellers, or other business partners.

· You work for someone who uses our products or services.

· You, or the company you work for, may be a candidate for our advertising or marketing efforts.

· You communicate with us, or we receive a communication from or regarding you, through our Services or other communication.

· You request information about us, our business, and/or the Services.



Information We Collect

We collect information from you when you voluntarily provide that information to us. This may occur, for example, when you register for an account, modify your profile and preferences, complete and submit a form through the Services, provide payment information to complete a transaction, contact us with inquiries, participate in an event or promotion, or respond to one of our surveys.

We collect information from you when you voluntarily provide that information as part of your use of the Services. Examples of this include: when you submit a technical support request, participate in a chat function as part of a Rubiktalk Meeting or Event, or request that a Meeting or Event that you are hosting be recorded using the Services.

We collect information about you from third parties including other Service users, third-party service providers which you have linked to your use of our Services (including social media accounts, single-sign-on services, and scheduling applications), resellers, distributors, your employer, your administrator, publicly available sources, data enrichment vendors, payment and delivery service vendors, advertising networks, analytics providers, and our business partners. The information which we receive from third parties depends on what policies that third party follows and our and your respective relationships with the third party.

Personal data relating to you that we process may include:

· Your name.

· Who you work for, and your job function or department.

· Your address, phone number, email address or other contact details (these details may relate to your work or to you personally, depending on the nature of our relationship with you or the company that you work for).

· Information relating to transactions with us involving you or the company you work for (for example, details of goods or services that we have supplied to, or obtained from, you or the person you work for).

· Information relating to you which it is necessary for us to process in order to enter into or perform a contract with you or the company you work for (for example, right to work information and information obtained from credit references agencies where this is necessary to enable us to carry out appropriate checks in relation to contracts with you or someone else that you work for or are otherwise related to).

· Certain device and connection information when you use our Services, including the type of device or endpoint (e.g. browser type and version, browser plug-in types and versions, operating system and platform) you are using to access the Services, IP address, geolocation data, duration of Service use, and connection quality. The amount of information may vary depending on the nature of the equipment you use to access the Services and may also include non-identifiable or aggregated information to conduct research on customer demographics, interests and behavior.

· Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.

· When you use our Services for telehealth, medical data shared in the context of a patient visit.



How We Use Information

How we use the information is shaped by the source of the information, the type of Services you use, and any privacy preferences that you have specified to us. Below are the specific purposes for which we use the information we collect or receive about you.

To take steps in order to enter into any contract or carry out our obligations arising from any contract entered into between Rubiktalk and you, the company you work for, or the company which provides you access to the services, including:

· To provide the Services, related customer support, and supporting functions. We use the information you provide to make the Services available to you in a personalized manner which optimizes your experience. This includes providing supporting functions like using the information you provide in your profile to identify you to other Service users, performing billing operations, identifying whether you are complying with your license grant for the Services, detecting fraudulent activity or other improper uses of the Services, and verifying your identity.

· To communicate with you about the Service. We may reach out to you using the information you have provided via email, telephone, in-window messaging, through the software for the Service, on the website, and otherwise as appropriate for transactional communications such a change of password confirmation, billing receipts, product updates, and responding to customer support requests. We also send you information as a new user for a Service to better help you use the Service. These communications are part of the Services and, in many cases, you cannot opt out of receiving them.

· For engagement communications – We may communicate with you or the company you work for to better help you engage with our Services and maximize your use of the Services. This includes user training, letting you know about newly available features of your Services and seeking quality-related and engagement feedback.

· For promotional communications - We may communicate with you or the company you work for to better inform you of the Services available to you. This includes letting you know about potential new Services, newsletters, events, and related Services we offer that we believe will be of interest to you. If we do so, and if required by applicable law, each communication we send you will contain instructions permitting you to “opt-out” of receiving future communications. You can also object to further marketing at any time by sending us an email at [email protected].

· To better understand our users, and improve our Services accordingly (when our legitimate interest in doing so is not overridden by your personal rights that may apply). We may use such information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, the domain names of your Internet service provider, general geographic location, and how you use and interact with the Services. We can use this information to identify trends, usage patterns, service quality interruptions, undiscovered bugs in the Services, and better optimize your Services experience in the future. Also, in an ongoing effort to better understand and serve the users of the Services, Rubiktalk often conducts research on its customer demographics, interests and behavior based on the information on an aggregate basis.

