Privacy & Security

The website tubit.com (the “Website”), the application Tubit (the “App”) and any related features (hereinafter, the “Services”, “Tubit”, or “We”) value the privacy of all of our users. We have established this Privacy Policy to show commitment to these rights and to safeguard your privacy. If you use our website, application or services, we urge you to read this Privacy Policy and become fully informed about how it affects your personal privacy. Please refer to this Privacy Policy to find out how to contact us if you have any questions about the content.

  1. Privacy Policy
  2. Types of personal data collected
  3. The use of the personal data
  4. The grounds for the processing the personal data
  5. The sharing of the personal data
  6. Age restriction
  7. Retention time and deletion of personal data
  8. Data Subject rights
  9. Push Messages, Promotional emails
  10. Security
  11. Right to lodge a complaint
  12. Changes to this privacy policy
  13. Data controller contact information

  1. Privacy Policy

    This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share. It applies whenever you visit our Website, our App, or otherwise use or access our Services.
    You are not legally required to provide us with any Personal Information, but we need it to provide you with the full range of the best experience of using our Services.
    You should always understand the privacy policies of any website when supplying information during your use.

  2. Types of personal data collected

    We collect personal data when you use or register on Tubit. It is possible to browse our website without registering, but you must register to use certain features and services we offer.

    Registration information

    Providing your Name, Surname, date of birth and email address is a prerequisite for concluding the contract; otherwise, we cannot offer you access to the Service. By registering for our Service, you will provide and share your personal data with other users. Anyone can see something public. For example, your name, status “live”, photo, number of followers, and number of diamonds earned.

    This personal data is available to the public to help connect you with other website users.

    During registration via Apple (“Sign in with Apple”)

    If you register or sign in with your Apple ID, you give Apple permission to share your Apple login, name (you can edit that), surname and email. This email address will be linked to your Tubit account and used to retrieve your Tubit account.

    During registration via Google

    When you sign in with your Google account, you will permit Google to share your name, surname, photo, email, birthday and gender with us. This email address will be linked to your Tubit account and used to retrieve your Tubit account.

    During registration via Facebook

    When you sign in to our Service using your Facebook account, you permit Facebook to share your name, surname, email, birthday, gender and profile picture with us.

    We will use personal data to form your Tubit account. If you remove the Tubit app from your Facebook settings or your Apple ID, we will no longer have access to this data. However, we will still have the personal data we received when you first set up your Tubit account using your Facebook or Apple ID (you must delete your Tubit account entirely for us to no longer have access to this data).

    Personal data you provide us when you use our services or register for an account with us:

    • we collect data about you when you register an account, create or change your profile, set preferences, register or make purchases through the Services. This personal data could include the following: name, photo, date of birth and other information to your profile information, your contact and transaction data.
    • we collect and store content you post, send, receive and share. This content includes any information about you that you may have: photos, user-to-user communications, chats, or feedback you provide or when you participate in any interactive features, surveys, contests or promotions.
    • we collect data about you when you provide through our support channels: information regarding a problem you are experiencing with a Service and any other documentation, screenshots or information that would help resolve the issue.
    • we collect transaction data: payment card details, coins, method of coins replenishment, transaction date, transaction ID, provider payment ID, transaction status and other information.

    Personal data we collect automatically and generate when you use our services or register for an account with us:

    • we collect data about your visit and your interaction with our services. This information includes the features you use, how you interact with other users, status, registration date, coins bought, date of last payment and use of services, and other information.
    • we collect data about the devices you use to access the Services. This device information includes your connection type and settings when installing, accessing, updating, or using our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, device model, manufacturer, User agent, platform, Software Development Kit version, User ID, time stamp Developer Key, application version, in-app events, and network status (WiFi/3G), Login source, application use, if the profile is linked to Apple/Google, crash data, and others information. We use your IP address, GPS, Bluetooth, or WiFi signals and/or country preference in order your location. How much of this information we collect depends on the type and settings of the device you use to access the Services.
    • we use cookies and other tracking technologies (e.g., device identifiers and pixels) to provide functionality and to recognise you. For more information, please see the Cookies Policy, which includes controlling or opting out of these cookies and tracking technologies.

