Cube Móvil respects your privacy and is committed to protecting your personal data. This privacy policy aims to inform you about: 

• how we use your personal data you may provide us, while you enquire, purchase, or use any of our products or services including accessing contents of this website, signing up to our communications or taking part in our surveys or competitions. 
• the legal principles and lawful basis in which we process your data.  
• your rights regarding your personal data and  
• other information related to the processing of your personal data that we would like to share with you. 

This privacy policy is provided in a layered format for your convenience of choosing the specific areas you are particularly interested in. 

Alternatively, you can find a summary of the privacy policy here.

We, Olamo Mobile S.L.U., operate in Spain with our registered office at Calle San Severo 26, piso Bajo, 28042, Madrid, Spain. We trade as Cube Móvil. We provide electronic communication services including national and international calls, texts, and data to customers. We are part of the Lyca Group of companies with diverse business areas. 

When we say, “we”, “us” or “our” in this policy, we are referring to the companies of the Lyca Group that participate in the processing of your data. 

Personal Data is any information about you from which you can be identified. However, it does not include data where your identity has been removed (it’s called anonymised data). 

We may collect, use, store and transfer different kinds of personal data which may be categorised as below: 

• Identity Data include your full name, date of birth, gender, language. 

• Contact Data include your correspondence address, email address, contact number. 
• Financial Data include your bank account and payment card details (which you provide to purchase products from us and make a payment directly to us, such as on our website). 
• Billing Data include your details about payments about the products and services you have purchased from us. 
• Technical Data include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, and platform you use to access our website. 
• Profile Data include your username and password, purchases made by you, your interests, and preferences. 

• Usage Data include information about how you use our website, products and services, top up records, call data records which include traffic data and location data. 
• Marketing and Communications Data includes your preferences in receiving marketing communications from us and other companies of the Lyca Group (as chosen and consented to) and your communication preferences. 
• Customer Care Data includes your feedback to us, survey responses and voice mail recordings when you contact us. 

We process your personal data to derive information so that we can make personalised offers to our customers. Such information does not directly or indirectly reveal your identity. However, if we combine or connect the derived information with your personal data, it may directly or indirectly identify you. So, we also process the derived information as personal data which will be used in accordance with this privacy policy. 

We obtain your personal data, directly and indirectly, when you: 

• Interact with our independent distributors, wholesalers, and retailers. 
• Interact with us when you provide your personal data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. 
• Purchase and use our products or services, or enquire about them; 
• Create an account on our website; 

• Subscribe to our services or communications; 
• Request marketing to be sent to you; 
• Enter a competition, promotion, or survey; or 
• Review our products and give feedback. 
• Download our app. 
• Access our website, using cookies. Please see our Cookie Policy for further details. 

In any case, you guarantee and are responsible for the accuracy, validity and authenticity of the personal data you provide us with, and you undertake to keep them duly updated. 

We use your personal data complying to all data protection laws and regulations, most commonly, in circumstances where: 

• we need to perform services under the agreed terms and conditions with you. 

• it is necessary for our legitimate interests in course of our business. 
• we need to comply with a legal or regulatory obligation. 

We have set out below, a description of all the ways and the lawful basis we use your personal data. In addition to your consent, legal, and regulatory purposes, we have also listed our legitimate interests including performance management, product offerings, market research where applicable, which may override your rights subject to the law.  

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. 

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of terms and conditions with you and where applicable, as required by law
To supply products and services to you including:  Managing payments Collecting money owed to us	(a) Identity (b) Contact (c) Financial (d) Billing	(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to recover sums owed to us)
To manage our relationship with you and administer your account which will include:  Notifying you about changes to our terms and conditions or privacy policy  Detecting and preventing crime and fraud  Asking you to leave a review or take a survey  Manage any concerns that you raise to our customer care department  Quality assurance and monitoring purposes  Intra-group data communications	(a) Identity  (b) Contact (c) Profile (d) Marketing and Communications (e) Customer Care (f) Usage	(a) Performance of terms and conditions with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to participate in a competition or complete a survey (non-promotional)	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of terms and conditions with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To market products and services to you To complete a survey (promotional)	(a) Identity (b) Contact (c) Marketing and Communications (d) Profile	(a) Legitimate interest to process marketing data (to grow our business) and consent for sending electronic marketing communications for new customers or reliance on existing customer relationship to send electronic marketing communications communications for new customers or reliance on existing customer relationship to send electronic marketing communications
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile	Necessary for our legitimate interests (to develop Cube Movil products/services and grow our business)
Profiling our customers	(a) Identity  (b) Contact  (c) Financial (d) Billing (e) Profile (f) Marketing and Communications (g) Customer Care (h) Usage	We profile our users based on our legitimate interest or customer’s consent. Profiling allows us to offer better services, tailored to the preferences of our customers, providing quality content, and personalised to their interests. The data will be processed for as long as you maintain your user account or object to the processing.

