Privacy Policy

1. Who we are

ComniCube Ltd (“ComniCube”, “we”, “us”, “our”) is a company registered in England and Wales. We operate the ComniCube messaging platform at comnicube.com and app.comnicube.com.

ComniCube Ltd is registered with the UK Information Commissioner’s Office (ICO) as a data controller. [ICO Registration Number: pending]

For questions about this policy or our data practices, contact us at privacy@comnicube.com.

2. Information we collect

We collect and process the following categories of personal data:

Account data: name, email address, company name, phone number, and password (stored as a hashed value) when you create a ComniCube account.

Billing data: payment card details (processed by Stripe — we do not store full card numbers), billing address, and transaction history.

Usage data: API calls made, messages sent and received, delivery statuses, campaign data, and feature usage within the platform.

Technical data: IP addresses, browser type, operating system, device identifiers, session tokens, and access logs.

Communications: email correspondence, support tickets, and chat messages sent to our team.

Customer contact data: where you upload or transmit phone numbers and contact details of your own customers for the purpose of sending messages, we process this data on your behalf as a data processor. Our obligations as processor are set out in our Data Processing Agreement.

3. How we use your information

We use the data we collect to:

• Provide, operate, and maintain the ComniCube platform
• Process your payments and manage your account
• Send service communications (receipts, security alerts, platform updates)
• Respond to support requests and enquiries
• Monitor platform security and prevent fraud and abuse
• Improve our services through aggregated usage analytics
• Comply with legal obligations and regulatory requirements
• Send marketing communications where you have given consent or where we have a legitimate interest (you may opt out at any time)

4. Legal basis for processing

Under UK GDPR, we process your personal data on the following legal bases:

Contract performance: processing necessary to provide the services you have contracted for — account management, message delivery, billing.

Legal obligation: processing required to comply with applicable law — financial record keeping, fraud prevention, regulatory compliance.

Legitimate interests: processing for our legitimate business interests where these are not overridden by your rights — security monitoring, service improvement, and direct marketing to existing customers for similar services.

Consent: where we rely on consent, you have the right to withdraw it at any time by contacting privacy@comnicube.com.

5. Data sharing and processors

We do not sell personal data. We share data only as necessary to provide our services:

AMD Telecom SA / Routee: our primary carrier infrastructure provider, which processes message delivery data.

Stripe Inc: payment processing. Data transferred under Stripe’s Privacy Shield-successor arrangements.

Cloud infrastructure providers: hosting and data storage within UK/EU data centres.

Professional advisers: lawyers, accountants, and insurers under confidentiality obligations.

Law enforcement or regulatory bodies when required by law.

A full list of sub-processors is available on request.

6. International transfers

Where personal data is transferred outside the UK or EEA, we ensure adequate protection is in place through appropriate safeguards (Standard Contractual Clauses or equivalent mechanisms) in accordance with UK GDPR Chapter V.

7. Data retention

Account data: retained for the duration of your account plus 6 years following closure (to meet statutory accounting obligations).

Message logs: retained for 90 days following delivery, then anonymised for aggregate reporting purposes.

Billing records: retained for 7 years to meet HMRC requirements.

Support communications: retained for 3 years following resolution.

8. Your rights

Under UK GDPR you have the right to:

• Access your personal data
• Correct inaccurate data
• Request erasure (“right to be forgotten”)
• Restrict processing
• Data portability
• Object to processing based on legitimate interests
• Not be subject to automated decision-making that produces legal or significant effects

To exercise any right, contact privacy@comnicube.com. We will respond within 30 days. You also have the right to lodge a complaint with the ICO at ico.org.uk/make-a-complaint.

9. Cookies

We use essential cookies to operate the platform (session management, security) and analytics cookies to understand usage (with your consent). See our Cookie Policy for full details.

10. Changes to this policy

We may update this policy from time to time. Material changes will be notified by email to registered users at least 14 days before taking effect. Continued use of our services constitutes acceptance of the updated policy.

11. Contact us

ComniCube Ltd
privacy@comnicube.com
[Registered address: pending]