    Personal data we collect from the third party:

    We receive information about you from service providers, which include financial services vendors (provide data for contesting transactions), marketing providers (give tags on the company and advertising activity), third-party communication applications (provide your public profile data in their apps), third party social network or login service (such as Google, Apple, Facebook).
    We receive information about you from other users when they provide us with information about you, including through user support or in connection with claims or disputes.

    In addition, you may provide us with your Avatar/Photo, a personalized graphical illustration that represents you. Please note that this information is optional; you may choose not to provide

  3. The use of the personal data

    We use your personal data to provide you with our services to comply with our legal obligations. This includes:

    • provision to use our Website, App or Service;
    • verification, moderation, confirmation, and control of your accounts and your activities on the Website or App;
    • provision of customer support to contact you regarding your account, resolve any dispute and respond to your questions and enquiries;
    • solutions technical issues, improvements existing and developing new product features;
    • promotion of our Website, App or Service;
    • personalise the user experience and allow us to deliver the type of content and product offerings in which you are most interested;
    • Solution of security issues;
    • ordering virtual goods;
    • process your payments and chargebacks;
    • provision of marketing information and special offers, and different kinds of notifications;
    • analytics, monitor and measure the performance of our marketing and advertising campaigns.
    • “push messages” from us within the app, even when you are not currently using the app. These will either contain messages that we send you as part of our Service, or they may contain advertising information.

  4. The grounds for the processing the personal data

    Our legal basis for collecting and using your personal data, as described in this Privacy Policy, depends on the data we collect and the specific context in which we collect it. Under Data protection laws, we must tell you our lawful basis for using your data. Please see that in the table below.

    Purpose of processing Data Source Legal basis
    To provide you with the Tubit service Name, Surname and email address You provide your name and email address, or we receive from Facebook, Google or Apple To perform a contract
    To facilitate networking opportunities Photo (optional, you may choose not to provide) You provide to us or via Facebook, Google, Apple Legitimate interest - to facilitate networking opportunities
    For age verification Date of birth You provide us, or via Facebook, Google, Apple Legitimate interest - to verify that You are not a child, minor or anyone under 18
    For identity verification and authentification purposes, prevent fraud and ensure the safety and security of Users Email, password or third-party social media authentication You provide us, or via Facebook, Google, Apple Legitimate interests - it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard site users.
    To take payments from you for services Payment card details You provide us To perform a contract
    To allow our Advertising Partners to serve targeted advertisements Advertising identifier associated with your device (Device ID), age and IP address We obtain your age from you or via Facebook, Google, or Apple, and the Device ID and the IP address from the device that you use to access the service Consent - as indicated by you in your Cookie Settings preferences and via your browser or device privacy preferences
    To serve advertisements to our Service users on third-party networks and measure the effectiveness of such ads Data about your visit to our Service and action took on those We obtain information from the device or browser that you use to access the Service Consent - as indicated by you in your Cookie Settings preferences and via your browser or device privacy preferences
    To send you marketing information about our events, offers and services Name, email address You provide us Consent (including soft-in)
    To respond to correspondence and queries that you submit to us Email address, IP address You provide us Legitimate interests - our legitimate interest is to respond to your requests to ensure quality user service and fix problems.
    To investigate and block Users for reported infringements of our Terms of Use User registration detail and device data You provide us, and we obtain information from the device or browser you use to access the Service. Legitimate interests - it is in our legitimate interests to prevent unauthorised behaviour to maintain the safety and integrity of our services.
    To block payment transactions as part of our anti-fraud procedures Name, IP address, email address, cardholder name, payments received, type of payment, user ID, country You provide your name, email address, and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our Service. Legitimate interests - it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services
    To defend legal claims, protect legal rights and protect people from harm This could include any information that is relevant to the issue This information may be obtained directly from you, from your device or third parties, Legitimate interests - it is in our legitimate interests to protect our legal rights, defend
    depending on the information involved legal claims and to protect our Users and third parties from harm

  5. The sharing of the personal data

    We may share the personal data you provide to us with other users. Your personal data may be transferred if we are involved in a merger, acquisition or asset sale.

    We may share the personal data that we collect with:

    • Affiliate;
    • our group of companies;
    • Systems and IT/IS solutions providers;
    • Hosting providers;
    • Payment processors;
    • Fraud prevention partners;
    • Marketing partners;
    • Companies through which we purchase and deliver gifts;
    • Lawyers.

    Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency), or it is necessary to detect, prevent and address fraud and other illegal activity, to protect ourselves, you and others, including as part of investigations.

    We may share personal data internally within our group of companies or with third parties for purposes described in this Privacy Policy. Personal data collected within the European Economic Area (“EEA”) may, for example, be transferred to countries outside the EEA. We utilise standard contract clauses approved by the European Commission to legitimise data transfers from the EEA to the United States and other countries.

    Data collected by Advertising Partners and other Service Providers may also be held outside the European Economic Area. We ensure that the data is adequately protected by ensuring that valid legal mechanisms are in place. If you want more information about the nature of the safeguards we have in place, please email dpo@tubit.com.

  6. Age restriction

    Children under 18 years of age are not allowed to use our website, and our services are not targeted at children under the age of 18. Tubit does not knowingly collect information about or market to children, minors or anyone under 18. If we become aware that a child, minor or anyone under 18 has registered with us and provided us with personal data, we will terminate that person’s registration and delete their Profile information from Tubit. If we delete a Profile because violated our no children rules, we may retain your email and IP address to ensure you do not try to get around our rules by creating a new Profile.

  7. Retention time and deletion of personal data

    Personal data is retained if you are a contract or consent duration party. In addition, we will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

    You may request the deletion of your account at any time through the My profile > Delete > Yes, I understand, let’s proceed > Delete Account > Yes, delete. Following such request with appropriate review by us, we will delete the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, we retain location, device, and usage data for these purposes for a reasonable period as may be necessary; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, we may be unable to delete your account, such as if there’s a balance on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, we will delete the account as described above.

  8. Data Subject rights

    Under Data protection laws, you have the following rights:

    • Right to be informed: what personal data an organization processes and why.
    • Right of access: you can request a copy of your data.
    • Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
    • Right to erasure: You can delete your data in certain circumstances.
    • Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
    • Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
    • Right to object: in certain circumstances (including where data is processed based on legitimate interests or for the purposes of marketing), you may object to that processing.
    • Rights related to automated decision-making, including profiling: there are several rights in this area where processing carried out solely automatically results in a decision that has legal or significant effects on the individual. In these circumstances, your rights include the right to ensure that there is human intervention in the decision-making process.

  9. Push Messages, Promotional emails

    You may receive “push messages” from us within the app, even when you are not currently using the app. These will either contain messages that we send you as part of our Service, or they may contain advertising information. You can stop receiving push messages or adjust your settings at any time by changing the configuration settings of your mobile device or in the Tubit app.

    When you register, you enter your email address, or we receive your email address from Apple/ Facebook/Google (if you register via a third-party login). Unless you opt-out, we will use this email address to send you different types of notifications, some of which may qualify as promotional emails. We send you information about the promotions and offers we have available by direct marketing or other modes of communication - if you’ve signed up for our communications or otherwise told us it’s ok. You can click the unsubscribe link at the bottom of each email you receive or email your request to us at support@tubit.com or by changing the settings in your profile.

  10. Security

    Tubit has implemented appropriate security measures to protect and prevent the loss, misuse, unauthorised access or disclosure and alteration of the information under our control, including your personal data. We use reasonable security measures to safeguard the confidentiality of your personal information. Tubit technical experts work hard to ensure your secure use of our site.

  11. Right to lodge a complaint

    You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you have an unresolved personal data collection, use, or disclosure concern we have not addressed satisfactorily. Data Protection Authority may decide to further investigate the matter. Tubit will always fully cooperate with any regulatory request.

  12. Changes to this privacy policy

    We reserve the right to replace, modify or amend this Privacy Policy at our own discretion. Changes to this Privacy Policy are effective when posted on this page. Please note the latest modification date at the bottom of the Privacy Policy.

  13. Data controller contact information

    The data controller of the website is Reilin Technologies Limited, located at Aglantzias, 62, EKATERINI NICOSIA BUSINESS CENTER, Flat/Office 109, Aglantzia, 2108, Nicosia, Cyprus.

    Data Controller has appointed an internal Data Protection Officer to contact you if you have any questions about this policy or data processing practices. Please direct your query to the data protection officer if you want to exercise your privacy rights. Data Protection Officer’s contact information is as follows: dpo@tubit.com.

    If you have any questions regarding this privacy policy, contact us via email at support@tubit.com.

Last updated April 14th, 2023