Privacy Policy

1. What Information Do We Collect?

In short: we collect the information you give us, plus some technical information collected automatically when you use our Site. Information you give us. We collect personal information that you voluntarily provide when you register on the Services, place an order or request a quote, apply for a business credit account, contact us, or take part in activities on the Site. Depending on what you do, this may include:

• Names and job titles
• Company names and business details
• Phone numbers and email addresses
• Billing and shipping addresses
• Usernames and passwords
• Order details and purchase history
• Payment information, such as card details or bank transfer details
• Tax documents you send us, such as a resale certificate
• Information you send during order verification or customer support

Payment data. When you pay by card, your payment details are handled by our third-party payment processors and are used only to complete your transaction. Please review the privacy notice of the processor shown at checkout for how they treat your data. Sensitive information. We do not process sensitive personal information. All information you give us must be true, complete and accurate, and you must tell us if it changes. Information collected automatically. When you visit or use the Services, some information is collected automatically. It does not directly reveal who you are (like your name), but it helps us keep the Site secure and working and understand how it is used. It includes:

• Log and usage data: IP address, browser type and settings, pages and files viewed, searches,

time stamps, features used, and error or crash reports.

• Device data: information about the computer, phone or tablet you use, such as device and

application identifiers, operating system, hardware model, internet provider or mobile carrier, and system configuration.

• Location data: the approximate location of your device, usually based on your IP address. If you

use device settings that share precise location, we may collect that as well. You can decline by turning off location access on your device, though some features may then not work. Information from third parties. We may receive limited information from payment processors, shipping carriers and fraud-prevention services when needed to complete, deliver or protect your order, for example confirmation that a payment cleared or that a delivery address is valid.

2. How Do We Process Your Information?

In short: we process your information to provide, improve and administer our Services, communicate with you, prevent fraud and comply with the law. We may also process it for other purposes with your consent. Depending on how you use the Services, we process your personal information for these purposes:

• To create and manage accounts, including business credit accounts, so you can sign in and keep

your account working.

• To fulfill and manage orders, including payments, shipping, returns, exchanges and warranty

claims.

• To respond to you, including quote requests, sales questions and customer support.
• To communicate with you about your orders and account, and, where permitted, to send you

offers and updates about our products. You can opt out of marketing at any time.

• To protect our Services and customers, including fraud prevention, order verification, credit

review and security monitoring.

• To improve our Site and catalog, by analyzing how the Site is used.
• To meet legal obligations, such as tax, accounting and recordkeeping requirements, and to

enforce our Terms and Conditions.

• To protect someone's vital interests, such as when needed to prevent harm.

3. What Legal Bases Do We Rely On?

In short: we process your personal information only when we have a valid legal reason, such as your consent, a contract with you, a legal obligation, or our legitimate business interests. If you are in the EU or UK, data protection law (GDPR and UK GDPR) requires us to name the legal bases we rely on:

• Consent. You have given us permission to use your information for a specific purpose. You can

withdraw consent at any time.

• Performance of a contract. We need your information to provide our Services or to take steps

you request before entering a contract.

• Legitimate interests. We process information for our legitimate business interests, such as

preventing fraud, keeping our Services secure and improving them, where these are not outweighed by your rights.

• Legal obligations. We need to comply with the law, for example by cooperating with a regulator

or law enforcement body, or by defending our legal rights.

• Vital interests. We need to protect your vital interests or those of another person.

If you are in Canada, we process your information with your express consent or, where appropriate, your implied consent, and you can withdraw consent at any time. In limited cases the law allows us to process information without consent, including for investigations and fraud detection and prevention, when collection is clearly in an individual's interest and consent cannot be obtained in time, to comply with a subpoena or court order, for certain business transactions, or where the information is publicly available as specified by regulation.

4. When and With Whom Do We Share Your Personal Information?

In short: we do not sell your personal information. We share it only in the situations below, and only as needed.

• Service providers. We share information with companies that help us run our business under

written agreements, such as payment processors, shipping carriers, fraud-prevention and credit-review providers, website hosting and analytics providers, and email or customer-support tools. They may use your information only to perform services for us.

• Legal and safety reasons. We may disclose information to comply with the law, respond to

lawful requests from authorities, enforce our Terms and Conditions, protect our rights, customers or the public, or investigate fraud.

• Business transfers. We may share or transfer information in connection with a merger, sale of

company assets, financing or acquisition of all or part of our business.

• With your consent. We may share information for other purposes if you ask us to or agree.

We may also use information that does not identify you, such as combined usage statistics, for our own business purposes, including internal research and improving our Services. This is not a sale of personal information.