· For uses as required by law or to otherwise protect our legal rights. There may be situations where we believe it is required by law or necessary to protect our legal rights or the interests of others to use the information in connection with pending or active litigation, regulatory compliance efforts, audits, and disclosures in connection with the acquisition, merger or sale of a business.

· For other uses with your consent. If Rubiktalk intends on using any information in any manner that is not consistent with this Policy, you will be informed of such anticipated use and be given an opportunity to provide your consent for such use and/or discontinue your use of the Services.

The Services are not intended to be used for profiling, automated processing, personal data relating to criminal convictions or offenses, other systematic monitoring of a public area, or any other operations which may result in a high risk of significantly affecting you or your legal rights.

If you are an EU resident, the following terms also apply:

Rubiktalk processes your personal data when we have an adequate legal basis for doing so. This means we collect and use your personal data where:

· We need it to provide you the Services;

· It satisfies a legitimate interest (which is not overridden by your data protection interests);

· You give us consent to use the personal data for a specific purpose; or

· We need to process your personal data to comply with a legal or contractual obligation.

If you have consented to our use of personal data for a specific purpose, you have the right to change your mind at any time, and the procedures for communicating that revocation of consent are detailed below. Any such decision will not affect any processing that has already occurred. Where you withdraw your consent, but we are using your information because we or a third party (e.g. your employer) have a legitimate interest in doing so, or we have different legal basis for using your information (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information. However, this may mean your access to the Services will be limited or suspended, and your accounts may be terminated, as applicable.



How Long We Keep Information

Rubiktalk will generally retain information for so long as you are an active user of the Services. Most information is available for you to modify or delete on a self-service basis. For more extensive requests, you may make a request per the guidelines below. Metadata and/or connection analytics following use of the Services is retained and made available for a host user and/or an administrative user to review during an administrator-set retention period. Information that is older than the pre-set retention period will be obfuscated and archived.

Following the end of your subscription to the Services, your information will generally be deleted or obfuscated within six months of the end of your subscription. If the Services are made available to you through an organization (e.g., your employer), we retain your information per your organization’s instructions. For more information, see the “Additional Information Regarding Processing Information of Our Customers” section below.

Some information may be retained to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, for marketing purposes according to your registered preferences if you have opted to receive such communication, information derived from cookies, and information required to continue to develop and improve our Services.

Where we retain information after your use of the Service, we take reasonable steps to make that data is not personally identifiable beyond the extent required to comply with our legal and regulatory obligations.



How We Protect Information

Rubiktalk takes appropriate physical, technical, and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration, and destruction. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your information from unauthorized access, use or disclosure.



Who We Share Information With

There are certain circumstances in which we may share your information with certain third-parties. Any access by a third party to the information is managed by Rubiktalk, and the third parties are vetted based in part on their ability to protect information. International movement of information consistent with this sharing is discussed in the “How We Move Information” section below.

As part of your use of the Service, you may share information with other users of the Service. Those users of the Service may be located in nearly any location around the world, may be communicating with Third Party Sites (as defined below) while using the Services, and may be limited by law or by an agreement with us about their use of information you share. However, this Policy only addresses our use of the information.

We may share information with employees, contractors, agents, or consultants with a strict need-to-know under appropriate confidentiality obligations.

We may share information with third parties which provide business-related functions on behalf of Rubiktalk, including:

· Our business partners, customers, suppliers, service providers, vendors, and sub-contractors for the performance of any contract we enter into or other dealings we have in the normal course of business with you or the company that you work for or the company that provides you access to the Services. Some examples of such business-related functions for which we may share information may include data hosting, analyzing data, providing marketing assistance, providing customer service and technical support, processing orders, sending communications to you on our behalf or at our direction, user engagement and onboarding, soliciting feedback regarding the Services, facilitating invoicing and/or payments, and others in our reasonable discretion;

· Our auditors, legal advisors and other professional advisors or service providers;

· Credit reference agencies for the purpose of assessing your credit score where this is in the context of us entering into a contract with you or the person that you work for;

· We may share information with our authorized distributors and resellers if you have purchased your license to the Services through a party other than Rubiktalk to enable those distributors and resellers to fulfill their business obligations to you; and

· We may share information obtained via our Services with analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy.

