Privacy Policy

1. Introduction

This Privacy Policy explains how Kubikel ("Kubikel", "we") collects, uses, and protects personal data when you use the Kubikel platform. This policy is drafted with regard to Law No. 27 of 2022 on Personal Data Protection (the PDP Law).

2. Data Controller

For personal data processed in order to operate the Service, Kubikel acts as Data Controller or Processor depending on the context of use. For Content you upload, you generally act as the Data Controller and Kubikel as the Processor.

3. Data We Collect

We may collect the following categories of data:

• Account data: name, email address, agency/organization, and role.
• Usage data: activity within the Service, logs, and device information.
• Content you upload: spatial and non-spatial data, which may contain third-party personal data.

4. Basis for Processing

We process personal data on a lawful basis, including: your consent, performance of a contract (providing the Service), compliance with legal obligations, and/or legitimate interests provided they do not override your rights.

5. Purposes of Processing

• to provide, maintain, and improve the Service;
• to manage accounts and user support;
• to maintain security and prevent misuse;
• to comply with legal obligations and lawful requests.

6. Data Sharing and Disclosure

We do not sell personal data. We may share data on a limited basis with service providers (sub-processors) that help us operate the Service, or where required by law. Sub-processors are bound by confidentiality and data-protection obligations.

7. Data Storage and Residency

We apply technical and organizational measures to protect data. For specific needs, including government clients, in-country data residency options can be provided by agreement.

8. Data Security

We apply encryption in transit and at rest, role-based access control, and separation of duties. No system is entirely free of risk, but we strive to maintain the confidentiality, integrity, and availability of data.

9. Data Retention

We retain personal data for as long as needed for the purposes of processing or as required by law. Once no longer needed, data is deleted or anonymized.

10. Your Rights as a Data Subject

Under the PDP Law, you have rights over your personal data, including:

• to obtain information about and access to your personal data;
• to correct or update inaccurate personal data;
• to end processing, delete, and/or destroy personal data;
• to withdraw consent previously given;
• to object to certain processing activities.

11. Cookies

We may use cookies or similar technologies to operate and improve the Service. You can manage your cookie preferences through your browser.

12. Changes to This Policy

We may update this Policy from time to time. We will notify you of material changes through the Service.

13. Contact

To exercise your rights or raise privacy questions, please contact the official Kubikel contact.