Privacy Policy

Last Updated: June 16, 2026

1. Introduction

This Privacy Policy (the “Privacy Policy”) governs your use of the ECubed Program (“Program”) and other related services (collectively the “Ecubed Service/s”), and explains how BairesDev LLC, and its affiliates (collectively “Company,” “we,” “us,” or “our”) handle personal information that we collect from or about you when using the Services and through your interactions with us.

For the purpose of this Privacy Policy, “you” or “your” means the individual accessing or using the Services.

E-Cubed is a membership-based professional networking platform designed exclusively for senior technology and engineering leaders, including CTOs, CIOs, and other executive-level professionals. The Service is intended for individual users acting in a personal and professional capacity (not on behalf of an organization).

By using Ecubed Services, you agree to the collection, use, and disclosure of information in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into our Terms & Conditions. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to privacy matters, this Privacy Policy shall control.

If you do not agree, you must not use the Service.

For further clarifications on this Privacy Policy, questions, or concerns, please do not hesitate to contact us at the contact information indicated below.

2. About us

BairesDev LLC is the sponsor of Ecubed and is a California Limited Liability Company with an address at 1999 S Bascom Ave, Campbell, CA 95008.

For the purpose of this Privacy Policy, we are the data controller of Personal Information you provide as described in this document, unless expressly specified otherwise.

3. Scope and Application

This Privacy Policy applies to all users of the Services, a professional senior technology networking service for individual users.

It applies to:

Applicants
Approved members
Individuals introduced to the Program by existing members
Website visitors

4. Personal Information we collect

As used in this Privacy Policy, “Personal Information” means any data relating to an identified or identifiable individual including, but not limited to: your first name, last name, company name, email address, phone number, job title, and date of birth, among others.

We collect Personal Information from you through our interactions with you and through Ecubed Services. You may provide this data directly and we get some of it by collecting data about your interactions and use.

In some cases, we may also receive Personal Information about individuals who have been introduced to us by existing participants. This information is provided by the introducing member and may include contact or identification details necessary to extend invitations or provide access to Ecubed Services. We process such information in accordance with this Privacy Policy and applicable data protection laws, and we expect participants to ensure they have the appropriate authorization to share such information with us.

If you provide us with any Personal Information about another person, you represent and warrant that (i) you have that person’s consent to do so; and (ii) that you are responsible for ensuring that your use, control, processing and disclosure of such Personal Information is in compliance with all applicable laws, rules and regulations, and the Terms & Conditions.

We collect Personal Information when you:

Register to use the Services or complete or submit information or forms on our Program, including when you apply for membership.
Download or upload contents on the Services, and any other information and content you generate, transmit, submit to or use in connection with the Services, as well as associated metadata.
Register for webcasts, seminars, conferences, discussions, etc. through the Services.
Provide us with feedback or suggestions and information via phone, email, social media, or any other means.
Answer a survey.
Subscribe to our newsletters or other content-related material.
Use forums or leave comments on our Program.
During in-person meetings or at our events, conferences, workshops, or gatherings.
Introduce or are introduced by a member to use the Services. We may collect certain information about these referrals or invitees to enable us to communicate with them and deliver their invitations.

Online information about you may also originate from the use of cookies and similar technologies (for example, pixel tags and device identifiers) on Ecubed Services or sites of third parties.

We may collect Personal Information from content that you create and then share with us (and others), with your consent, by uploading it to our Program. Such Personal Information may include photos, videos, personal stories, or other similar media or content. This information may be considered or reveal sensitive Personal Information, as it could reveal your race and gender, and depending on the type of content, could also potentially reveal political opinion and health information. Please note that we do not control the content that you may post to our forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit Personal Information to these forums or social networks and whether you wish to make your profile available to other users.

