Privacy Policy

Qubic3D ("Qubic3D", "we", "us", or "our") respects your privacy and is committed to protecting personal information that we process in connection with our services.

This Privacy Policy explains how we collect, use, disclose and protect information when you:

• visit our website at www.qubic3d.co.za or any related pages (the "Website");
• use the Qubic3D advertiser dashboard or tools;
• use our driver / fleet apps or tablet software; or
• otherwise interact with us (for example by email or at events).

If you do not agree with this Policy, you should not use our services.

1. Who we are and how to contact us

Qubic3D (Pty) Ltd

[Company registration number if you have it]

[Registered address – optional on website version]

Email: privacy@qubic3d.co.za / support@qubic3d.co.za

We act as the "responsible party" / "data controller" for personal information we collect and use for our own purposes (for example our Website, sales and advertiser relationships). For certain advertiser campaigns we may also act as a "processor" / "operator" on behalf of our customers.

2. Scope of this Policy

This Policy covers:

• visitors to our Website;
• prospective and current advertisers, agencies and partners;
• drivers and fleet owners participating in the Qubic3D network;
• in-vehicle tablets running Qubic3D content; and
• any other individuals whose personal information we process in connection with our business.

This Policy does not cover third-party websites, apps or platforms that link to or from our services. Those are governed by their own privacy policies.

3. What information we collect

3.1 Information you provide to us

We collect information you voluntarily provide when you:

• fill in "Book a campaign" or contact forms on our Website;
• create or use an advertiser account;
• sign up as a driver or fleet partner;
• communicate with us by email, phone or messaging; or
• respond to surveys, promotions or events.

This information may include:

• Identification & contact: name, surname, company name, role, email address, phone number, country or city.
• Account details: username, password, account preferences.
• Business details: company size, industry, campaign goals, budgets, billing information, VAT number.
• Driver / fleet details: full name, ID/passport number (if required by contract), vehicle registration, banking details for payouts, proof of address, and similar.
• Any other information you choose to share in free-text fields ("How can we help?", support tickets, etc.).

3.2 Information we collect automatically

When you use our Website or dashboard, we automatically collect certain technical information, such as:

• Device and browser information (type, version, OS, screen size).
• IP address and general location (e.g. city/region).
• Pages visited, links clicked, time spent, and other analytics events.
• Referring URL (how you arrived at our Website).

We collect this information through cookies, pixels and similar technologies (see section 7).

3.3 Information from in-vehicle tablets

When Qubic3D tablets are installed in vehicles, our software may collect:

• Playback events: what content was shown, when, and for how long.
• Presence signals: whether the tablet has detected that a person is present (see section 4).
• QR interactions: when a QR code displayed on the tablet is scanned and resolved (we collect technical info about the scan and destination; we do not usually know the identity of the rider unless they later provide it to us).
• Device status: battery level, storage, app version, connectivity, and basic diagnostics.
• Approximate location and movement: such as general route or area, where needed for campaign targeting and reporting (e.g. "campaign delivered in Sandton CBD").

We design our system so that information from tablets is aggregated and anonymised for reporting to advertisers; it is not used to build profiles of individual riders.

3.4 Information from third parties

We may receive information from:

• advertising agencies or brands that list you as a contact;
• fleet partners that provide driver details or vehicle information;
• payment providers and banks (for example, confirming that a payment was successful);
• event partners or conference organisers where you opted-in to share your details;
• publicly available sources such as LinkedIn or company websites.

4. Presence detection & camera use

Some Qubic3D tablets use presence detection to ensure that ads only play – and impressions are only counted – when a person is actually in the vehicle.

We know this is a sensitive area and we want to be very clear:

4.1 How presence detection works

• Presence detection uses the device's front-facing camera or similar sensor to check whether there is a person-shaped silhouette in front of the screen.
• The analysis is done in real time on the device itself using an algorithm (for example, a model that detects shape and motion).
• The system then produces a simple signal such as:
  • "person present / person absent", or
  • a count of how many "presence windows" occurred during a ride.

