Privacy Policy Qubs

Qubs Privacy Policy

Last updated:08.07.2026

This Privacy Policy explains how QubHQ S.R.L., a company registered in Romania, with registered office at Gheorghe Doja 165B, Oradea, Bihor, registered with the Trade Registry under no. J05/612/2023, fiscal identification code RO47754744, hereinafter referred to as “Qubs”, “we”, “us”, or “our”, collects, uses, stores, shares, and protects personal data when you use Qubs services.

This Privacy Policy applies to:

1. End-Users who use Qubs.app, Qubs Moments, Qubs Discovery, digital menus, social features, rewards, cashback, uploads, or related user-facing services;

2. Venues such as restaurants, cafés, bars, hotels, event spaces, hospitality businesses, and their representatives using Qubs Digital Menu, Qubs Moments, Qubs Discovery, advertising partnership tools, rewards, analytics, or related venue services;

3. Advertisers such as brands, agencies, affiliates, partners, and business users using Prestige Advertising by Qubs, campaign tools, brand profiles, advertising budgets, top-ups, recurring payments, and related advertising services.

Together, these are referred to as “Qubs services”.

By using Qubs services, you acknowledge that your personal data may be processed as described in this Privacy Policy.

1. Who controls your data

For most processing activities, the data controller is:

QubHQ S.R.L.
Gheorghe Doja 165B, Oradea, Bihor, Romania
CUI: RO47754744
Trade Registry: J05/612/2023

In some cases, a Venue or Advertiser may also act as an independent controller for data they collect, upload, configure, or use through Qubs. For example, a Venue may be responsible for staff data, venue-managed rewards, customer interactions, or data processed outside Qubs. An Advertiser may be responsible for its landing pages, campaign claims, external tracking, CRM data, or data collected outside Qubs.

Where Qubs processes personal data only on behalf of a Venue, Advertiser, or business customer, Qubs may act as a processor and a separate Data Processing Agreement may apply.

2. Personal data we process

Depending on how you use Qubs, we may process the following categories of personal data.

2.1 Account and identity data

This may include:

1. name;

2. email address;

3. phone number;

4. username;

5. password or login credentials;

6. profile photo;

7. account ID;

8. role or permissions;

9. authentication data;

10. communication preferences.

2.2 Venue and business data

For Venues and their representatives, this may include:

1. company name;

2. business contact details;

3. role or job title;

4. workspace data;

5. location data;

6. menu settings;

7. billing information;

8. fiscal information;

9. support requests;

10. staff user permissions;

11. advertising intensity settings;

12. reward and loyalty configurations;

13. venue moderation actions.

2.3 Advertiser and campaign data

For Advertisers, agencies, affiliates, and brand representatives, this may include:

1. company or brand name;

2. business contact details;

3. role or job title;

4. brand profile data;

5. campaign settings;

6. advertising content;

7. media uploads;

8. landing page links;

9. targeting or delivery settings;

10. budget and top-up data;

11. recurring payment settings;

12. invoice and billing data;

13. campaign validation and moderation notes;

14. campaign performance data.

2.4 End-User content and activity data

For End-Users, this may include:

1. uploaded photos, videos, text, reactions, comments, and Moments;

2. likes, follows, shares, reports, and social interactions;

3. venue pages viewed;

4. QR codes scanned;

5. digital menu sessions;

6. reward tiers unlocked;

7. rewards redeemed or attempted;

8. cashback, wallet, credit, or balance activity, where available;

9. discovery interactions;

10. ad interactions;

11. support messages and complaints.

2.5 Location and presence data

Qubs may process location or physical-presence data when needed for Moments, Discovery, venue check-ins, reward validation, fraud prevention, and user experience.

This may include:

1. GPS location, if enabled;

2. approximate location;

3. IP address;

4. QR scan data;

5. venue session data;

6. device or browser signals;

7. Wi-Fi or network-related signals;

8. time and location of interactions;

9. technical indicators used to verify whether you are inside or near a Venue.

You may disable certain location permissions through your device or browser settings, but some Qubs features may not work correctly without them.