Profiling and automated decisions 

As described below, we may carry out customer profiling, taking into account all data provided by you. This profiling will consider, for example: 

• Your behaviour on the website, cookies, cursor movements, or your preferences and interests. 
• Behaviour when you receive our informative newsletters, such as, for example, which content you find interesting according to the number of newsletters you open and the frequency with which you open them. 
• Interaction you may have through other channels such as queries on our information channels, or contact. 

• Information you may provide us with through satisfaction surveys. 

We also inform you that, for some services, we may process your personal data using automated means. This means that certain decisions are taken automatically without human intervention, such as, for example, segmenting you according to whether you are interested in certain sections of the website or whether you may use other services that we may offer. 

Furthermore, when you accept to receive commercial communications, these may be adapted and personalised, according to the interests of the customers, either based on the products and services requested, or based on data that we can deduce or obtain from your browsing, interest in certain content, reaction to our communications, among others. This personalisation is partially automated, in the sense that we determine the parameters of the personalisation, but it is the technological platform that generates the customer profile. 

We may also process other data as a result of the interactions made by the customer through our website when accessing through their third-party user and password (Social Login): the user’s name, email, date of birth and geographical location, in addition to their likes on social networks when the customer consents and optionally, in order to offer a personalised experience related to the person’s “Likes”. 

Marketing 

You will receive marketing communications from us either if you have consented to receive them or purchased products or services from us, and in each case, you have not opted out of receiving that marketing. You will also receive marketing communications from other Lyca entities if you have consented to receive such communications on their Lyca products or services. Every communication either through email or text shall provide you with an option to opt-out/unsubscribe from such communications. 

What happens if you do not provide us with your personal data 

In those cases where we need to collect your personal data because we are required to do so by law or we need them to perform a contract or service with you, you should be aware that refusal to provide any mandatory data will prevent us from achieving the purpose for which it is requested. Unless specifically stated otherwise at the time of data collection, the personal data we request from you through this website, or any other input channel is mandatory and necessary for the purpose for which your data is being processed. 

You can also Contact our Customer Services Department to let us know your marketing preferences and whether you’re happy to hear from us by email, text, or telephone. 

• Call 3332 from Cube Móvil free of charges. 
• You can also dial +34 621153332 from another network or +34 621153332 from abroad. Call charges may vary depending upon network operators. 
• Alternatively, you can also email to ayuda@cubemovil.es or you can use the opt-out/unsubscribe from that you will find in each of the email or text marketing communications. 

We may have to share your personal data with the parties set out below for the purposes set out: 

• Other Lyca Group companies and associated enterprises who provide ancillary services such as IT Services, Customer Service support for the fulfilment of your orders and clarification of any of your queries. 
• Other Lyca Group companies where you have chosen to receive marketing communications from them on Lyca products and services other than Cube Móvil 
• External third parties who provide IT technical support services, data centre services and call centre support. 
• Regulators, judicial authorities and other law enforcement authorities who require reporting of processing activities in certain circumstances. 

In case we choose to sell, transfer or merge parts of our business, then the new owners may use your personal data in the same way as set out in this privacy policy. In the event that we or the new owners update the information regarding the processing of your personal data, such new information will replace this policy. 

We inform you that some of our data processors, such as, for example, IT service providers, may have access to the personal data you have provided us with. Where applicable, we require all these external third parties to respect the security of your personal data and to process it in accordance with the law. We do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. 

