1. Who We Are

Cubed Pay Limited (“Cubed Pay”, “we”, “us” or “our”) is based at:

1 Allied Business Center
Coldharbour Lane
Harpenden
AL5 4UT
United Kingdom

We are the data controller of your personal data under the UK General Data Protection Regulation (“UK GDPR”) and the Data Protection Act 2018.

2. What Personal Data We Collect

We may collect and process the following types of personal data:

• Information you provide to us, including: Name; Residential address; Email address; Telephone number; Date of birth; Identity documents; Employment status; Financial information; Account activity and transaction information
• Information collected automatically, including: IP address; Device and browser information; Pages visited; Session times; Cookies and analytics data

Further details are set out in our Cookie Policy.

3. Why We Collect Your Data

We process your personal data for the following purposes:

• To provide our services, including account access, transactions and customer support
• To meet legal and regulatory obligations, including anti-money laundering, fraud prevention and Know Your Customer checks
• To protect the security and integrity of our platform
• To improve our services and user experience
• To send marketing communications where you have given consent

Our lawful bases for processing include performance of a contract, legal obligations, legitimate interests and consent.

4. Sharing Your Data

We may share your personal data with:

• Third-party service providers who support our operations, including IT, compliance, customer support and payment infrastructure providers
• Fraud prevention and credit reference agencies
• Law enforcement, regulators or public authorities where legally required
• Affiliates, partners or selected third parties where you have provided consent

We only share personal data where necessary and with appropriate safeguards in place.

5. International Transfers

Where personal data is transferred outside the United Kingdom or European Economic Area, we will ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.

6. Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, including contractual, legal, regulatory, fraud prevention and legitimate business purposes.

When personal data is no longer required, we will securely delete or anonymise it.

7. Data Security

We use appropriate technical and organisational measures to protect personal data, including:

• Secure encrypted transmission
• Firewalls
• Access controls
• Internal policies and staff training
• Monitoring and security procedures

8. Your Rights

Under UK GDPR, you have the right to:

• Access your personal data
• Request correction of inaccurate data
• Request the deletion of your data
• Restrict processing
• Object to processing
• Request data portability
• Withdraw consent where processing is based on consent

Requests will normally be handled within one calendar month once your identity has been confirmed.

9. How to Contact Us

To exercise your rights or contact us about this Privacy Policy, please email: contact@cubed-pay.com

Or write to:

Data Protection Officer
Cubed Pay Limited
1 Allied Business Center
Coldharbour Lane
Harpenden
AL5 4UT
United Kingdom

You also have the right to lodge a complaint with the Information Commissioner’s Office if you are unhappy with how your personal data has been handled.

10. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be published on our website, and where changes are significant, we may notify users directly.

GDPR Notice – Summary of Key Rights and Legal Bases

• Lawful Bases for Processing: Cubed Pay Limited may process personal data under the following lawful bases:
• Performance of contract – to provide our services
• Legal and regulatory obligations – including AML, KYC and compliance requirements
• Legitimate interests – including fraud prevention, security and service improvement
• Consent – including marketing communications and optional cookies

Your Rights Under GDPR

You may exercise your data protection rights by contacting: contact@cubed-pay.com or by writing to our Data Protection Officer at the address listed above.