Privacy Policy

Overview

This is the Privacy Policy for the website hosted at https://www.subtica.com/ (“our site”), our products and services, and for other Subtica activities at which you may provide your personal data, such as sponsored events or trade shows. We are committed to protecting and respecting your privacy.

This policy (together with our terms of service and any other documents referred to in it) sets out:

1. Information we collect
2. Cookies and other tracking technologies
3. How we use your information
4. Our promotional updates and communications
5. Lawful Bases
6. Who we share your information with
7. Where we store your information
8. Child safety
9. Payment processing
10. How we protect your information
11. How long we keep your information
12. EU Citizen Rights
13. Note to Users Outside the United States

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By engaging in our site and services, you acknowledge you have read and understood this privacy policy. To the extent applicable privacy law includes the European Economic Area General Data Protection Regulation, (the “GDPR”) with respect to personal data collected by us.

Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.

Information we collect

We will collect and process the following personal data from you:

1. Information you give us, which may consist of:
   1. Information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product, in discussion boards or other social media functions on or via our site, enter a competition, promotion or survey, submit a query, providing information at trade shows or sponsored events and when you report a problem with our site;
   2. Your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph, login and password details;
   3. Technical information, which may include the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, operating system and platform;
   4. Information about your visit, which may include the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
   5. IP Location data, where IP addresses are collected and location is inferred based on IP location.
   6. Information collected from other platform activities.

If you are using our products or services as a developer, the following information regarding your end users may be received and processed by us:

1. “End User Technical Information”: This refers to technical information related to an end user’s mobile device or computer, such as: device type, operating system, “End User Transaction Information”: This refers to transaction information related to an end user’s activities with respect to your app or other digital product, and may include:
   1. Last seen time that the end user used your app or digital product;
   2. Apple receipt file;
   3. Google purchase token;
   4. “Optional End User Information”: This refers to information that we may receive if you select or enable this option in our products, which may include: user ID of the end user in your app or digital product;
   5. Additional attribution or metadata associated with an end user;
   6. End User Technical Information, End User Transaction Information, and Optional End User Information are collectively referred to as “End User Information”.

Cookies and other tracking technologies

Our site uses cookies and/or other similar technologies such as device-IDs, in-app codes, pixel tags, analytics tools or web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content. Our site uses cookies and similar technologies to distinguish you from other users of our site. This helps us to provide you with a good experience when you browse our site and use our service and also allows us to improve our site. Most web browsers automatically accept cookies and similar technologies, but if you prefer, you can change your browser to prevent that and your help screen or manual will tell you how to do this. However, you may not be able to take full advantage of our website if you do so. A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser. Others are used to remember you when you return to the site and will last for longer. We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

How we use your information

Information we collect:

1. We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
   1. To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
   2. To keep our site safe and secure.
   3. For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
   4. To improve our site to ensure that content is presented in the most effective manner for you and for your computer.
   5. To allow you to participate in interactive features of our site and service, when you choose to do so.
   6. To deliver and improve our products and services and your overall user experience.

Information we receive from other sources:

1. We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

End User Information:

1. We will only use End User Information to provide our services and products to you, in accordance with the agreement agreed to and signed by us.

Our promotional updates and communications

Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products and services. You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by submitting your email address here.

Lawful Bases

We will only collect and process personal data where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to operate the site or deliver any products or services you have requested) and “legitimate interests”. We rely on our legitimate interests as our lawful basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law).

How we use your information

We may share your information with selected third parties which may include:

1. Analytics and search engine providers that assist us in the improvement and optimization of our site and subject to the cookie section of this policy (this will not identify you as an individual).

Where we store your information

The data that we collect from you will be stored securely on Amazon Web Services (“AWS”) in the USA.

Child safety

The site is intended for use only by persons who are at least 16 years of age. By using the site, you confirm to us that you meet this requirement. If you are under the age of 16, you confirm you have received permission from your parent or guardian before using this site or sending us personal information.

Payment processing

Payment details you provide will be encrypted using secure sockets layer (SSL) technology before they are submitted to us over the internet. Payments made on the site are made through our payment gateway provider. You will be providing credit or debit card information directly to the operator which operates a secure server to process payment details, encrypting your credit/debit card information and authorizing payment. Information which you supply is not within our control and is subject to the operator’s own privacy policy and terms and conditions.

Fees and Payment

1. Subscription fees

   You agree to pay all fees associated with the subscription plan you select, as listed on the Subtica Pricing page.

   Subscription fees may change upon renewal of your Subscription Term. Subtica will provide reasonable prior notice of any changes. By continuing to use the Service after the updated fees take effect, you authorize Subtica to charge the new amount to your stored payment method.

2. Billing disputes

   If you believe that a billing error has occurred, you must notify Subtica within thirty (30) days from the date of the invoice containing the disputed charge to request a correction or refund. Disputes submitted after this period may not be eligible for review.

3. Automatic Renewal and Cancellation

   All subscription plans automatically renew at the end of each Billing Period unless cancelled in accordance with this section.

   Cancellation stops future charges, but does not retroactively refund payments already processed, except where expressly stated below.

   1. 14-Day Free Trial

      Some subscription plans include a 14-day free trial.

      You may cancel your trial at any time during the trial period without being charged. If you do not cancel before the trial ends, your subscription will automatically convert to a Monthly plan, and the applicable Monthly fee will be charged to your stored payment method.

   2. Monthly Subscription

      Monthly subscriptions begin automatically after the free trial (if applicable).

      You may cancel your trial at any time during the trial period without being charged. If you do not cancel before the trial ends, your subscription will automatically convert to a Monthly plan, and the applicable Monthly fee will be charged to your stored payment method.

   3. Annual Subscription

      Annual subscriptions are billed upfront for the entire 12-month term.

      You may cancel at any time; cancellation applies only to the next renewal term. Refunds: You may request a full refund within thirty (30) days of the initial annual charge. Refund requests submitted after this 30-day period cannot be processed.

4. Payment Authorization

   By subscribing, you authorize Subtica to charge your stored payment method for all applicable fees at the start of each Billing Period and upon each renewal, until you cancel your subscription.

How we protect your information

Security is one of our biggest priorities at Subtica. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

1. All application data is secured in transit using TLS.
2. Any payment transactions will be encrypted using SSL.
3. Subtica audits changes to the application throughout the development lifecycle: architecture reviews are performed as well as stringent automated and manual code review processes.
4. Subtica monitors application servers, infrastructure, and the Subtica network environment to detect potential abuse.
5. Subtica uses Amazon Web Services (“AWS”) to persistently store Customer data and does not host Customer data on its premises. AWS is a leading cloud provider, and holds industry best security certifications, such as SOC2 and ISO 27001. Customer data sent to Subtica from around the world is sent to AWS data centers located in the United States.

How long we keep your information

We retain personal data during any period in which you have expressed an interest in our products and services, for as long as you have an account with us in order to meet our contractual obligations to you, and for two years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

EU Citizen Rights Under GDPR

You have the right under certain circumstances:

1. to be provided with a copy of your personal data held by us.
2. to request the rectification or erasure of your personal data held by us.
3. to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example).
4. to object to the further processing of your personal data, including the right to object to marketing.
5. to request that your provided personal data be moved to a third party.
6. Your right to withdraw consent:
   1. Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by going here.

You do, however, have the right to approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html for data protection authorities in the EU).

If you have questions, concerns, or requests related to this Privacy Policy, please contact us at: support@subtica.com

Note to users outside the United States

Subtica is based in the United States. The Site and our products and services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.