We transfer personal data to some of our service providers who are based outside the European Economic Area (EEA). Specifically, Cube Móvil uses a technical services provider based in India and Customer Service providers based in Morocco and Philippines. This constitutes processing of your personal data outside the EEA.  

Whenever we transfer your personal data out of the EEA, we ensure that a high degree of protection is afforded to it by following various safeguard measures so that there is no detriment to you. 

We take steps to ensure your privacy rights are at least as compliant with the requirements of EU law, including requiring appropriate security measures from such third parties, set out in a contract between us, to protect your personal data. 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those staff members or other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a strict duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable supervisory authority of a breach where we are legally required to do so. 

We retain your personal data only for the period it is necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal and regulatory requirements. 

Retention period for different category of your personal data varies and are subject to applicable laws, regulatory requirements and legal limitation periods, which are tabulated in our Data Retention Policy which you can request from us by Contacting our Customer Services Department. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case, we may use this information indefinitely without further notice to you. 

Subject to certain conditions under data protection laws where applicable, you have the following rights in relation to your personal data: 

• Right to obtain information about your processed data, the applicable legal basis (including what specific legal obligation entitles us to process your data) and right to have access to your personal data. 

• Right to rectification and to correct your personal data – This enables you to correct any incomplete or inaccurate data we hold about you, though we may need to verify the accuracy of the new data you provide to us. 
• Right to ask us to erase your personal data. 
• Right to object to the processing of your personal data. 
• Right to ask us to restrict the processing of your personal data. 
• Right to data portability of your personal data -This enables you to ask us to transfer your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. 

Note, however, that this right only applies to automated information for which you initially provided consent to be used to perform a contract with you. 

• Right to withdraw your consent to the processing of your personal data. 
• Right to inform us of your wishes regarding the storage, deletion and communication of your personal data to a third party upon your death. 

To exercise any of the rights set out above, please send your request to ayuda@cubemovil.es and we shall respond, in accordance with the regulations, within the stipulated timeframe. 

You may also reach out to our Data Protection Officer if you have any issues in enforcing your rights at DPO@lycagroup.com or writing to the following address: 

 

Data Protection Officer, 

LycaMobile UK Limited,

2nd Floor, Walbrook Building, 

195 Marsh Wall, 

E14 9SG London. 

 

Despite our best efforts, if any of your concerns remain unresolved, you may report them to: 

 

Agencia Española de Protección de Datos (“AEPD”) 

Address: C/Jorge Juan, 6, 28001 Madrid, Spain 

Telephone: +34 901 100 099/ +34 91 266 35 17 

Website: www.aepd.es 

 

We would, however, appreciate the chance to deal with your concerns first before you approach the supervisory authority, so please do contact us in the first instance. 

Cost for Data Access 

You are normally not required to pay any fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if we find your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

What we may need from you 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information, if required, in relation to your request to expedite our response. 

Time limit to respond 

According to GDPR, all legitimate requests are required to be completed within one month, before which we shall complete the request. However, if your request is particularly complex or you have made several requests it may exceed the said period. In this case, we shall notify you and keep you updated. 

You can reach out through our Customer Services Department on 3332 from any Cube Móvil Account or +34 621153332 from another telephone. 

You may also e-mail the Customer Services Department at ayuda@cubemovil.es or by completing the online enquiry form at www.Cubemovile.es

For compliance, enforcement and questions in relation to this policy, we have a appointed a data protection officer (DPO) who may be reached at DPO@Lycagroup.com. or writing to the following address: 

 

Data Protection Officer, 

LycaMobile UK Limited,

2nd Floor, Walbrook Building, 

195 Marsh Wall, 

E14 9SG London. 

Changes to the policy 

We update our privacy policy, time to time, to reflect the changes in data protection laws. 

Our website, app and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from any Child. 

If you are under the age of 14, we request that you do not provide us with your information and do not use our website and app. 

If you are a parent or guardian of a child under 14, please contact us if you are aware that your child has used our website or app or otherwise provided their information to us without your consent.  

We shall delete or otherwise cease processing your child’s personal information within a reasonable time to make sure that we do not contact you in the future.