5. Categories of Personal Information and specific pieces of Personal Information we collect.

We collect the following categories of personal data:

When you apply, register, or interact with the Service, we may collect the following categories of Personal Information listed below from users, for commercial and/or business purposes:

5.1 Information You Provide

Name
Email address
Professional background (job title, experience, industry)
Characteristics of protected classifications under state or federal law: such as age, gender, etc.
Application responses and screening information
Profile information (bio, preferences, interests)
Messages and User Content you choose to share
Introductions submissions
Member Content (written materials, presentations, recordings, webinar contributions, and other content you submit or make available through the Services)

5.2 Account Information

Username and password
Account status (approved, pending, terminated)
Onboarding data and verification details

5.3 Communications

Messages exchanged within the Services
Communications with us (support, onboarding, feedback)

5.4 Automatically Collected Data

We may automatically collect:

IP address and approximate location
Device and browser information
Log data (access times, pages viewed, interactions)
Cookies and similar tracking technologies

6. How do we use Personal Information

We use Personal Information to fulfill certain business/commercial purposes (collectively the “Purposes”). These purposes include:

6.1 Provide the Service

Evaluate membership applications
Create and manage user accounts
Enable networking and communication between members
Operate core platform features

6.2 Improve and Personalize the Experience

Improve Program functionality and usability
Recommend relevant connections or content
Analyze usage patterns
Customize the content and messaging you see on Ecubed Services
Personalize your experience

6.3 Communications

Send onboarding instructions and Service updates
Notify you of changes to policies or features
Provide administrative or support messages
Send periodic emails regarding Ecubed Services, announcements, software updates, and upcoming events

6.4 Safety and Integrity

Prevent fraud, abuse, or misuse
Enforce Terms & Conditions
Protect users and Services integrity

6.5 Member introductions

Process introductions of third parties by existing members, using limited contact information solely to communicate with introduced individuals and facilitate their access to the Services

6.6 Corporate reasons

Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company about our users is among the assets transferred

6.7 Legal purposes

Resolve disputes, enforce our contacts, including the Terms & Conditions, carry out our obligations and enforce our rights, and protect our business interests and the interests and rights of third parties.
Comply with certain legal rules and regulations that we are subject to, and as required by law enforcement

6.8 Automated Decision-Making and Profiling

We may use automated processing, including profiling, to recommend connections and content, personalize your experience, and detect fraud, abuse, or misuse. We do not make decisions producing legal or similarly significant effects on you based solely on automated processing, except where permitted by applicable law. Where applicable, you may exercise the rights described in Section 14 in relation to such processing. The logic of this processing involves matching attributes from your profile and platform activity (such as professional background, interactions, and stated interests) against attributes of other members and content to surface relevant suggestions. The consequences of such processing are limited to the recommendations and personalization shown to you within the Services and the detection of activity that may indicate fraud or misuse. This processing does not result in decisions producing legal or similarly significant effects on you.

7. Legal basis we follow to process Personal Information.

We rely on the following legal bases to collect and process Personal Information under applicable data protection laws:

Consent: where you have provided your consent for the processing of your Personal Information for a specific purpose.
Performance of a contract: where processing is necessary for the performance of a contract with you or taking steps prior to entering a contract with you.
Legal obligation: where we have a legal obligation to process Personal Information for example when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law.
Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law but it clearly benefits you.

Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

Where we rely on legitimate interests, our legitimate interests include: operating, securing, and improving the Services; preventing fraud, abuse, and misuse; communicating with members and prospective members; conducting analytics and research to develop Ecubed Services; processing introductions submitted by existing members; and protecting our rights and the rights of third parties. We have assessed that these interests are not overridden by your rights and freedoms. You have the right to object to processing based on legitimate interests as described in Section 14.

We do not sell or rent your personal data.

We may share information in the following cases:

8.1 With Other Members

Profile information visible to approved users
Content you choose to share publicly or within the Service, including Member Content such as webinar recordings or presentations you have contributed, provided that it was made available by you. We strongly encourage you to carefully consider the information that you will post or share through Ecubed Services.
Messages exchanged between users

8.2 Service Providers

We may share Personal Information globally with our affiliates and group companies to carry out our activities, as specified in this Privacy Policy. Also, we may share Personal Information with third parties services providers located in different countries which may differ from your location or country of origin.

