October Communications Ltd (t/a Cubisly) Policies
1. Accessibility & Inclusion Policy
1.1 Our commitment
October Communications Ltd (t/a Cubisly) values the diversity of its learners and is committed to providing a digital learning environment that is accessible to as many people as possible.
1.2 Current status
- • Video captions & transcripts – not yet available.
- • Alt‑text on images – work in progress.
- • Keyboard‑only navigation & basic screen‑reader support – partially supported.
1.3 Aspirational target
We aim to achieve WCAG 2.1 AA conformance across cubisly.com
1.4 Requesting adjustments
Learners who require alternative formats or reasonable adjustments can email learn@cubisly.com. We respond within 5 business days and aim to implement agreed adjustments within 14 days where technically feasible.
1.5 Feedback & contact
Accessibility feedback can be directed to Daniel Nelson (Accessibility Lead) via learn@cubisly.com.
2. Cancellation & Refund Policy
2.1 Cooling‑off period
Consumers in the US/UK/EU may cancel any purchase within 14 calendar days of the transaction date and receive a full refund, provided the learner (a) has not completed the course and (b) has not downloaded any paid digital content.
2.2 Digital‑download rule
Where course materials are sold as stand‑alone digital downloads, your right to a refund ends once the download starts, unless mandatory consumer law grants additional rights.
2.3 Bundles & subscriptions
- • Bundles follow the same 14‑day rule.
- • Cubisly currently offers no recurring subscription, therefore no pro‑rata refunds apply.
2.4 How to cancel
- Use the Self‑Service Dashboard under My Account → Purchases, or
- Email learn@cubisly.com with your order ID.
Refunds are processed to the original payment method (Stripe) within 14 days of approval.
2.5 Business/enterprise contracts
Corporate agreements may include bespoke cancellation terms as stated in the relevant order form. Where silent, this policy applies.
3. Cookie Policy
3.1 What are cookies?
Cookies are small text files placed on your device to store data that can be recalled by a web server.
3.2 How we use cookies
| Category | Purpose | Examples |
|---|---|---|
| Strictly necessary | Site security, log‑in and load balancing | Session ID |
| Functional | Remember preferences | Chatwoot chat state |
| Analytics | Measure site usage | Google Analytics 4, Hotjar |
| Advertising | Deliver and measure ads | Google Ads, Meta Pixel |
3.3 Consent
A cookie banner asks new visitors to opt in to non‑essential cookies. Continued browsing without interaction is treated as consent, as cubisly.com currently lacks a “Reject” button.
3.4 Cookie lifespan
Non‑essential cookies last between 90 days and 2 years (provider defaults). Session cookies expire when you close your browser.
3.5 Managing cookies
You can delete or block cookies via your browser settings at any time.
4. Privacy Policy
4.1 Scope
This policy describes how Cubisly collects and processes personal data when you visit cubisly.com or participate in our courses.
4.2 Who we are
October Communications Ltd (t/a Cubisly), Company No 8816416, 85 Great Portland Street, First Floor, London W1W 7LT, United Kingdom.
4.3 Data we collect
- Account data – name, email, hashed password, demographics.
- Learning data – course progress, assessment results, certificates.
- Usage data – pages visited, device information, IP address.
- Payment data – last four digits of card, expiry month/year, billing address (processed by Stripe).
- Marketing preferences.
4.4 Lawful bases (GDPR)
| Purpose | Legal basis |
| Delivering courses you enrol in | Contract performance |
| Analytics & service improvement | Legitimate interest |
| Marketing emails | Consent |
| Compliance with legal obligations | Legal obligation |
4.5 Processors & transfers
Data is stored on 20i servers in the UK/EU and may be processed by:
- Google Analytics 4
- Google Ads
- Meta Ads
- Hotjar
- Chatwoot
- Mautic
- Stripe (payments)
Where data is transferred outside the UK/EU, we rely on Standard Contractual Clauses or adequacy decisions.
4.6 Retention
Inactive learner accounts are retained indefinitely unless you request deletion. Back‑ups may persist for up to 30 days.
4.7 Your rights
You may request access, correction, deletion, restriction, portability, or object to processing by emailing or learn@cubisly.com. We respond within 30 days.
4.8 Security
- TLS encryption in transit & AES‑256 at rest
- Regular security patches & vulnerability scans
- Role‑based internal access controls
4.9 Marketing
Marketing emails are sent only with explicit opt‑in consent. You may unsubscribe at any time via the footer link or by contacting us.
4.10 Children
Cubisly is restricted to users 18 years or older. We do not knowingly collect data from minors.