Last modified: March 2024
Cubico is committed to every individual’s right to privacy and complies with the local privacy laws applicable in the various countries in which we operate. These provide, amongst other things, that the data we hold about you should be processed lawfully and fairly; be kept up to date, where necessary, and not be retained for longer than is necessary; and be kept securely to prevent unauthorised access by other people. You have the right to see what is held about you and to correct any inaccuracies.
The following privacy policy applies to all Cubico group companies, which control and make use of information collected (“Privacy Policy”). It sets out how we manage personal information, including how we collect and use your personal information and the rights available to you. Please also refer to our cookie policy for information on what cookies are; what the cookies we use are for; and for options on how you can manage or delete them.
Any change to this Privacy Policy will be posted here and will be effective immediately. Cubico reserves the right to update and change this Privacy Policy from time to time in order to reflect any changes to the way in which we manage your personal information or any changes to applicable legal requirements.
Who are we and who is responsible for your personal information?
Cubico is a leading investor in, and developer, owner and operator of, global renewable energy projects. Headquartered in the United Kingdom, we also have offices and projects around the world including in Brazil, Colombia, Mexico, Uruguay, the United States, Greece, Italy, Spain, the United Kingdom and Australia.
If you are in Australia, the entity that is responsible for your personal information is Cubico Sustainable Investments Australia Pty Ltd (ACN 624 996 078) which can be contacted directly by mail at KPMG (Sydney), ‘Tower 3 International Towers Sydney’, Level 38 , 300 Barangaroo Avenue, Sydney NSW 2000.
What kinds of personal information do we collect and hold?
The information we collect and hold depends on how you or others within your organisation interact with us, and includes:
- Personal details such as name, the company you work for, address, email address, telephone number, job title etc.
- Your IP address, a string of numbers unique to your computer that is recorded by our web server when you request any page or component on this website. This information may be used to monitor your usage of this website.
- Payment details including security code numbers and other associated payment or billing information.
- Identification, background and financial verification information provided by you or collected as part of our business acceptance and ongoing monitoring processes
- Attendance details and records where you have attended meetings or events hosted by us.
- Marketing, communication preferences and related information.
- Cubico may also use information submitted by you in order to consider you for a position within Cubico, should you apply to Cubico in respect of a vacancy advertised on this website (see separate Recruitment Privacy Notice) or to answer your queries should you contact us with a question.
- Further business information provided in connection with a project or contract you are engaging with us on.
Sometimes we may also have access to and use personal information for individuals we are not directly engaging with. This information is managed in the same manner as any personal information we directly collect.
How do we collect personal information?
Cubico collects personal information in a number of different ways, including:
- Directly from you when you supply personal information to us.
- When you or your organisation engages with us.
- When you or your organisation accesses and uses our website or a website managed by us or in connection with one of our projects.
- When you attend a meeting or event hosted by us alone or together with one of our partners.
- When you or your organisation offers services to us.
- From third parties such as background screening services, authorities or public registers.
What purposes will we hold, use and disclose your personal information for and on what basis?
Generally, Cubico needs your personal information because it is necessary to:
- conduct our business (including the business of associated entities);
- otherwise engage with you, but only where these interests are not outweighed by your privacy interests; or
- comply with legal requirements applicable to Cubico.
Cubico may hold, use and disclose your personal information for the following purposes:
- Providing or receiving services or otherwise engaging with you as requested by you or your organisation.
- Managing and administering the relationship between Cubico and you or your organisation.
- In accordance with any global legal, compliance or other requirements (e.g. anti-money laundering laws, counter-terrorism laws, financial checks, crime prevention or trade sanctions).
- In accordance with our compliance policies and standards.
- To host meetings and events.
- To oversee and manage the people accessing our premises.
- For insurance, legal, tax or accounting purposes.
- To identify and verify contract counterparties and persons authorised to trade on behalf of you or your organisation.
- To comply with any laws, regulations, court orders or to protect and enforce our legal rights.
- To engage with you in relation to the collection and processing of your personal information as contemplated by this Privacy Policy.