Therefore, the Personal Information we collect may be collected, transferred to, processed, and/or stored, in the United States or anywhere where we, our affiliates, our partners, our vendors, agents, suppliers, or service providers maintain facilities. As such, Personal Information may be subject to privacy laws from different countries.

In this regard, we may share Personal Information with:

Our affiliates: to provide Ecubed Services.
Our vendors, agents, suppliers, or service providers: that help us conduct our business and/or support our infrastructure

8.3 Legal Requirements

We may disclose information if required to:

Comply with law or legal process
Enforce our Terms & Conditions
Protect the rights, safety, or security of users or the Company

8.4 Successors in Interest

In the event there is a change in the corporate structure of the Company including, without limitation, by merger, consolidation, sale, liquidation, transfer of substantial assets, or in the unlikely event of bankruptcy, we may, in our sole discretion, transfer, sell or assign Personal Information collected on and through the Services to one or more affiliated or unaffiliated third parties or successor in interest.

8.5 Professional Advisors

We may disclose Personal Information to our legal, financial, insurance and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

8.6 Public Use of Member-Provided Content

In limited cases, we may publish certain content you provide — such as a headshot or professional photograph, a quote or testimonial, and related professional information — on our public-facing ECubed Program or in related promotional materials, in order to feature members, share program highlights, and promote the Program. You may withdraw your consent or request removal at any time by contacting us at the email address set out in Section 20.

9. Your Content And Public Information

Certain information you choose to share may be visible to others on the Service.

You are responsible for what you disclose, including:

Profile content
Posts and messages
Professional information shared in networking contexts

We are not responsible for how other users use information you voluntarily share. Please review our Terms & Conditions for the full terms governing any content posted by you.

10. Cookies And Tracking Technologies

To enable our systems to recognize your browser or device and to provide and improve our products and Services, we use cookies and other technologies.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow it) that enable the site’s or service provider’s systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved Services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better experiences and tools in the future.

We use cookies and similar technologies to:

Keep you logged in
Improve user experience
Understand Program usage
Enhance security

Where you access the Services, we set strictly necessary cookies as required to operate the Services. We will only set non-essential cookies and similar tracking technologies (including analytics, functional, and marketing cookies) with your prior consent, which you may give, refuse, or withdraw through our cookie banner. Additional information on the cookies we use, their purposes, and retention periods is available through our cookie banner.

11. Data Retention

We will keep Personal Information as long as necessary to fulfill the purposes described herein. Upon your request, we will delete your Personal Information, unless we are allowed or required to keep certain Personal Information, for example, to fulfill a legal obligation or to resolve a dispute, etc. When accounts are terminated, we may retain limited data where required or permitted by law. Member Content (as defined in our Terms & Conditions) contributed to the Services — such as webinar recordings or presentations — may be retained for the duration of the Program’s operation, unless you request removal and no legal or contractual obligation prevents deletion.

To determine retention periods, we consider, among others: (i) the duration of our relationship with you; (ii) any legal, regulatory, or accounting retention obligation; (iii) the need to retain Personal Information to establish, exercise, or defend legal claims; and (iv) the need to fulfill the original purpose of collection or a compatible secondary purpose; and any consent you have provided. When Personal Information is no longer required, we will delete, anonymize, or securely archive it in accordance with applicable law.

12. Data Security

We use reasonable technical and organizational safeguards to protect your information.

However, no system is fully secure, and we cannot guarantee absolute security.

You are responsible for:

Keeping your login credentials confidential
Securing your device and account access

12.1 Data Breach Notification

In the event of a personal data breach affecting your Personal Information, we will respond in accordance with applicable law. Where required, we will notify the competent supervisory authority and affected individuals within the timeframes set by applicable law, including, where applicable, within 72 hours under the EU General Data Protection Regulation (the “EU GDPR”) and UK General Data Protection Regulation (the “UK GDPR”).

13. International Data Transfers

Your information may be processed in countries outside your residence, including the United States, where data protection laws may differ.

