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Privacy Policy

Version 1.0 – September/2024

We, CUBOS SOLUÇÕES EM TECNOLOGIA LTDA, registered under CNPJ/MF number 18.571.767/0001-36, hereinafter referred to in this policy as "Cubos Tecnologia" or "Cubos", understand the importance of your privacy and recognize the need for transparency regarding the processes of collecting and processing your personal data within our services.

Thus, this Privacy Policy (“Policy”) has been drafted in accordance with Law No. 13.709/2018 (“General Data Protection Law” or “LGPD”), Law No. 12.965/2014 (“Internet Civil Framework” or “MCI”) and other applicable laws, with the primary objective of providing information on how your personal data is handled, covering the following topics:

Important Definitions;
Our Role as Personal Data Processors;
What Personal Data We Collect, How, and for What Purposes;
Legal Grounds for Processing Personal Data;
Storage of Personal Data;
Security Measures Adopted;
Sharing of Personal Data;
Rights of Data Subjects;
Updates and Changes to the Privacy Policy;
Contact and Queries;
Competent Jurisdiction.

This Policy addresses the processing of personal data performed by Cubos within the context of the use of the QUIPU software by the Client, including:

Personal data of individual users who have an account/registered user on the QUIPU software and have access to the platform ("Registered Users");
Personal data of individuals participating in online meetings where the QUIPU software is being used ("External Participants");

The QUIPU software (“software” or “QUIPU”) is an artificial intelligence application that acts as an operational assistant for a sales team of an organization that contracts the use of the software (“Client”). It captures the transmission of online meetings, structures the captured data, and automates processes such as CRM entries, among others. It can also be used for general meetings with other content and purposes, utilizing the same capabilities. QUIPU also allows salespeople/online meeting participants and managers of these Client teams to ask questions and receive AI-generated responses about information and content discussed in the meetings.

Important Definitions

To clarify and better understand this Policy, we adopt the following definitions:

Personal Data: Any information related to an identified or identifiable natural person. Therefore, anonymized data is not considered personal data;
Sensitive Personal Data: Any personal data concerning racial or ethnic origin, religious beliefs, political opinions, trade union membership or membership in religious, philosophical, or political organizations, data related to health or sexual life, genetic or biometric data, when linked to a natural person;
Data Subject: The individual to whom the personal data relates;
Data Processing: Any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction;
Data Controller: The individual or legal entity responsible for decisions regarding the processing of personal data – in this Policy, the Controller is the Client;
Client: The legal entity that has contracted Cubos to provide the software and its services to Registered Users;
Data Processor: The individual or legal entity, public or private, that processes personal data on behalf of the Controller – in this Policy, the Processor is Cubos;
Sub-Processor: A data processor contracted by another data processor to assist in fulfilling the purposes established in this Policy;
Data Protection Officer (DPO): The individual or legal entity designated to act as the communication channel between the data processing entity, data subjects, the Brazilian Data Protection Authority (ANPD), and third parties in general;
Services: The provision of the QUIPU software and the necessary technical support for its use;
Registered Users: Individuals authorized by the Client to use a user account to access QUIPU for conducting meetings.

The Client is the data controller of the personal data processed by QUIPU in the normal operation of the software, including the name, voice/audio, automatically generated captions, and photograph/image of the meeting participants (Registered Users or External Participants), as well as information related to the content of conversations held during the meetings.

Cubos acts as a processor of this data processing, following the Client's instructions in accordance with this Privacy Policy.

This Policy includes two columns. The content in the left column should be considered for legal binding purposes, while the content in the right column is provided solely for interpretation facilitation.

Our Role as a Personal Data Processor

The decision to share Registered Users' access data with Cubos so that we can: i) allow Registered Users access to the services provided by the QUIPU software; and ii) store and process the information handled by the QUIPU software through Registered Users' actions is made by the Client. Therefore, the Client operates as the Controller of the personal data of Registered Users and External Participants due to the online meetings held using the QUIPU software.

Cubos, in turn, acts as the Processor of this personal data, as our services aim to meet the Client's demand by providing the functionalities of the software and processing the information collected by QUIPU. We process personal data on behalf of the Controller (Client) for the purposes they determine.

If you are using our services as a Registered User, the Client (the legal entity with which you have a legal relationship) is responsible for decisions regarding the processing of your data. In this case, exercising your rights should be directed to this organization. We are not responsible for processing decisions made by the Controller, which may be subject to a specific privacy policy.

In such situations, it is the Client's responsibility to:

Manage the purposes and legal grounds for personal data processing and provide transparency to the data subjects;
Set limitations on software usage by Registered Users; and
Receive and fulfill requests from data subjects or the National Data Protection Authority, as well as from any other direct or indirect public administration authority or entity.

Our role as a Processor is guided by proper care and security measures to protect the stored personal data.

Registered Users can hold online meetings with only other Registered Users or with External Participants. Since the Client is the Controller of the personal data of External Participants involved in such meetings, it is the Client's duty to instruct Registered Users to inform External Participants, during meetings, about the capture of personal data, the purposes of processing, and other necessary information to comply with LGPD requirements.

What Personal Data We Collect, How, and for What Purposes

As a Processor, we only conduct lawful processing as outlined in the QUIPU Terms of Use, as required by our Client upon contracting our services. This involves processing the collection, storage, access, and deletion of personal data at the Client's request.

To provide Cubos’ services, a Registered User, using the Google Chrome browser, installs an extension that enables the QUIPU software to integrate with the browser. Online meetings held via specific video conferencing platforms (e.g., Google Meet, Microsoft Teams) are accessed by the QUIPU software, which captures personal data through the Google Chrome browser and enables processing by Cubos.

QUIPU captures the automatic transcription of the meeting provided by the video conferencing platform used, and/or the meeting’s audio and its transcription, with the purpose of processing this information to understand what was discussed in the meetings by Registered Users and External Participants, whose personal data is processed.

The audio and/or transcription is also used to provide an online meeting summary, indicating the topics discussed, relevant information mentioned, and next aligned actions. The photograph/profile image of the connected user (if applicable) is also collected to generate the meeting summaries.

Additionally, QUIPU processes the transcription and/or meeting audio to evaluate the performance of the Registered User in conducting the sales meeting (or other types of meetings), considering a meeting model predetermined by the Client.

Finally, this data is also used as input for formulating questions by Registered Users (including those who did not attend the meeting but have access levels to view the meeting records and use this feature, as determined by the Client). These questions are answered by an AI system trained to respond to such inquiries about the meeting content.

Cubos has no control over the content produced by and made available to the Client (meetings conducted and the Registered Users or External Participants involved, the content of these meetings, transcriptions, participant images/photos, summaries, Registered Users' evaluations, questions, and answers about the meeting content). During meetings, Registered Users and External Participants may refer to personal data of the Registered Users and External Participants, as well as third parties not present in the meeting. This should only be done if they are authorized to do so within the context of the LGPD (which may even include processing sensitive data or data from children and adolescents, over which Cubos has no control).

The Client, as the Controller of the personal data included in the content produced by and made available to the Client through the use of QUIPU in meetings conducted by Registered Users, is responsible for defining the processing that will be performed after QUIPU makes this content available to the Client and its Registered Users. This includes the purposes and legal grounds for processing this personal data, which may be subject to the Client’s own privacy policy.