- For any other purposes for which your personal information was provided to us or related to or ancillary to any of the above purposes.
We will only use your personal data when applicable law allows us to and, depending on the nature and purposes of processing being carried out, our basis for processing includes:
- Consent: you have given express consent for us to process your personal information for a specific purpose. Note that you have the right to withdraw your consent at any time.
- Pursuing our legitimate interest or those of a third party: the processing is necessary for the purposes of our legitimate interests or those of a third party, except where such interests are overridden by your interests, fundamental rights and freedoms which require protection of personal information.
- Complying with legal obligations: the processing is necessary to discharge a relevant legal or regulatory obligation to which we are subject.
- Performance of a contract: the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
How do we hold personal information?
Cubico may hold personal information on our technology systems, those of our contractors, suppliers or agents or in paper files. Cubico is committed to ensuring that any personal information we hold is secured in accordance with Cubico’s policies and procedures, including appropriate physical and technological security measures and cautious selection of third party service providers.
Are you required to provide us with, or allow us to use, your personal information?
Generally, you will provide us with your personal information on a voluntary basis. You have the option of not identifying yourself or of using a pseudonym when dealing with us, however, there may be circumstances where Cubico cannot undertake certain activities or engage with you further without access to and use of personal information. Where this occurs and you have not provided us with the required personal information or you choose to ask us to stop making use of your personal information, we will contact you to discuss further.
Who will we share your personal information with?
Cubico may share your personal information as necessary with third parties where such personal information is required by that third party to provide a service to us. This may include insurers, legal advisors, financial advisors, IT providers, background screening providers, accountants, tax advisers, auditors, building or site managers and operators, contractors, suppliers, agents, and government and regulatory bodies. Third parties will not be allowed to use your personal information for their own purposes.
We may also share non-personal aggregate statistics (group) data about our website’s traffic patterns with partners or other parties, however we do not sell or share any information about individual users for this purpose.
Will your personal information be shared overseas?
Due to the global nature of our business, Cubico may also be required to share your personal information overseas to other members of the Cubico group or to our contractors, suppliers or agents including in the United Kingdom, Brazil, Colombia, Mexico, Uruguay, the United States, Greece, Italy, Spain and Australia.
Some of the countries where your personal information is shared may not have data protection laws as strict as the country you are located in. In these cases, where Cubico transfers personal information to other members of the Cubico group or third party service providers acting on Cubico’s behalf, Cubico does so, as applicable, on the basis of agreements put in place to protect your information in a form approved for this purpose by the European Commission or UK Information Commissioner (as applicable) or otherwise in a manner which ensures a level of data protection at least as protective as that required in (as applicable) the UK, the European Economic Area and Australia.
What are your rights in relation to your personal information?
Depending on the country you are located in and subject to certain exceptions and legal conditions, you have various rights in relation to your personal information. These include:
- The right to request a copy of any information that we currently hold about you or to seek a correction of such information.
- In some circumstances you have the right to require us to delete (or stop making active use of) your personal information or restrict our use of your information, so that it can only continue subject to restrictions.
- The right to request that personal information you have provided is sent to you in a structured, commonly used and machine-readable format and have the right to transmit that data to another organisation. This can be done by providing details of your request to us, using the contact details provided;
- The right to make a complaint if you have any concerns about our management of your personal information. We will endeavour to respond to your request or complaint promptly; and
- The right to request a copy of this Privacy Policy in an alternative form, and we will take reasonable steps in these circumstances to give you a copy in that form.
We will use all reasonable endeavours to ensure that the information we hold is accurate, up to date and relevant and we will be happy to correct any inaccuracies.
If you wish to do any of this or if you have any questions or comments about our Privacy Policy, please contact the Communications Team at Cubico Sustainable Investments, Floor 11, 70 St Mary Axe, London, EC3A 8BE, United Kingdom or dataprivacy@cubicoinvest.com.
You may also have a right to lodge a complaint to the relevant data protection authority, which in the UK is the UK Information Commissioner (www.ico.org.uk) and in Australia is the Office of the Australian Information Commissioner (www.oaic.gov.au).