I. WEBSITE PRIVACY
II. INFORMATION COLLECTION AND USE
Information You Provide to Us
You can browse our Website without providing any personal information to us. Cubex gathers and retains personal information about you when you voluntarily submit it to us and automatically collects statistical information about visitors’ use of the Website. Information that you submit may be linked with statistical information about your access to and use of the Website.
Inquiries and Forms
If you choose to complete and submit a form or otherwise provide information through our Website when you make an inquiry, including but not limited to the “Contact Us” page, we may collect your name, postal or email address, contact information and any other data you submit.
Social Networking Activities
The Website includes the ability for you and other users to link to social networking websites. As a result, we receive information about you when you choose to post or otherwise share information about our Website on these social networking websites. We may also receive information about you from your social networking account depending on your privacy setting for that account; you can control this by adjusting your privacy setting on your social network account.
Before you can utilize some portions of the Website, we will require that you create an account and provide us with your first name, last name, and email address, and create a password. You may also need to verify your account post creation by email verification.
When you engage in any financial transaction through the Website, you will be asked to provide certain of your financial information, such as your debit card, credit card or PayPal account and billing or shipping address.
Surveys, Contests and Other Promotions
Use and Retention of Information You Provide
We may use the information we collect from you for our general operational and development purposes, for example:
- to respond to your requests or inquiries,
- to process transactions you have requested,
- to manage or facilitate the operation of the Website,
- to enhance your experience with Cubex,
- to communicate with you about products, services, events and other opportunities related to Cubex,
- to identify you or authenticate your identity,
- to communicate with you regarding your account with us,
- to monitor and improve the use and satisfaction of Website users,
- to display advertisements relevant to your interests,
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection,
- to notify you about changes to our Website or any products or services we offer or provide though it,
- to conduct research and analysis, and
- to expand our services and outreach.
We will only keep financial transaction information (if any) as long as necessary to complete the transaction or series of recurring transactions authorized by you. We may keep all other information indefinitely.
III. AUTOMATICALLY COLLECTED INFORMATION
URLs and IP Addresses
The types of cookies we may use on our Website include:
Session cookies: These temporary cookies expire and are automatically erased whenever you close your browser window. We may use session cookies to grant you access to content and to enable actions you must be logged in to do.
Persistent cookies: These usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We may use persistent cookies to better understand your use patterns so we can improve the Website. For example, we may use a persistent cookie to associate you with your user account or to remember that your choices on the Website, but this only works when cookies on our site are enabled.
We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.
How Personal Information May Be Shared
- We may disclose information to our subsidiaries and affiliates.
- We may disclose information that we collect about you to our third-party contractors and payment processors who perform services for us in connection with the Website, or to complete or confirm a transaction or series of transactions that you conduct with us.
- We may also disclose information to service providers or suppliers if the disclosure will enable that party to perform business, professional or technical support for us, including, for example, survey administration, processing of application information, marketing partners, analytics services and research services; these providers are permitted to use the information in order to provide the services to us but are not permitted to use the information for their own unrelated purposes.
- We may disclose information about you as part of a merger, acquisition or other sale or transfer of the assets or business of Cubex.
- We may be legally obligated to disclose information about you to the government or to third parties under certain circumstances, such as in connection with illegal activity on the Website, or to respond to a subpoena, court order or other legal process. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.
- We may share aggregated or anonymous information that does not identify you with third parties. For example, we may disclose the number of visitors to the Website or the number of people who have downloaded a particular document.
Opting Out of Communications
If you do not want Cubex to share your information with any of its approved partners, sponsors, or other relevant third parties, please contact us at the email or phone number listed below under Contact, and state your request along with your first and last name, email and postal address and phone number. We will make every effort to process all such requests within thirty (30) days.
If you no longer want to receive promotional emails from Cubex on a going-forward basis, you may opt out of receiving emails by clicking the “unsubscribe” link at the bottom of those email you receive or, if you have an online account, you may log in to your account and make changes to your communication preferences. If you are having difficulty unsubscribing using the above methods, please contact us directly at the email or phone number listed below under Contact. Please allow ample time for us to process your request. However, please note that even if you opt out from receiving promotional emails, we will continue to send you service-related communications and may need to keep information we have collected about you for record-keeping, research and other purposes.
Links to Other Websites
This Website is not intended for children under the age of 13. If you are under 13 years of age, please do not use or access this Website at any time or in any manner. By using this Website, you affirm that you are over the age of 13. Cubex does not seek through this Website to gather personal information from or about persons under the age of 13.
California Privacy Rights
Under California law, a California resident with whom we have an established relationship has the right to request certain information with respect to the types of personal information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be in writing and sent to us at the mailing address set forth below.
Access from Outside North America
If you access the Website from outside of North America, information that we collect about you will be transferred to servers inside North America and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area. By allowing us to collect information about you, you consent to such transfer and processing of your data.
IV. OTHER PRIVACY
You may provide personal information to us other than on or through the Website. Aside from through the Website, other ways we collect personal information include via email, telephone, facsimile, postal mail, or in person. If we use any information on or through the Website that we collected other than on or through the Website, the Website Privacy terms, above, will apply in their entirety to the use of such information. If personal information you have provided is not used on or through the Website, then the only sections of the Website Privacy terms above that will apply to the use of such information are: “Use and Retention of Information You Provide,” “How Personal Information May Be Shared,” “Governing Law,” and “Contact.”