4.2 What we do not do

With presence detection, Qubic3D:

• does not capture, store or stream images or video of riders to our servers;
• does not save photo or video files on the tablet for later review;
• does not use facial recognition or identify who a person is;
• does not track or follow individual riders across different rides or vehicles.

In other words: the camera (or sensor) is used as a yes/no detector to unlock playback and count anonymous impressions, not as a surveillance or identification tool. Based on the way the system is designed, we cannot know who a particular rider is from presence detection alone.

4.3 What we record

What may be sent back to our servers is limited to non-identifying signals, for example:

• that an ad played while presence was "on";
• the number of valid presence windows per trip;
• aggregate impression counts per campaign, per day, per location.

We treat these signals as measurement and analytics data, not as personal profiles of riders.

We still disclose this processing here because we believe riders and advertisers deserve transparency whenever a camera or similar sensor is involved, even when the data never leaves the device as an image.

5. How we use information

We use the information described above for the following purposes:

1. Providing and operating the Qubic3D platform
   • Running the Website, advertiser dashboard, driver/fleet apps and tablet software.
   • Creating and managing user accounts.
   • Serving and optimising ad campaigns.
2. Campaign delivery, measurement and reporting
   • Delivering ads to the correct locations, vehicles and time windows.
   • Using presence detection signals to gate playback and count impressions.
   • Measuring QR scans and campaign engagement.
   • Providing anonymised or aggregated reports to advertisers and partners.
3. Driver & fleet management and payouts
   • Evaluating driver / fleet applications.
   • Tracking performance metrics (e.g. tablet uptime, route coverage).
   • Calculating incentives and payouts.
   • Complying with contractual and accounting obligations.
4. Customer support & communication
   • Responding to enquiries and support requests.
   • Sending service messages (for example, updates about campaigns, dashboard changes, or important system notices).
5. Marketing & business development
   • Sending communications about Qubic3D products, features, events or offers, where permitted by law.
   • Managing mailing lists and marketing preferences.
   • Analysing how prospects interact with our Website and content to improve our messaging.
6. Security, fraud prevention & legal compliance
   • Detecting and preventing fraud, abuse or misuse of our services (for example, attempts to "game" impressions).
   • Protecting the security and integrity of our systems and devices.
   • Complying with legal obligations, law enforcement requests, tax and accounting rules.
   • Enforcing our Terms of Use and other agreements.

We may also use anonymised or aggregated data for analytics, product development, forecasting and research. When data is anonymised, it can no longer be linked to an identifiable person.

6. Legal bases (where applicable)

Where data protection laws such as the Protection of Personal Information Act (POPIA) or the GDPR apply, we rely on one or more of the following legal bases:

• Performance of a contract – for example, when processing information to provide our services to advertisers, drivers or partners.
• Legitimate interests – such as operating and improving our platform, ensuring security, performing analytics and communicating with customers about our services, where these interests are not overridden by your rights.
• Consent – for certain types of marketing communications or where required by law for cookies and similar technologies.
• Legal obligation – where we need to retain or disclose information to comply with laws, court orders or regulatory requirements.

7. Cookies & similar technologies

We use cookies and similar technologies on our Website and dashboard to:

• remember your preferences and keep you signed in;
• understand how visitors use our pages;
• measure marketing and campaign performance;
• protect against fraud and abuse.

You can usually control cookies through your browser settings (for example, blocking or deleting them). However, disabling certain cookies may affect the functionality of the Website or dashboard.

If you operate in jurisdictions that require it, we may display a cookie banner and ask for your consent for certain non-essential cookies.

8. How we share information

We do not sell your personal information.

We may share information with:

1. Service providers and subprocessors

   Companies that help us operate our services, such as cloud hosting providers, analytics tools, payment processors, email delivery platforms, device management providers and customer support tools. These providers are only allowed to process data on our instructions and under appropriate contractual safeguards.