5. Do We Use Cookies and Other Tracking Technologies?

In short: yes, we may use cookies and similar technologies to keep the Site working and to understand how it is used. We and our partners may use cookies, web beacons, pixels and similar technologies to remember your cart and preferences, keep you signed in, secure the Site, and measure traffic and performance. Most browsers accept cookies by default, but you can set your browser to remove or reject them. If you do, some parts of the Site, such as the cart or checkout, may not work properly.

6. How Long Do We Keep Your Information?

In short: we keep your information only as long as we need it for the purposes in this notice, unless the law requires or permits longer. We keep personal information for as long as you have an account with us, as needed to provide our Services, and as required for tax, accounting, warranty and other legal purposes. When we no longer have a legitimate need to process your information, we delete or anonymize it. If that is not possible, for example because it sits in backup archives, we store it securely and keep it away from further use until deletion is possible.

7. How Do We Keep Your Information Safe?

In short: we use organizational and technical safeguards to protect your personal information. We have put in place reasonable technical and organizational measures designed to protect the personal information we process. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise that hackers, cybercriminals or other unauthorized parties will never defeat our safeguards and improperly access, collect, steal or change your information. Sending information to and from our Services is at your own risk, so please use the Services only in a secure environment.

8. What Are Your Privacy Rights?

In short: depending on where you live, you may have rights over your personal information. You can review, change or close your account at any time. In some regions, including the European Economic Area (EEA), the United Kingdom, Switzerland and Canada, data protection law gives you rights that may include:

• Access to your personal information and a copy of it
• Correction or erasure of your information
• Restricting how we process it
• Data portability, where it applies
• Not being subject to automated decision-making
• Objecting to processing in certain situations

To make a request, contact us using the details in Section 14. We will review and act on your request in line with applicable law. If you are in the EEA or UK and believe we are processing your information unlawfully, you can also complain to your local data protection authority. If you are in Switzerland, you can contact the Federal Data Protection and Information Commissioner. Withdrawing consent. Where we rely on your consent, you can withdraw it at any time by contacting us or updating your preferences. This does not affect processing that happened before you withdrew, or processing based on other lawful grounds. Opting out of marketing. You can unsubscribe from marketing emails at any time using the unsubscribe link in the email, or by contacting us. We may still send you service messages needed to run your account or fulfill your orders. Account information. To review or change your account information, or to close your account, you can sign in and update your account settings or contact us. When you ask us to close your account, we will deactivate or delete it from our active databases. We may keep some information to prevent fraud, troubleshoot problems, assist with investigations, enforce our Terms and Conditions and meet legal requirements. Cookies. You can usually set your browser to remove or reject cookies, as described in Section 5.

9. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") setting that lets you signal that you do not want your online browsing activity monitored. No uniform standard for recognizing DNT signals has been finalized, so we do not currently respond to DNT signals or any other mechanism that automatically communicates your choice not to be tracked. If a standard is adopted that we must follow, we will explain how in an updated version of this notice.

10. Do United States Residents Have Specific Privacy Rights?

In short: if you live in California, Colorado, Connecticut, Texas, Utah or Virginia, you may have specific rights over your personal information. Categories of personal information we collect. In the past twelve months we have collected the following categories: Category Examples Collected A. Identifiers Name, postal address, phone Yes number, email address, account name, IP address, online identifier B. Customer records (California Name, contact details, financial Yes Customer Records statute) information C. Protected classifications Gender, date of birth No under state or federal law D. Commercial information Orders, purchase history, Yes payment details E. Biometric information Fingerprints, voiceprints No F. Internet or similar network Browsing and search activity, Yes activity interactions with our Site G. Geolocation data Approximate device location Yes H. Audio, electronic, visual or Images, audio or call recordings No similar information I. Professional or Business contact details, job Yes employment-related title information J. Education information Student records No Category Examples Collected K. Inferences drawn from other Profiles of preferences or No information characteristics L. Sensitive personal None collected No information We keep these categories for as long as you have an account with us or as needed for legal, tax and warranty purposes. We may also collect other personal information when you interact with us in person, online, by phone or by mail, for example when you contact customer support, take part in surveys, or ask us questions. How we use and share your information. Section 2 explains how we use personal information, and Section 4 explains when we share it. We disclose personal information to service providers under written contracts. We have not sold or shared personal information with third parties for a business or commercial purpose in the past twelve months, and we do not plan to. California residents.

• Shine the Light law. California Civil Code Section 1798.83 lets California residents ask us, once a

year and free of charge, which categories of personal information we disclosed to third parties for direct marketing and the names and addresses of those third parties. To make a request, write to us using the contact details in Section 14.