When we employ another company to perform services of this nature, we only provide such company the right to use such information that is reasonably necessary to perform their specific function.

We may share information with other third parties, including when you provide consent for a specific situation. If Rubiktalk intends on sharing any information in a manner other than as described above using any personal data in any manner that is not compatible with this Privacy Policy, and we do not have a legal basis for sharing that information without your consent, you will be informed of such anticipated use and be given an opportunity to provide your consent for such use.

We may share information with third parties if we reasonably believe that such action is necessary to:

· comply with a legal obligation, regulation, or government request,

· enforce our policies and agreements,

· protect and defend the rights, property, and safety of Rubiktalk, our customers, users, resellers, or others, or

· act in urgent circumstances to protect the personal safety of users of the Services or the public.

This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

We may share information with our subsidiaries and corporate affiliates including Verizon who support our processing of personal data under this Policy.

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, acquisition, merger, reorganization, dissolution or similar event, information may be part of the transferred assets. You will be notified via email and/or other means with any news of a transaction and any choices you may have regarding your information.

For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.



How We Transfer Information

We provide our Services primarily from the United States, where we are based. Your use of the Services requires the movement of information to our locations and the locations of our third-party service providers. Your use of the Services may require that our international affiliates and subsidiaries in countries including Australia, India, Netherlands, Singapore, and United Kingdom have access to the information.

If you are an EU resident:

Your information may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent data protection law. It may be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

· In order to store it.

· In order to enable us to provide services to and fulfill our contract with you or the company your work for or the company that provides you access to the Services. This includes order fulfillment, processing of payment details, and the provision of support services.

· Where we are legally required to do so.

· In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

· Where we have your consent to do so.

When we share information about you within Rubiktalk and with entities in countries with local laws which may differ from yours, we safeguard the transfer of information we collect from the European Economic Area and Switzerland to the United States. We are no longer participating in the EU-U.S Privacy Shield, nor the Swiss-U.S. Privacy Shield, but we are safeguarding transfers through other means such as standard contractual data protection clauses, which have been approved by the European Commission and Switzerland, and/or the Verizon Binding Corporate Rules, as applicable. In some cases we may use other appropriate legal mechanisms to safeguard the transfer. Please see our Trust Center for further information about standard contractual data protection clauses.

If you are an Australian national, where Rubiktalk discloses personal information (as defined by the Australian Privacy Act) of Australian nationals with third parties outside of Australia, Rubiktalk will operate in a manner materially consistent with the applicable Australian Privacy Principles and seek to ensure that the third party recipient holds and uses the personal information consistently with the applicable Australian Privacy Principle and other applicable privacy laws.



Additional Information Regarding Processing Information of Our Customers

Where we provide access to the Services to you under contract with an organization (for example your employer), or if you use an email address provided by an organization to access the Services, that organization may act as the controller of the information. Your use of the Services may be subject to that organization's policies. Each organization may appoint administrative users of the Services. An administrator may have the ability to access, modify, and/or delete certain information that you have provided, give information to Third Party Sites (as defined below), and restrict your access to the Services and information in whole or in part.

In this situation, Rubiktalk is the processor, rather than the controller, of your information. Where we are the processor, we do not control why or how your information is used, and you will need to contact your relevant controller (e.g. your employer and/or the company which provides you access to the Services) to find out about your data protection rights and responsibilities. All questions about your organization’s policies and administrative user access rights should be directed to your organization.



Privacy and Recordings

Video and audio from the video conferencing services may be recorded and saved via the Services by the host account for the Service in which you are participating. We do not and cannot control whether your use of the Services is being video recorded or audio recorded, via the Services or a third-party technology. If you do not want to be recorded during your use of the Services, you may inform your host of that decision and/or decline to use the Services.



How You Can Access and Control Information

In accordance with applicable law, your ability to control the information may include the right to:

· Request a record of information you have provided

· Request that information be corrected or removed

· Request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example)

· Request that, to the extent reasonably possible, information be provided in a structured and commonly used electronic format for portability and transfer

· Object to and/or opt-out of our use of your information, including the right to object to marketing, in whole or in part, subject to certain exceptions prescribed by law.