Where we transfer Personal Information from the European Economic Area (the "EEA"), the United Kingdom (the "UK"), or Canada to countries that have not received an adequacy decision (or equivalent recognition) from the competent authority, we implement appropriate safeguards required by applicable law, including the European Commission’s Standard Contractual Clauses, the UK International Data Transfer Agreement (or Addendum), or other lawful transfer mechanisms. You may request a copy of these safeguards by contacting us at the address in Section 20.

14. Your Privacy Rights

Under applicable laws, you are granted certain rights in relation to your Personal Information. Accordingly, we offer you security, transparency, control, and access to your Personal Information as available, and with the exceptions set forth in applicable laws. We recognize the following rights (which you can exercise in accordance with Section 15):

14.1 Right to know what information is being collected. Right to access personal information.

You have the right to request us to disclose:

The categories of Personal Information we have collected about you.
The categories of sources from which the Personal Information was collected.
The business or commercial purpose for which the Personal Information was collected or shared.
The categories of third parties to whom we disclose Personal Information.
The specific pieces of your Personal Information we have collected.

14.2 Right to delete your Personal Information.

You have the right to request us to delete any Personal Information that we have collected from you subject to certain exceptions according to applicable law.

14.3 Right to no retaliation following opt-out or exercise of other rights.

You have the right not to be discriminated against by us as a result of your exercise of any of your rights under applicable law. If you exercise any of your rights hereunder, we won’t deny you Ecubed Services, charge you a different price or rate for Ecubed Services, provide you a different level or quality of Services, or take any other retaliatory action against you.

14.4 Right to opt-out of the sharing of your Personal Information.

You have the right to opt out of the sharing of your Personal Information with third parties for certain purposes. However, please note that we may share your information with trusted service providers, vendors, and partners who assist us in operating Ecubed Services, fulfilling our contractual obligations, and delivering our products and features.

If you choose to opt out of such sharing, we may be unable to provide certain Services, features, or functionalities that depend on these third-party providers.

14.5 Right to correct inaccurate Personal Information.

You have the right to request us to correct any inaccurate Personal Information, taking into account the nature of the Personal Information and the purposes for which such Personal Information was collected, processed, or used.

14.6 Right to know what information is shared and to whom.

You have the right to request us to disclose:

The categories of Personal Information that we shared about you and the categories of third parties to whom the personal information was shared.
The categories of Personal Information that we have disclosed about you for a business purpose and the categories of persons to whom we have made such disclosure.

14.7 Right to limit use and disclosure of sensitive Personal Information.

You have the right to request us to use your sensitive Personal Information only to the extent that is necessary to perform the Services, as would be reasonably expected by an average user who requests such Services.

Under this Privacy Policy, Personal Information is considered sensitive if it reveals:

Racial or ethnic origin.
Political opinions.
Religious or philosophical beliefs.
Trade union membership.
Genetic or biometric data for the purpose of uniquely identifying a natural person.
Data concerning health or data concerning a natural person’s sex life or sexual orientation.

14.8 Rights of Nevada Residents

Pursuant to Section 603A of the Nevada Revised Statutes, residents of Nevada may, at any time, submit a request to an operator of a website in Nevada directing the operator not to make any sale of any personal information the operator has collected or will collect about the consumer. We do not sell, rent, or otherwise share your data with any third party in exchange for monetary or other valuable consideration under any circumstances, unless you specifically consent to such disclosure.

14.9 Additional Rights for Residents of the EEA and the UK

If you are located in the EEA or the UK, you also have the following rights under the EU GDPR and UK GDPR:

Data portability — receive the Personal Information you provided in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible.
Restriction of processing — request that we limit processing in certain circumstances.
Objection — object, on grounds relating to your particular situation, to processing based on legitimate interests; and object at any time to processing for direct-marketing purposes.
Withdraw consent — where processing is based on consent, withdraw it at any time, without affecting the lawfulness of prior processing.
Lodge a complaint — with your local data protection supervisory authority (e.g., the UK Information Commissioner’s Office for UK residents).
Not be subject to solely automated decision-making producing legal or similarly significant effects on you, except where permitted by applicable law.

Where required by applicable law, we will appoint an EU and/or UK representative under Article 27 of the EU GDPR or UK GDPR. The representative’s contact details will be made available upon request.

