PRIVACY POLICY

PICUBE shall act as the controller of the information processed pursuant to this Privacy Policy and undertakes to implement reasonable technical, administrative, organizational and cybersecurity measures intended to safeguard the confidentiality, integrity, availability and security of the information under its control.

The scope of processing shall include information provided directly or indirectly by the USER, information generated as a result of interaction with the PLATFORM, information associated with subscription and authentication environments, behavioural and usage information, technical information relating to DEVICES and browser environments, and any information generated as part of the operation, maintenance, security, analytics or improvement of the SERVICES.

For legal purposes, PICUBE may designate as its address the one indicated in its Terms and Conditions or any address subsequently communicated through electronic means.

The processing of information shall be carried out in accordance with applicable law, including, without limitation, the Federal Law on Protection of Personal Data Held by Private Parties (Mexico), as well as, where applicable, the General Data Protection Regulation (GDPR) of the European Union and any other applicable provisions.

The USER expressly acknowledges that the PLATFORM operates under a client-side encryption and zero-knowledge architectural model intended to minimize server-side visibility over encrypted vault contents and authentication secrets.

In this context, PICUBE may act as a controller with respect to account-level information, subscription information, technical metadata, behavioural analytics and operational records under its control, while simultaneously lacking technical access to encrypted vault contents, plaintext passwords or the USER's MASTER PASSWORD.

The USER further acknowledges that the operation of the PLATFORM may involve international data flows, distributed technological infrastructure, third-party service providers, cloud-hosting environments, cybersecurity tools, analytics systems and behavioural tracking technologies located across different jurisdictions.

PICUBE may process information consisting of account registration information, including email address, account identifiers and subscription status; hashed or encrypted authentication-related credentials associated with account-level authentication processes; technical information such as IP address, browser metadata, operating system, device identifiers, user-agent information, timestamps, access logs, session data and technical usage patterns; subscription and billing metadata processed in connection with paid plans and subscription environments; behavioural analytics and telemetry data associated with usage of the PLATFORM, particularly within free-tier environments; operational and security logs; support communications voluntarily submitted by the USER; and information relating to interactions with advertising, tracking or analytics technologies implemented through the PLATFORM.

The USER expressly acknowledges that PICUBE does not ordinarily collect, process, store or access plaintext passwords stored within the PASSWORD VAULT, decrypted vault contents or the USER's MASTER PASSWORD.

Likewise, PICUBE does not ordinarily possess technical visibility over encrypted credentials stored locally within the USER's DEVICE or browser environment as part of the zero-knowledge operational model implemented by the PLATFORM.

The USER further acknowledges that certain information generated through analytics, advertising integrations, behavioural tracking technologies or third-party technological tools may be processed by authorized third-party providers in accordance with their own technological infrastructure and applicable privacy frameworks.

Information shall be processed for purposes including enabling registration, authentication and access to the PLATFORM; operating and maintaining account-level environments; managing subscriptions and billing relationships; enabling password-generation functionalities; maintaining operational security; detecting, preventing and mitigating fraud, abuse, unauthorized access or malicious conduct; generating operational records and support logs; improving, optimizing and developing the PLATFORM and the SERVICES; conducting behavioural analytics and usage analysis; administering advertising integrations applicable to free-tier environments; complying with legal or regulatory obligations; responding to lawful requests from competent authorities; issuing operational communications, technical notifications, security alerts and service-related notices; and enforcing the Terms and Conditions and related policies governing the PLATFORM.

PICUBE may additionally process information in aggregated, dissociated, anonymized or statistical form for purposes relating to analytics, service improvement, operational optimization, cybersecurity analysis, technological development, artificial-intelligence training, commercial intelligence or product-development initiatives, provided that such processing does not directly identify the USER.

The USER expressly acknowledges and agrees that PICUBE operates under a zero-knowledge and client-side encryption model specifically intended to limit PICUBE's technical ability to access encrypted vault contents stored by the USER through the PLATFORM.

Accordingly, encryption and decryption of PASSWORD VAULT contents occur locally within the USER's DEVICE or browser environment and not within PICUBE's servers or centralized infrastructure.

The USER further acknowledges that PICUBE does not possess or maintain the USER's MASTER PASSWORD, vault encryption keys or decrypted PASSWORD VAULT contents and therefore may be technically incapable of restoring access to encrypted vault data in the event of loss, deletion, corruption or unavailability of the USER's MASTER PASSWORD or local environment.

The USER expressly understands and accepts that this architectural limitation constitutes an essential characteristic of the SERVICES and does not represent a service malfunction, deficiency or failure attributable to PICUBE.