2. Advertisers, agencies and partners

   We share aggregated and anonymised campaign reports (impressions, presence-gated plays, QR scans, etc.) with advertisers and their agencies. We do not typically share identifiable rider information because we do not collect it from tablets.

3. Drivers and fleet owners

   Where necessary, we may share limited information so that drivers and fleets can understand their performance and payouts, or to coordinate campaigns in specific regions.

4. Corporate transactions

   If we enter into a merger, acquisition, financing, sale of assets or similar transaction, your information may be transferred as part of that deal, subject to confidentiality obligations and applicable law.

5. Legal and safety

   We may disclose information if we believe it is reasonably necessary to:

   • comply with applicable laws, regulations, legal processes or lawful requests;
   • protect the rights, property and safety of Qubic3D, our users or the public;
   • investigate and respond to fraud, abuse or security issues.

9. International transfers

Qubic3D is based in South Africa, but some of our service providers may be located in other countries. This means your information may be transferred to and processed in countries that may have different data protection laws to those in your country.

Where required by law, we take steps to ensure that an adequate level of protection is in place, such as:

• using providers in countries recognised as having adequate protection; or
• implementing appropriate safeguards (for example, contractual clauses approved by relevant authorities).

10. Data retention

We keep personal information only for as long as reasonably necessary for the purposes described in this Policy, including:

• while you have an active account or ongoing relationship with us;
• for the period needed to comply with legal, tax or accounting obligations;
• for the period allowed or required to enforce or defend legal claims.

After that, we will delete or anonymise the information, or if this is not possible (for example, in backup archives), we will securely store it and isolate it from further use until deletion is possible.

11. Security

We implement technical and organisational measures designed to protect information against unauthorised access, loss, misuse or alteration, including:

• encryption in transit and at rest;
• access controls and multi-factor authentication for admin accounts;
• network security controls and monitoring;
• secure development and change-management practices.

No method of transmission or storage is completely secure, but we continuously work to improve our protections. For more detail, see our Security page.

12. Your rights

Depending on applicable law and your location, you may have some or all of the following rights regarding your personal information:

• Access – to request confirmation that we process your personal information and to obtain a copy.
• Correction – to ask us to correct inaccurate or incomplete information about you.
• Deletion – to request that we delete certain information (subject to legal retention requirements).
• Restriction – to request that we limit how we use your information in certain circumstances.
• Objection – to object to processing based on legitimate interests, including direct marketing.
• Portability – to receive certain information in a structured, commonly used format, or to ask us to transfer it to another controller, where technically feasible.
• Withdraw consent – where processing is based on consent, you may withdraw it at any time (this will not affect the lawfulness of processing before withdrawal).

To exercise any of these rights, please contact us at privacy@qubic3d.co.za and provide enough information to identify yourself. We may need to verify your identity before fulfilling your request, especially for access or deletion.

You also have the right to lodge a complaint with your local data protection authority. In South Africa, this is the Information Regulator (www.justice.gov.za/inforeg/).

13. Direct marketing

We may send you marketing communications about Qubic3D products and services if:

• you have requested information from us;
• you have signed up to our services; or
• you have otherwise consented, where required by law.

You can opt out of marketing emails at any time by clicking the "unsubscribe" link in the email or contacting us at privacy@qubic3d.co.za. We may still send non-marketing messages, such as service or account notifications.

14. Children's privacy

Qubic3D's services are not directed at children under 16, and we do not knowingly collect personal information from children. If you believe that a child has provided us with personal information, please contact us so that we can investigate and, if appropriate, delete the information.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services or legal requirements. When we do, we will update the "Last updated" date at the top of this page.

If the changes are material, we may provide additional notice (for example, by email or a banner on our Website).

16. How to contact us

If you have any questions, concerns or requests relating to this Privacy Policy or our data practices, you can contact us at:

Qubic3D (Pty) Ltd
Email: privacy@qubic3d.co.za
Support: support@qubic3d.co.za