2.6 Technical and usage data

We may process:

1. IP address;

2. browser type;

3. device type;

4. operating system;

5. language settings;

6. cookies and similar identifiers;

7. log data;

8. session data;

9. feature usage;

10. error reports;

11. security events;

12. analytics data;

13. performance data.

2.7 Payment and billing data

Where payments, top-ups, recurring payments, subscriptions, invoices, cashback, wallet, or payout features are available, we may process:

1. billing name;

2. company details;

3. invoice data;

4. VAT or fiscal data;

5. payment status;

6. transaction references;

7. top-up history;

8. recurring payment settings;

9. payout data;

10. refund or adjustment records.

Full payment card details are usually processed by payment processors and not stored directly by Qubs, unless expressly stated otherwise.

3. Why we process personal data

We process personal data for the following purposes.

3.1 To provide Qubs services

We use data to:

1. create and manage accounts;

2. operate Qubs.app;

3. provide digital menus;

4. manage Venue workspaces;

5. manage Advertiser workspaces;

6. display venue pages;

7. operate Qubs Moments;

8. operate Qubs Discovery;

9. enable social features;

10. manage rewards, loyalty, cashback, and wallet features;

11. deliver Prestige Advertising campaigns;

12. process budgets, top-ups, recurring payments, invoices, and payouts;

13. provide support.

3.2 To operate Qubs Moments and user-generated content

We use data to:

1. allow users to upload Moments;

2. link content to physical Venues;

3. verify physical presence where required;

4. display content on venue pages, feeds, discovery pages, or Qubs.app;

5. allow reactions, comments, reports, and social interactions;

6. moderate content;

7. allow Venues to report, hide, restrict, or request removal of content connected to their Venue.

3.3 To operate rewards and loyalty features

We use data to:

1. determine whether a User qualifies for a Reward;

2. unlock reward tiers;

3. validate redemption windows;

4. show redemption instructions;

5. prevent reward fraud;

6. share necessary redemption information with Venues;

7. manage cashback, wallet, credit, or balance features where available.

3.4 To operate Prestige Advertising by Qubs

We use data to:

1. create advertiser accounts and brand profiles;

2. validate ads, brands, campaigns, and media;

3. deliver campaigns through Qubs inventory;

4. run auctioning, ranking, distribution, and optimization systems;

5. measure campaign performance;

6. provide reports;

7. detect fraud and invalid traffic;

8. process top-ups, recurring payments, invoices, and billing;

9. enforce prohibited and restricted advertising categories.

3.5 To provide analytics and improve Qubs

We use data to:

1. measure platform performance;

2. understand usage trends;

3. improve features;

4. improve menu, Moments, Discovery, Rewards, and Advertising systems;

5. calculate Venue performance tiers;

6. improve advertising delivery;

7. identify errors and technical issues;

8. develop new services.

Where possible, we use aggregated or anonymized data.

3.6 To protect Qubs, users, Venues, and Advertisers

We use data to:

1. prevent fraud;

2. detect fake activity;

3. detect invalid traffic;

4. protect accounts;

5. secure the platform;

6. investigate abuse;

7. moderate content;

8. enforce Terms and Conditions;

9. respond to reports and complaints;

10. protect the integrity of Qubs.

3.7 To comply with legal obligations

We use data to:

1. issue invoices;

2. keep accounting records;

3. respond to legal requests;

4. comply with tax obligations;

5. handle legal claims;

6. comply with data protection obligations;

7. comply with advertising, platform, consumer, or safety obligations where applicable.

4. Legal bases for processing

Depending on the context, we process personal data based on:

1. Contract performance, where processing is needed to provide Qubs services or perform our agreement with you;

2. Legal obligation, where processing is required for accounting, tax, regulatory, security, or legal compliance;

3. Legitimate interest, where processing is needed for security, fraud prevention, analytics, moderation, platform improvement, business operations, advertising measurement, and service integrity;

4. Consent, where required for precise location, optional cookies, marketing communications, certain personalization features, or other optional processing;

5. Vital interests or public interest, only in rare cases where safety or legal reporting requires it.

You may withdraw consent at any time where processing is based on consent. Withdrawal does not affect processing that happened before withdrawal.

5. Public content and visibility

Some Qubs features are public or visible to others.

