Cubiks uses certain Sub-Processors to assist in the delivery and support of its products and services.
A Sub-Processor is a third party processor engaged by Cubiks, including entities from inside Cubiks Group. A list of operating companies of the Cubiks Group can be found here. The Sub-Processor has or potentially will have access to process data (which may contain personal data) as described in the table below.
Cubiks undertakes a commercially reasonable selection process by which it evaluates the security, privacy and confidentiality practices of proposed sub-processors that will or may have access to or process Data.
Cubiks requires its sub-processors to satisfy equivalent obligations as those required from Cubiks (as a Data Processor) as set forth in Cubik’s Data Processing Agreement (“DPA”), including but not limited to the requirements to:
- Process Personal Data in accordance with the data controller’s documented instructions (as communicated in writing to the relevant sub-processor by Cubiks);
- In connection with their sub-processing activities, use only personnel who are reliable and subject to a contractually binding obligation to observe data privacy and security, to the extent applicable, pursuant to applicable data protection laws;
- Provide regular training in security and data protection to personnel to whom they grant access to Personal Data;
- Implement and maintain appropriate technical and organizational measures (including measures consistent with those to which Cubiks is contractually committed to adhere to insofar as they are equally relevant to the sub-processor’s processing of Personal Data on Cubik’s behalf) Cubiks reserves the right to audit the sub-processor on an annual basis or request certification of proof of the sub-processors security commitment;
- Promptly inform Cubiks about any actual or potential security breach; and
- Cooperate with Cubiks in order to deal with requests from data controllers, data subjects or data protection authorities, as applicable.
This policy does not give Customers any additional rights or remedies and should not be construed as a binding agreement. The information herein is only provided to illustrate Cubik’s engagement process for sub-processors as well as to provide the actual list of third party sub-processors, subcontractors and content delivery networks used by Cubiks as of the date of this policy (which Cubiks may use in the delivery and support of its Services).
SERVER LOCATION AND SECURITY
Cubiks Online is hosted in two data centres in the UK. From March 2019, it will be hosted within the EU on Microsoft Azure. Cubiks Connect and Connect API are hosted within the EU on Microsoft Azure. Full details on the compliance of Microsoft Azure is available here.
Bespoke Solutions are hosted in two data centres in the UK.
Office specific document servers are located in each country of operation. Backup servers are located in the UK.
Cubiks is ISO 270001 certified for Information Security Management (certificate number IS639040).
Sub-Processors and Trusted Third Parties
|Cloud Direct (On Direct Business Services Ltd)||Provides routine encrypted backup of Cubiks' PCs and servers. Cloud Direct and its employees do not possess the ability to decrypt the data.||https://www.clouddirect.net/legal/privacy-policy|
|Full Fat Things||Provide development services for the Cubiks websites across all countries. They have access to email and enquiry data (but not candidate or client data) submitted to Cubiks.com and the other websites of the Cubiks Group.||https://fullfatthings.com|
|HRNX LLC||A middleware provider used to connect Cubiks to other HR systems (ATS, HRIS, HCM, e-Learning and ERP). All HRNX middleware is hosted by Cubiks.||http://www.hrnx.com/privacy|
|Innovation Visual||Cubiks SEO (Search Engine Optimisation) consultants who have full access to the Cubiks website.||https://www.innovationvisual.com/services/privacy-policy|
|Microsoft Corporation||Cubiks use Microsoft Azure (European Region) for the hosting and delivery of Cubiks Online Solutions and storage of associated data. Office 365 is used internally across Cubiks.||https://www.microsoft.com/en-us/trustcenter/privacy/privacy-overview|
|Opensquare||Opensquare provides Cubiks with research services for semantic analytics.||https://opensquare.eu/en/mentions-legales|
|Real Group||Real Group provide Cubiks with an e-learning platform for PAPI-3 training and qualification, and stores data on Cubiks customers who undergo PAPI-3 training.||http://www.realgroup.co.uk/privacy-policy|
|Bytes||Manages cloud hosting services for Microsoft contracts and relevant support services.||https://www.bytes.co.uk/company/corporate-policies/gdpr-documents|
|Odoo||CRMS Platform, provides backup services and has very limited access required for support services.||https://www.odoo.com/privacy|
|Cubiks use Google for Email filtering and quarantine services.||https://policies.google.com/privacy?hl=en&gl=uk|
|Netpremacy||3rd party solutions provider that interacts with Google on Cubiks’ behalf.||https://www.netpremacy.com|
|Pulsant||Co-Location data centre. Provides rack space for Cubiks’ servers for both production. environments and Cubiks Internal systems.||https://www.pulsant.com|
CUBIKS GROUP SUB PROCESSORS, ASSOCIATES AND AGENTS
Cubiks Belgium SA/NV
Cubiks Management Consulting (Shanghai) Co Ltd.
Cubiks (Denmark) AS
Cubiks Finland Oy
Cubiks (France) SAS
Cubiks (Germany) GmbH
Cubiks (Hong Kong) Limited
Cubiks Malaysia Sdn Bhd
Cubiks (Netherlands) BV
Cubiks Norway AS
Cubiks Singapore Pte Ltd
Cubiks Sweden AB
Cubiks Limited (Dubai Branch)
Cubiks Limited (Abu Dhabi Branch)
Cubiks Limited (UK)
Cubiks USA Inc
AGENTS AND ASSOCIATES
Cubiks India (Quadrangle Consulting Services Pvt Ltd.) - www.quadrangleconsulting.org
Cubiks Morocco – www.idoine-maroc.com
Cubiks Poland – www.alta.pl
Cubiks Saudi Arabia – www.advanced-learning.com
Cubiks Spain – www.facthum.com
Cubiks Switzerland – www.plusvalue-evolution.ch
Cubiks Brazil – www.daconsulting.com
Cubiks Greece – www.zeleradvisory.com
Cubiks Hungary – www.careersolutions.hu
Cubiks Indonesia – www.qsirecruit.com
Cubiks Italy – www.exeoconsulting.com
Cubiks Russia – www.case-hr.com
Cubiks Singapore – www.leadconsulting.org
Cubiks South Africa – www.workdynamics.co.za
Cubiks Turkey – www.elemental-v.com
Cubiks France – www.balio-conseil.com
Cubiks Australia – www.davidsonwp.com
Last Updated January 2019.