• Minors. If you are under 18, live in California and have a registered account, you may ask us to

remove content you posted publicly on the Services. Contact us using the details in Section 14 with the email address on your account and a statement that you live in California. Please note that the content may not be completely removed from all of our systems, such as backups. California Consumer Privacy Act (CCPA) notice. This part applies only to California residents. You have these rights:

• Right to delete. You can ask us to delete your personal information, subject to legal exceptions,

such as legal compliance requirements or protection against illegal activity.

• Right to know. You can ask whether we collect and use your personal information, the categories

and purposes, whether we sell or share it, the categories of third parties involved, and the specific pieces of personal information we hold about you.

• Right to correct inaccurate personal information.
• Right to opt out of the sale or sharing of your personal information. We act on opt-out requests

as soon as feasible and no later than 15 days after we receive them.

• Right to non-discrimination. We will not treat you differently for exercising your privacy rights.
• Right to limit use of sensitive personal information. We do not process sensitive personal

information. You may also object to our processing of your information, ask us to restrict it, and appoint an authorized agent to make a request for you. We may deny a request from an agent who does not provide proof of authorization. Verification. Before we act on a request, we need to confirm that you are the person the information relates to. We will match details you give us with information we already hold, or contact you using a phone number or email address we have on file. We use the information in your request only to verify your identity or authority, and we delete any additional information you provide for verification as soon as we finish. To make a request, email [email protected] or call (903) 677-4333.

11. Rights of Residents of Texas, Colorado, Connecticut, Utah and Virginia

These rights apply only to residents of the named state and only to personal data used in an individual or household context, not in a commercial or employment context. They are not absolute, and in some cases we may decline a request as the law permits. To make any request below, email [email protected] or call (903) 677-4333. Texas residents (Texas Data Privacy and Security Act). You have the right to:

• Confirm whether we are processing your personal data and access it
• Correct inaccuracies in your personal data
• Delete personal data you provided or that we obtained about you
• Obtain a copy of your personal data in a portable format
• Opt out of the processing of your personal data for targeted advertising, the sale of personal

data, or profiling that produces legal or similarly significant effects We respond within 45 days of receiving a request, and may extend that once by 45 days when reasonably necessary, telling you why. If we decline your request, you may appeal by emailing us. We will tell you in writing of the outcome of your appeal within 60 days. If you are not satisfied, you may submit a complaint to the Texas Attorney General. Colorado residents (Colorado Privacy Act). You have the right to be informed whether we process your personal data, to access it, to correct inaccuracies, to delete it, to obtain a copy of data you shared with us, and to opt out of targeted advertising, the sale of personal data, or profiling that produces legal or similarly significant effects. If we decline your request, you may appeal by emailing us. Within 45 days of receiving your appeal, we will tell you in writing what action we did or did not take and why. Connecticut residents (Connecticut Data Privacy Act). You have the same set of rights as Colorado residents. If we decline your request, you may appeal by emailing us. Within 60 days of receiving your appeal, we will tell you in writing what action we did or did not take and why. Utah residents (Utah Consumer Privacy Act). You have the right to be informed whether we process your personal data, to access it, to delete it, to obtain a copy of data you shared with us, and to opt out of targeted advertising or the sale of personal data. Virginia residents (Virginia Consumer Data Protection Act). You have the same set of rights as Colorado residents. You may use an authorized agent, and we may deny a request from an agent who does not give proof of authorization. We may ask for additional information reasonably needed to verify you. We respond within 45 days of receiving a request, and may extend that once by 45 days when reasonably necessary, telling you why within the first 45 days. If we decline your request, you may appeal by emailing us. Within 60 days of receiving your appeal, we will tell you in writing what action we did or did not take and why. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

12. Do We Collect Information From Children?

Our Services are intended for adults, and we do not knowingly collect personal information from children under 13. If you believe a child has given us personal information, please contact us at [email protected] and we will delete it.

13. Do We Make Updates to This Notice?

In short: yes, we update this notice when needed to keep it accurate and compliant with the law. We may update this notice from time to time. The updated version will carry a new "Last updated" date and takes effect as soon as it is posted. If we make material changes, we may notify you by posting a prominent notice or by contacting you directly. We encourage you to review this notice regularly.

14. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, or want to exercise a privacy right, contact us: Cube Devices Corp, doing business as Bulk Devices 13207 Lone Creek, Pearland, TX 77584, United States Email: [email protected] Phone: (903) 677-4333, Monday to Friday, 8:00 am to 5:00 pm (EST)

15. How Can You Review, Update or Delete the Data We Collect From You?

Depending on the laws that apply to you, you may have the right to access the personal information we collect from you, change it or delete it. To make a request, email [email protected] or call (903) 677-4333. We may need to verify your identity before we act on your request.