Last modified: May 2023
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.
1. 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, Portugal, 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.
2. 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, including:
- Personal details such as name, 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.
- 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.
3. 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.
4. 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.
5. 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.
6. What purposes will we hold, use and disclose your personal information for?
Cubico holds, uses and could 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.
- For any other purposes for which your personal information was provided to us or related to or ancillary to any of the above purposes.
7. Why are we collecting the personal information?
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.
If Cubico cannot lawfully manage personal information on the above or other permitted grounds under data protection laws or where we are otherwise required to do so, we may need to get your express consent.
8. 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.
9. 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, Portugal, 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.
10. 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 including 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 can also 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.
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.
You also have 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.
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).