14.10 Additional Rights for Residents of Canada

If you are located in Canada, the processing of your Personal Information is subject to the Personal Information Protection and Electronic Documents Act (‘PIPEDA’) and, where applicable, provincial privacy legislation (including Quebec’s Law 25). In addition to the rights above, you may:

access and request correction of your Personal Information;
withdraw your consent, subject to legal or contractual restrictions and reasonable notice;
file a complaint with the Office of the Privacy Commissioner of Canada or, for Quebec residents, the Commission d’accès à l’information du Québec.

We have designated a privacy officer responsible for our compliance with applicable Canadian privacy laws, who can be contacted at the address in Section 20.

For Quebec residents: prior to transferring Personal Information outside Quebec, we conduct a privacy impact assessment in accordance with Section 17 of Quebec’s Law 25, taking into account the sensitivity of the information, the purposes for which it is to be used, the protection measures applicable, and the legal framework of the destination jurisdiction

15. How to exercise your rights.

You might exercise any of your rights under this Privacy Policy by contacting us at the following e-mail address legal@joinecubed.com.

When receiving a verifiable user request, we will confirm that the person making the request is the user about whom we have collected the Personal Information. We will generally avoid requesting additional information for such purposes. However, if we cannot verify the identity of the user from the information already maintained by us, we may request certain additional information that will be only used for the purposes of verifying the user’s identity.

We will address your verifiable user request in an appropriate manner, and we will respond to your request in the term that is applicable, if none is applicable, within 45 (forty-five) days from the date on which your request was received.

The applicable response window depends on your jurisdiction:

EEA/UK: 30 calendar days from receipt, extendable by up to 60 additional days for complex or numerous requests, in accordance with Article 12 of the EU GDPR and UK GDPR.
Canada: the timeframe required by applicable Canadian law (generally 30 days under PIPEDA, with extensions where permitted).
United States and other jurisdictions: 45 days, unless a different period is required by applicable law.

Provided you have a password-protected account with us, we may verify your identity, by authenticating you through that account.

However, please note that some of your rights may be subject to certain limitations or exemptions, as provided under applicable law.

15.1 Requests made through authorized agents.

Please note that you also may designate an authorized agent to make the request on your behalf and exercise your rights under this Privacy Policy. Before accepting your agent’s request, we will take all steps necessary to verify you have duly authorized such agent to act on your behalf, for which they must provide us a signed written authorization or a copy of a power of attorney.

Please note that the parents and/or legal guardians of a child may exercise the rights on behalf of such child.

16. Communications

We may send you service-related communications. You can opt out of commercial messages at any time. by contacting us at the following email address: legal@joinecubed.com

If you reside in the EEA, the UK, or another jurisdiction requiring opt-in consent for direct-marketing communications, we will only send marketing communications based on your prior consent, which you may withdraw at any time without affecting the lawfulness of processing carried out before withdrawal. You may withdraw your consent or unsubscribe by following the instructions provided in each marketing communication or by contacting us at the email address above.

17. Do Not Track Settings

Some third parties may collect aggregate information about the users’ online activities over time and across websites when they use the Sites. The service does not recognize Do Not Track signals.

18. Children’s Privacy

The Service is not intended for individuals under 18 years old or the equivalent minimum age in the relevant jurisdiction. If you are underage, please do not use Ecubed Services and do not provide us with any Personal Information.

We do not knowingly collect data from minors. If we become aware of such data, we will delete it.

19. Changes To This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version on the Program and update the ‘Last Updated’ date above. For material changes — particularly those affecting how we collect, use, or share Personal Information, or your rights — we will provide reasonable advance notice through the Services or by email before the changes take effect, and where required by applicable law, we will obtain your consent. Continued use of the Service after the effective date of changes constitutes acceptance of the revised Policy, except where consent is required

20. Contact Us

Thanks for reading our Privacy Policy. If you have any questions, requests, comments, and/or concerns regarding this Privacy Policy, please contact us at the following e-mail: legal@joinecubed.com and phone number (408) 516-4155.