This may include:

1. Moments;

2. profile information;

3. reactions;

4. comments;

5. venue-linked content;

6. uploaded photos or videos;

7. discovery activity;

8. public brand profiles;

9. public venue profiles;

10. promoted content.

You should not upload or publish content that you do not want others to see.

If you delete content, we will remove it from active public display where technically possible. However, copies may remain in backups, logs, moderation records, reports, cached systems, legal records, or places where it has already been shared or interacted with.

6. Venue moderation and content removal

Because Qubs Moments is connected to real physical Venues, participating Venues may be able to report, hide, restrict, or request removal of User Content connected to their Venue.

This may happen if content:

1. violates Venue rules, house rules, internal policies, safety rules, or brand standards;

2. damages, dirties, or negatively affects the image, reputation, atmosphere, or commercial interests of the Venue;

3. shows staff, customers, minors, private areas, or other people without appropriate permission;

4. is misleading, abusive, defamatory, inappropriate, harmful, or unsafe;

5. creates privacy, safety, operational, or reputational concerns.

Qubs may review, remove, restrict, or keep removed such content according to its Terms, community rules, legal obligations, and platform standards.

7. Advertising and promoted content

Qubs may display advertising, sponsored content, promoted articles, brand covers, banners, offers, or other promoted content inside Qubs.app, Qubs Moments, Qubs Discovery, digital menus, venue pages, and other Qubs surfaces.

We may process contextual, session-based, device, venue, interaction, and advertising performance data to:

1. display ads;

2. measure ad performance;

3. prevent fraud;

4. run auctioning and distribution systems;

5. report campaign performance to Advertisers;

6. improve advertising relevance and delivery.

Advertisers generally receive aggregated or campaign-level reporting, not personal identification data of individual End-Users.

Where required, advertising or promoted content may be labelled as “Sponsored”, “Promoted”, “Ad”, “Prestige”, “Promoted Article”, or similar.

Where legally required, we will request consent for advertising cookies or similar tracking technologies.

8. AI and automated systems

Qubs may use automated systems, including AI-based systems, to support:

1. content generation;

2. translations;

3. nutritional estimates;

4. ad validation;

5. campaign moderation;

6. content moderation;

7. fraud prevention;

8. ranking and discovery;

9. recommendation systems;

10. analytics;

11. support and internal workflows.

Automated systems may help Qubs review, classify, rank, restrict, or recommend content, Venues, campaigns, rewards, or ads.

Where required by law, you may have rights related to automated decision-making.

9. Who we share personal data with

We may share personal data with the following categories of recipients.

9.1 Service providers

We may share data with providers that help us operate Qubs, including:

1. cloud and hosting providers;

2. database providers;

3. security providers;

4. analytics providers;

5. payment processors;

6. email and communication tools;

7. customer support tools;

8. AI providers;

9. content delivery networks;

10. mapping providers;

11. monitoring and error reporting providers.

9.2 Venues

We may share data with Venues where needed to:

1. validate rewards;

2. show venue-linked Moments;

3. allow content reporting or moderation;

4. manage venue pages;

5. process user interactions with the Venue;

6. resolve complaints or support requests;

7. prevent fraud or abuse.

9.3 Advertisers

We may share aggregated or campaign-level advertising data with Advertisers, such as promoted sessions, impressions, clicks, spend, venue performance, timing, and general campaign metrics.

We do not normally share personal identification data of End-Users with Advertisers.

9.4 Public users

If you publish content publicly, other users may see it.

This may include Moments, comments, reactions, profile information, venue-linked content, and other public interactions.

9.5 Professional advisors and authorities

We may share data with legal, tax, accounting, audit, compliance, or professional advisors.

We may also share data with public authorities, courts, regulators, law enforcement, or other parties where required by law or necessary to protect rights, safety, and platform integrity.

10. Third-party providers

Qubs depends on third-party software, infrastructure, platforms, APIs, hosting providers, cloud services, AI systems, analytics providers, payment processors, security providers, and other external services.

These may include, without limitation:

1. Google Cloud;

2. Google Gemini;

3. Cloudflare;

4. Vercel;

5. database providers;

6. authentication providers;

7. payment processors;

8. email providers;

9. analytics tools;

10. content delivery networks;

11. AI providers;

12. domain and DNS providers;

13. mapping providers;

14. other software and infrastructure services.

