Last updated 10th January 2024.

Privacy Policy

Your privacy is important to us. It is Subbly Ltd's policy to respect your privacy regarding any information we may collect from you across our website, https://www.subbly.co, and other sites we own and operate.

Information we collect

Log data

When you visit our website, our servers may automatically log the standard data provided by your web browser. This data is considered “non-identifying information”, as it does not personally identify you on its own. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

We may also collect data about the device you are using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

Personal information

We may ask for personal information, such as your:

This data is considered "identifying information", as it can personally identify you.

We only request this information when you interact with our services—like signing up for an account, making use of our platform features, paying for access, or subscribing to our newsletter. We only use collected personal information in the context of providing or improving these services.

Business data

Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

How we collect information

We collect information by fair and lawful means, with your knowledge and consent. We also let you know why we’re collecting it and how it will be used. You are free to refuse our request for this information, with the understanding that we may be unable to provide you with some of your desired services without it.

Use of information

We may use a combination of identifying and non-identifying information to understand who our visitors are, how they use our services, and how we may improve their experience of our website in future. We also use this information to gain insights into demographics, product and service popularity, and the effectiveness of our marketing activity. We do not disclose the specifics of this information publicly, but may share aggregated and anonymised versions of this information, for example, in website and customer usage trend reports.

In addition to the above, we may utilize non-personally identifiable information about our merchants, such as business name, logo, and non-performance-based metrics (e.g., features in use on Subbly), to create and publish testimonials and merchant stories ('customer stories') for promotional purposes. This use of merchant data is intended to showcase the experiences and successes of our users on our platform, while respecting their privacy and confidentiality. Merchants have the right to request the removal of their information from these promotional materials at any time.

We primarily use your personal information for the purposes of granting you access to engage with certain areas of our site, to charge you for your subscription, and to notify you of any changes to your account and service.

We may use your personal details to contact you with updates about our website and services, along with promotional content that we believe may be of interest to you. If you wish to opt out of receiving promotional content, you can follow the “unsubscribe” instructions provided alongside any promotional correspondence from us.

Merchant Data Rights and Consent

As part of our commitment to privacy and respecting the rights of our merchants, we provide options for consent regarding the use of your business-related information in our promotional materials, such as testimonials and merchant stories. All Subbly merchants have the option opt-out of having their non-personally identifiable business information (such as your business name, logo, and selected business metrics) used in our promotional content

For more information on this, please refer to Section 13 of our Terms and Conditions. If you wish to request the removal of your business information from our existing promotional materials, you can do so at any time. Requests for removal or changes in consent can be made by contacting us directly at [email protected]. We will process your request in a timely manner, in accordance with our commitment to respecting your rights and privacy.

Data processing and storage

The personal information we collect is stored and processed in , or where we or our partners, affiliates and third-party providers maintain facilities. We only transfer data within jurisdictions subject to data protection laws that reflect our commitment to protecting the privacy of our users.

We only retain personal information and business data for as long as necessary to provide a service, or to improve our services in future. While we retain this data, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure, and cannot guarantee absolute data security.

If you request your personal information be deleted, or where your personal information becomes no longer relevant to our operations, we will erase it from our system within a reasonable timeframe.

Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

Third-party access to information

We use third-party services for:

These services may access our data solely for the purpose of performing specific tasks on our behalf. We do not share any personally identifying information with them without your explicit consent. We do not give them permission to disclose or use any of our data for any other purpose.

We may, from time to time, allow limited access to our data by external consultants and agencies for the purpose of analysis and service improvement. This access is only permitted for as long as necessary to perform a specific function. We only work with external agencies whose privacy policies align with ours.

We will refuse government and law enforcement requests for data if we believe a request is too broad or unrelated to its stated purpose. However, we may cooperate if we believe the requested information is necessary and appropriate to comply with legal process, to protect our own rights and property, to protect the safety of the public and any person, to prevent a crime, or to prevent what we reasonably believe to be illegal, legally actionable, or unethical activity.

We do not otherwise share or supply personal information to third parties. We do not sell or rent your personal information to marketers or third parties.

Children’s Privacy

We are committed to protecting the privacy of children who use our services. We encourage parents to engage with us in protecting their children’s privacy, ensuring a safe and enjoyable online experience. Please refer to our Children’s Privacy Policy for more information.

Limits of our policy

This privacy policy only covers Subbly Ltd's own collecting and handling of data. We only work with partners, affiliates and third-party providers whose privacy policies align with ours, however we cannot accept responsibility or liability for their respective privacy practices.

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. If you are a registered user on https://www.subbly.co, we will notify you using the contact details saved in your account. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

Your rights and responsibilities

As our user, you have the right to be informed about how your data is collected and used. You are entitled to know what data we collect about you, and how it is processed. You are entitled to correct and update any personal information about you, and to request this information be deleted. You may amend your account information at any time, using the tools provided in your account control panel.

You are entitled to restrict or object to our use of your data, while retaining the right to use your personal information for your own purposes. You have the right to opt out of data about you being used in decisions based solely on automated processing.

Feel free to contact if you have any concerns or questions about how we handle your data and personal information.

 

Subbly Ltd Data Controller

Stefan Pretty
[email protected]

 

Subbly Ltd Data Protection Officer

Stefan Pretty
[email protected]

Submit data requests as an EU citizen using Subbly as a merchant here.

This policy is effective as of 21 May 2018.