The USER acknowledges and agrees that certain functionalities of the PLATFORM, particularly within free-tier environments, may involve behavioural tracking technologies, cookies, analytics tools, telemetry systems, advertising integrations and related monitoring technologies intended to support operational analytics, advertising functionality, performance optimization, abuse prevention and service improvement.

Such processing may include collection of behavioural events, interaction patterns, usage metrics, session information, navigation behaviour, technical metadata, device characteristics and advertising-related analytics.

PICUBE may work with third-party analytics providers, advertising providers, behavioural-monitoring providers or technological partners in connection with these functionalities.

Paid subscription tiers may reduce, modify or eliminate certain advertising or behavioural tracking functionalities depending on the subscription model applicable to the USER.

PICUBE may share, transfer or disclose information to third parties, within or outside the USER's jurisdiction, where reasonably necessary for operation of the PLATFORM, including hosting providers, infrastructure providers, cybersecurity services, payment processors, analytics providers, advertising providers, support providers, professional advisors, auditors, affiliates or competent governmental, judicial or regulatory authorities.

PICUBE shall not sell the USER's personal data to unrelated third parties.

The USER acknowledges that certain third-party service providers involved in hosting, analytics, subscriptions, behavioural tracking, advertising or cybersecurity services may process information pursuant to their own technological and operational environments.

PICUBE implements reasonable technical, organizational, administrative and cybersecurity measures intended to protect information against unauthorized access, loss, misuse, alteration, destruction, disclosure or compromise, taking into consideration the nature of the PLATFORM and the operational environment of the SERVICES.

Such measures may include access controls, encryption protocols, authentication controls, internal security procedures, monitoring systems, restricted-access environments and cybersecurity safeguards consistent with commercially reasonable industry standards.

Notwithstanding the foregoing, the USER expressly acknowledges that no technological environment, cybersecurity system, browser infrastructure, software environment, cloud infrastructure or transmission channel can guarantee absolute security or complete immunity from vulnerabilities, exploits, unauthorized access, malware, interception, technological failures or future cybersecurity threats.

Accordingly, the USER remains solely responsible for maintaining the security of the USER's DEVICE, browser environment, local storage, authentication credentials, MASTER PASSWORD and overall cybersecurity posture.

The USER may exercise such rights as may be available under applicable law, including rights of access, rectification, erasure, restriction, objection, portability or withdrawal of consent with respect to information processed by PICUBE, subject to the limitations established under applicable law and the technological nature of the PLATFORM.

The USER expressly acknowledges that information stored locally within encrypted vault environments may not be technically accessible by PICUBE due to the zero-knowledge architecture implemented by the PLATFORM.

Information shall be retained for such period as may be necessary to fulfill the purposes described in this Privacy Policy, comply with legal or regulatory obligations, resolve disputes, enforce agreements, maintain operational records, defend legal claims or preserve cybersecurity integrity.

Certain technical logs, security records or operational records may continue to be retained for compliance, fraud-prevention, audit or cybersecurity purposes where reasonably necessary.

The PLATFORM may use cookies, SDKs, local storage technologies, pixels, session technologies and similar tracking mechanisms for authentication, analytics, behavioural analysis, advertising, operational functionality, security monitoring and user-experience optimization purposes.

The USER may configure certain browser environments to reject or limit cookies or tracking technologies; however, doing so may affect the availability or functionality of certain components of the PLATFORM.

Information may be transferred, processed or stored across multiple jurisdictions in accordance with the operational, technological, corporate or infrastructural needs of PICUBE and its authorized providers.

The USER expressly consents to such international transfers and acknowledges the international nature of the technological infrastructure supporting the PLATFORM.

PICUBE reserves the right to modify, restate, update or amend this Privacy Policy at any time.

Such modifications shall become effective upon publication or notification through the PLATFORM or any reasonable electronic means.

Continued access to or use of the PLATFORM following such modifications shall constitute acceptance thereof.

This Privacy Policy, as well as any processing of information, legal relationship or dispute arising out of or related thereto, shall be governed by and construed in accordance with the federal laws of the United Mexican States, excluding any conflict-of-laws provisions that could refer to the application of foreign law.

Any dispute shall be finally resolved by arbitration administered by the International Court of Arbitration of the International Chamber of Commerce (ICC), with seat in Mexico City, United Mexican States, in the English language, in accordance with its Rules in force at the relevant time.

Notwithstanding the foregoing, PICUBE may seek interim, provisional or injunctive relief before competent judicial or administrative authorities whenever necessary to protect confidential information, trade secrets, cybersecurity infrastructure, technological assets or intellectual property rights.

The USER acknowledges the international nature of data processing associated with the PLATFORM and assumes responsibility for compliance with any laws applicable to the USER in connection with access to or use of the SERVICES.