These providers may process personal data only as needed to provide infrastructure, AI, analytics, payment, communication, security, moderation, or platform services.

11. International transfers

Some service providers may process personal data outside Romania or outside the European Economic Area.

Where required, Qubs uses appropriate safeguards such as adequacy decisions, Standard Contractual Clauses, or other legally accepted transfer mechanisms.

12. Retention

We keep personal data only for as long as needed for the purposes described in this Privacy Policy.

Typical retention periods include:

1. account data: while the account is active;

2. workspace data: while the workspace is active and as needed for legal or operational reasons;

3. billing and invoice data: for the legal accounting retention period;

4. uploaded content: while published or as needed for moderation, legal, backup, or dispute reasons;

5. reward data: while needed for validation, fraud prevention, disputes, and accounting;

6. campaign data: while needed for delivery, reporting, billing, validation, disputes, audits, and legal protection;

7. support data: while needed to resolve issues and protect legal interests;

8. logs and security data: for a limited technical and security period;

9. anonymized or aggregated analytics: may be kept longer.

When data is no longer needed, we delete it, anonymize it, or restrict it according to our retention rules and legal obligations.

13. Security

We use reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include access controls, authentication, monitoring, backups, encryption where appropriate, internal policies, and security reviews.

However, no digital system is completely secure. You are responsible for protecting your account credentials and managing access to your account or workspace.

14. Cookies and similar technologies

Qubs may use cookies, local storage, pixels, SDKs, device identifiers, session identifiers, analytics tools, and similar technologies.

These technologies may be used for:

1. login;

2. authentication;

3. security;

4. session management;

5. preferences;

6. analytics;

7. performance measurement;

8. fraud prevention;

9. advertising;

10. reward validation;

11. location/session validation;

12. platform functionality.

Where required, we will ask for consent before using optional cookies or similar technologies.

More details may be provided in a separate Cookie Policy or cookie settings.

15. Marketing communications

We may send marketing or commercial communications where legally permitted.

This may include:

1. product updates;

2. platform news;

3. venue updates;

4. reward updates;

5. campaign opportunities;

6. advertiser opportunities;

7. business communications;

8. promotional messages.

You may opt out of marketing communications at any time.

Service, security, legal, billing, account, reward, campaign, or transactional messages may still be sent even if you opt out of marketing.

16. Children and minors

Qubs is not intended for children below the minimum age required by applicable law.

If we learn that we processed children’s data unlawfully, we may delete or restrict the account and related data.

Some features, rewards, advertisements, venues, or content may be age-restricted.

We do not knowingly use children’s data for targeted advertising where prohibited by law.

17. Your rights

Depending on the situation and applicable law, you may have the right to:

1. access your personal data;

2. obtain a copy of your personal data;

3. correct inaccurate or incomplete data;

4. request deletion of your data;

5. restrict processing;

6. object to processing based on legitimate interest;

7. request data portability;

8. withdraw consent where processing is based on consent;

9. object to direct marketing;

10. lodge a complaint with a data protection authority.

To exercise your rights, contact us at:

Email: [insert privacy email]

We may need to verify your identity before responding.

Some rights may be limited by legal obligations, security reasons, accounting rules, fraud prevention, dispute resolution, or the rights of others.

18. Complaints

If you believe your data protection rights have been violated, you may contact us first so we can try to resolve the issue.

You also have the right to lodge a complaint with the Romanian data protection authority:

Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal
Website: [insert ANSPDCP website]
Email: [insert ANSPDCP email if desired]

Complaints to ANSPDCP may be submitted in writing, including by post, email, or the authority’s electronic form.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

The updated version will be made available through Qubs.app, the website, email, dashboard, in-app notification, or another reasonable method.

If changes are significant, we may provide additional notice where appropriate.

Continued use of Qubs services after the updated Privacy Policy becomes effective means that you acknowledge the updated version.

20. Contact

For privacy, data protection, account, content, reward, advertising, or platform matters, you may contact us at:

QubHQ S.R.L.
Gheorghe Doja 165B, Oradea, Bihor, Romania
CUI: RO47754744
Trade Registry: J05/612/2023