Privacy Policy

1What Information We Collect About You

1.1 We collect the following types of information about you:

• Account Data: Account and profile information that you provide when you register for an account or sign up for our products or services, for example your name, username or similar identifier, job title, date of birth, physical address, email address, and telephone number(s).
• Support Data: Information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots.
• User Content: Content you provide through use of our products or services, for example posts, comments, discussion forums, chats, and reviews.
• Preference Data: Communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or questionnaire that we send you.
• Transaction Data: Details of any transactions, purchases, or orders that you've made with us.
• Financial Data: Payment information - your payment card information will be processed by our payment processor.
• Technical Data: Information about your device or connection, for example your internet protocol (IP) address, log-in data, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our products or services.
• Usage Data: Information about your use of or visit to our Platform, for example your clickstream to, through, and from our Platform, products you viewed, used, or searched for, page response times, download errors, length of visits to certain pages, and page interaction information.

1.2 We collect the above information when you provide it to us or when you use or visit our Platform. We may also receive information about you from other sources.

1.3 We do not directly collect sensitive data or special category data about you, except as described in section 1.4 below regarding identity verification.

1.4 Identity Verification Data

Depending on the service you use, we may require you to verify your identity. When you undergo identity verification:

• Documents you may submit: Passport, driver's license, national ID card, proof of address, and/or a selfie photograph. The specific documents required depend on the application and level of verification needed.
• Biometric data: For certain registrations, facial recognition technology may be used to compare your selfie against your identity document. This biometric processing is performed by our third-party verification provider.
• Third-party processing: Your identity documents and biometric data are processed by our verification partner, GlobalConnect, who acts as a data processor on our behalf. GlobalConnect retains your documents in accordance with their own privacy policy and applicable legal requirements.
• What we retain: RUBI does not store copies of your identity documents or biometric data. We retain only the verification results, including: verification status (approved/declined), verified name, date of birth, document type used, and date of verification.
• Retention period: We retain verification results for the duration of your account plus 7 years, or as required by applicable anti-money laundering and regulatory requirements.

1.5 Other than identity verification data described above, we do not collect sensitive data about your race, ethnic origin, politics, religion, trade union membership, genetics, health, or sexual orientation.

2How We Use Information We Collect

2.1 We only use your personal information where the law allows us to. We use your personal information only where:

• We need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our Platform;
• It satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests;
• You've given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories with your permission; or
• We need to comply with a legal or regulatory obligation.

2.2 If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us, but please note this will not affect any use of your information that has already taken place.

2.3 We do not share your personal information with any company outside our group for marketing purposes, unless with your express specific consent to do so.

2.4 For visitors to or users of our Platform who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.

3How We Share Information We Collect

3.1 We may share personal information on aggregated or de-identified basis with third parties for research and analysis, profiling, and similar purposes to help us improve our products and services.

3.2 We share your identity verification data with our verification partner, GlobalConnect, who processes identity documents and performs biometric checks on our behalf. GlobalConnect acts as a data processor and is contractually required to protect your information and process it only for verification purposes.

3.3 If you use any third-party software in connection with our products or services, you might give the third-party software provider access to your account and information. Policies and procedures of third-party software providers are not controlled by us, and this policy does not cover how your information is collected or used by third-party software providers.

3.4 Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies.

3.5 We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.

3.6 If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.

4How We Store and Secure Information We Collect

4.1 We use data hosting service providers based in Australia and the United States of America to host the information we collect.

4.2 We have adopted the following measures to protect the security and integrity of your personal information:

• Information is encrypted using TLS/SSL technology;
• Your account is password-protected;
• Access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
• Our information collection, storage, and processing practices are reviewed regularly.

4.3 We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

4.4 While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.

4.5 We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. After such time, we will delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it from further use.

5How We Transfer Information Internationally

5.1 We collect information globally and primarily store that information in Australia and the United States of America. We transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.

5.2 Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.

6Your Rights

6.1 You have the right to:

• Be informed of what we do with your personal information;
• Request a copy of personal information we hold about you;
• Require us to correct any inaccuracy or error in any personal information we hold about you;
• Request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
• Object to or restrict the processing by us of your personal information (including for marketing purposes);
• Request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
• Withdraw your consent at any time where we are relying on consent to process your personal information.

6.2 Our Platform enables you to update certain information about yourself within your account settings.

6.3 You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications, by updating your preferences within your account, or by contacting us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.

6.4 As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

6.5 Any request under paragraph 6.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.

6.6 We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.

7Changes to This Policy

7.1 We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.

8Policy Towards Children

8.1 Our products and services are not directed to individuals under 16. We do not knowingly collect personal information from individuals under 16. If we become aware that an individual under 16 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 16.

9Contact Us

9.1 Please contact us at privacy@rubi1.io for any privacy-related questions or concerns.

9.2 Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.

Legal Bases Table (EU Users)