You can exercise many of these abilities directly through the Services via your Rubiktalk profile page. You may opt out of non-transactional emails through the email notification center. For any issue that cannot be handled on a self-service basis, please reach out to our Support team for assistance. You can also exercise the rights listed above at any time by contacting us at [email protected]. In some instances, if you access the Services under contract with an organization, we may be required to direct your inquiries to an administrative user.

If you no longer want to use our Services, you may choose not to access our website or video-conferencing services at any time and, as applicable, you will need to reach out to our Support team or an administrative user to deactivate your account. If you are an organizational user of the Services, you will need to arrange for an administrative user to remove personal data associated with your account. Otherwise, personal data will be deleted or obfuscated within 180 days of the deactivation of your account.

You may contact our Support team to ask us to stop accessing, storing, using and otherwise processing your information where our legal basis for doing so relies on your consent or is otherwise objectionable by law. Where you gave us consent to use your information for a limited purpose, you can contact our Support team to withdraw that consent, but this will not affect any processing already occurred. Where you withdraw your consent, but we are also using your information under a different legal basis (for example, fulfilling a contract with you), we may continue to process your information, subject to your rights to access and control your information. Please note that we may need to retain certain information to fulfill legal obligations, in accordance with our record retention practices, or to complete transactions.



Additional Notes on Your Privacy

Rubiktalk does not knowingly collect information from children under the age of 13, and our Services are not intended for use by minors (as defined in your relevant jurisdiction). By using our Services, you confirm to us that you are not under the age of 13 and/or not a minor.

If you are a minor, please do not submit any information through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide information via the Services without permission. If you have reason to believe that a minor has provided information to Rubiktalk, please contact us and we will endeavor to delete that information from our databases.

The Services may contain links, add-ins applications, social media widgets or other access points that will take you and your information to other websites and resources on the Internet that are not operated or controlled by Rubiktalk (“Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. We have no control over, are not responsible for, and do not endorse the information practices of such third party websites and resources. Your access to and use of such third party websites or resources, including your use of any content, information, data, advertising, products, or other materials on or available through them, is solely at your own risk and is subject to the terms and conditions of use and privacy policy(ies) applicable to such Third Party Sites and related resources. Once you choose to be directed to a Third Party Site, you should read the applicable privacy statement before sharing any personal or other information. If you object to information about you being shared with a Third Party Site, please disable any applications or plug-ins which communicate with the Third Party Site or contact your administrator to do so.



Changes to this Policy

The Services and our business may change from time to time. As a result, at times it may be necessary for Rubiktalk to make changes to this Policy. Rubiktalk reserves the right to update or modify this Policy at any time and endeavor to give you the opportunity to review the revised Policy before you choose to continue using our Services.

Please review this Policy periodically. Your continued use of the Services after any changes or revisions to this Policy indicates that you have read and understood the terms of such revised Policy.

This Policy shall not apply to any unsolicited information you provide to Rubiktalk through this website or otherwise through the Services. This includes, but is not limited to, any ideas for new products or modifications to existing products. All such unsolicited information shall be deemed to be non-confidential. Rubiktalk shall be free to reproduce, use, disclose, distribute and exploit such unsolicited information without limitation or attribution. However, if such unsolicited information also includes personal data, we will also determine whether we have a lawful basis for the collection and use of that information prior to doing so.



How to Submit a Complaint/Dispute Resolution

If you have a complaint about Rubiktalk’ privacy practices, please write to us at the address below. We will take reasonable endeavors to work with you to attempt to resolve your complaint.

If you are an EU resident, and you have a request or concern about how we handle your personal information, you can also contact your local supervisory authority.

If you are an Australian national, and you have a complaint about how we handle your personal information, you can also contact the Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001, Australia, https://www.oaic.gov.au.

How to Contact Rubiktalk

If you have any questions about our Privacy Policy or the information practices of the Services, please contact to the email [email protected].

Additional Terms

Please note that, in addition to this Policy, your access to and use of

· this website is subject to our Terms of Service; and

· your access and use of our Services is subject to our Acceptable Use Policy and either the terms and conditions governing your subscription for our Services or, if you are not a paying customer of Rubiktalk or part of a paying organizational customer of Rubiktalk, our Terms of Service.