Cubex LLC (“Cubex”, “we”, “us”, “our”) has adopted and instituted the following procedures and policy related to any Biometric Data that may be collected as a result of our customers’ and their respective employees’ or agents’ use of the Cubex products and services. Cubex customers are responsible for developing and complying with their own Biometric Data collection, use, storage, retention and destruction procedures and policies as may be required under any and all applicable laws and regulations.
Biometric Data Definition
“Biometric Data” means any biological characteristics of a person, or information based upon such a characteristic, including, without limitation, characteristics such as those defined as “biometric identifiers”1 and information such as that defined as “biometric information”2, in each case under the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq or any other similar characteristics or similar information under any comparable law or regulation.
- See Exhibit A
- See Exhibit A
Collection, Storage, Use, Retention, Destruction and/or Transmission of Biometric Data
Cubex customers are responsible for compliance with any and all applicable laws and regulations governing any collection, storage, use, retention, destruction and/or transmission of Biometric Data they conduct, possess or facilitate. Cubex customers agree to obtain the prior valid written consent of applicable third party users of Cubex products and services in order for such third party user to use the fingerprint scanner device of the Cubex inventory management devices (or any other device that is part of the Cubex products and services that collects Biometric Data), which consent shall provide legal and valid authorization for the customers, Cubex and/or Cubex’s authorized vendors to collect, store, retain, use, and/or transmit Biometric Data.
Cubex’s standard operating procedure does not call for the collection, storage, use, retention or transmission of Biometric Data by Cubex. Cubex products and services (i.e., the inventory management system and related software) provided to customers by Cubex, allow for the collection, storage, use and retention of any and all Biometric Data to be maintained and isolated on each individual physical product device (i.e., the Biometric Data is not transmitted to any other device or store on the cloud or otherwise stored, used or retained elsewhere). If, however, Cubex and/or its vendors do at any time collect, store, use, possession, retain and/or transmit Biometric Data during the course of conducting Cubex’s operations and of providing products or services to Cubex’s customers and their respective employees and agents (i) the collection, storage, use, retention and/or transmittal of any Biometric Data will be for the sole purpose of identity verification; and (ii) Cubex customers agree to obtain written authorization from each applicable individual prior to the collection of such data on Cubex’s and its vendors’ behalf.
Cubex does not sell, lease or trade any Biometric Data that is received from customers or customer employees or agents as a result of their use of Cubex products or services. Cubex customers also shall agree not to sell, lease or trade any Biometric Data that is received from customers or customer employees or agent as a result of their use of Cubex products or services.
Inventory Management Devices and Attached Scanners
Cubex customers agree that, in light of the developing nature of the legal landscape and requirements that may apply to the collection, use and storage of Biometric Data, to the extent that such customers and their employees and agents use the fingerprint scanner device of the Cubex inventory management devices (or any other device that is part of the Cubex products and services made available to customers that collects Biometric Data), Cubex customers agree and have the responsibility to:
- Generally, comply with all applicable laws and regulations regarding Biometric Data;
- Inform any participating employee or agent in writing that Biometric Data is being collected, stored, and used;
- Provide the specific purpose(s) for collecting Biometric Data and indicate the length of time for which the Biometric Data will be collected, stored, and used;
- Indicate to participating employee or agent the manner in which the Biometric Data will be destroyed; and
- Receive a prior written consent from each participating employee and/or agent authorizing the customer, to collect, use, store, and transmit the participating employee’s and/or agent’s Biometric Data.
Cubex will not disclose, disseminate and/or transmit any customer’s employees’ or agents’ Biometric Data to any person or entity other than the customer and Cubex’s authorized vendors without or unless:
- First obtaining the customer’s employee’s written consent;
- Disclosure is required by state or federal law; or
- Disclosure is required pursuant to a valid warrant or subpoena.
Retention Schedule and Destruction
Cubex inventory management devices locally maintain all Biometric Data collected by the device. Each device contains a hard drive that securely stores the Biometric Data collected for purposes of individual verification.
While unlikely, if, at any point, after obtaining the proper authorization from each applicable employee and/or agent of a Cubex customer, any Biometric Data is shared with Cubex during the course of a customer’s term of use of a Cubex device, Cubex will securely retain the Biometric Data until the customer notifies Cubex that it has terminated the employee or agent or the employee or agent has discontinued using the applicable Cubex device, or the customer’s employee or agent makes a written request to Cubex that such Biometric Data be destroyed. At that time, any and all Biometric Data in Cubex’s possession will be destroyed.
Customer’s User Opt-Out Option
All Cubex customers and customer’s employees and agents understand that providing Biometric Data is not required to gain secure access to any of Cubex’s inventory management devices and he or she is free to decline to provide Biometric Data and can be provided with a secure PIN for access to the Cubex inventory management device. Additionally, any customer employee or agent may revoke consent to the collection of his or her Biometric Data at any time by notifying his or her employer or agent in writing. Upon written revocation, the customer employee will be provided a PIN to access the Cubex medicinal storage solution device.
The Illinois Biometric Information Privacy Act, in relevant part, currently provides “Biometric identifier” means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include donated organs, tissues, or parts as defined in the Illinois Anatomical Gift Act or blood or serum stored on behalf of recipients or potential recipients of living or cadaveric transplants and obtained or stored by a federally designated organ procurement agency. Biometric identifiers do not include biological materials regulated under the Genetic Information Privacy Act. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. Biometric identifiers do not include an X-ray, roentgen process, computed tomography, MRI, PET scan, mammography, or other image or film of the human anatomy used to diagnose, prognose, or treat an illness or other medical condition or to further validate scientific testing or screening.
The Illinois Biometric Information Privacy Act, in relevant part, currently provides “Biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers.