PRIVACY POLICY

of Subty application and Subty Website

Last updated on: May 18, 2023

Subty, a product of Subty Inc., a Delaware company, incorporated on 28.03.2023 and located at 228 Park Ave S PMB 85451 New York, NY 1003, with EIN: 92-3507670 (hereinafter – «Company») is a marketplace of subscriptions that allows consumers to browse and purchase products or services relating to subscription services of third parties.

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of Your information when you use our Service or/and application and tells you about your privacy rights and how the law protects you.

We use your Personal data to provide and improve our Service. By using the Service and/or Application, you agree to the collection and use of information in accordance with this Privacy Policy.


1. Interpretation and Definitions

1.1. Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.2. Definitions
For the purposes of this Privacy Policy:

● "Account" means a unique account created for You to access our Service or parts of our Service.
● "Application" means the software program provided by the Company downloaded by You on any electronic device, named Subty.
● "Company" (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to Subty Inc.
● "Country" refers to United States of America.
● "Cookies" are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
● "Device" means any device that can access the Service such as a computer, a cell phone or a digital tablet.
● "Personal Data" is any information that relates to an identified or identifiable individual.
● "Service" refers to the Website and/or Application.
● "Service Provider" means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
● "Usage Data" refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
● "You" means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

2. Collecting and Using Your Personal Data

2.1. Types of Data Collected

2.1.1. Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

● Email address
● First name and last name
● Phone number
● Address, State, Province, ZIP/Postal code, City
● Usage Data

2.2. Usage Data
Usage Data is collected automatically or manually when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
2.3. Information Collected while Using the Application
While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

● Information regarding your location

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

3. Use of Your Personal Data

3.1. The Company may use Personal Data for the following purposes:

● To provide and maintain our Service, including to monitor the usage of our Service.
● To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
● For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
● To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
● To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
● To manage Your requests: To attend and manage Your requests to Us.
● For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
● For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

3.2. We may share Your personal information in the following situations:

● With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
● For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
● With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
● With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
● With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
● With Your consent: We may disclose Your personal information for any other purpose with Your consent.


3.3. This information will also be used to communicate with you about and to process and complete your purchases, returns, and inquiries. We will use the information and content you provide to administer the Service & Application, including to personalize products and services to you, market to you, analyze other data we collect, identify other potential customers (e.g. determine how many customers are a certain size), and develop new goods and services. This information may also be used to allow you to participate in polls, sweepstakes, promotions, and contests and to administer these activities. This information may be used to establish your account with Subty.

3.4. We may also use Personal Information as we believe to be necessary or appropriate for certain essential purposes, including: to comply with applicable law and legal process; to respond to requests from public and government authorities, including public and government authorities outside your country of residence; to detect, prevent, or investigate potential security incidents or fraud; to facilitate the functionality of our mobile applications and websites; to provide important product safety information and notice of product recalls; to enforce our terms and conditions; to protect our operations or those of our affiliates; to protect our rights, privacy, safety or property, security and/or that of our affiliates, you or others; and to allow us to pursue available remedies or limit the damages that we may sustain.

3.5. Use of cookies. Subty might use cookies to support the performance of our site and to remember choices you have made, such as preferred language. You can modify your browser settings to control whether your computer or other device accepts or declines cookies. If you choose to decline cookies you may not be able to use certain features of Subty, or certain Subty functionality. You can delete cookies from your browser; however, that means that any settings or preferences managed by those cookies will also be deleted and you may need to recreate them. Depending on your mobile device, you may not be able to control tracking technologies through settings. The emails we send might include a web beacon or similar technology that lets us know if you received or opened the email and whether you clicked on any of the links in the email.

3.6. Google Analytics. Subty might use Google Analytics, a web analytics service offered by Google. Google Analytics assists us in gathering analytics and statistical data in connection with Subty. On our behalf Google processes this information to analyze the usage of Subty, create reports on Subty activities, and provide other services related to Subty and internet usage for us. If you have any questions or concerns with regard to Google Analytics’ privacy practices, you can review their privacy policy at https://policies.google.com/privacy?hl=en.

3.7. Facebook & Instagram. If you interact with Subty on the Facebook platform, Subty might collect your public Facebook/Instagram profile information, which includes your first and last name and your profile picture. Subty might also collect other information from the Facebook platform; if so you will be prompted about what specific information will be collected when you connect to Subty for the first time.

3.8. Social plugins. Subty might give you the option to share information by email, social or other sharing applications, using the clients and applications on your smart device. Social plugins (including those offered by Facebook, Twitter, Instagram, and Pinterest) allow you to share information on those platforms. Social plugins and social applications are operated by the social network themselves and are subject to their terms of use and privacy policies.

We use reasonable administrative, logical, physical and managerial measures to safeguard your information against loss, theft and unauthorized access, use and modification. We may retain information as required or permitted by applicable laws and regulations, including to fulfill the purposes described in this Statement.

4. Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

5. Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

6. Disclosure of Your Personal Data

6.1. Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

6.2. Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

7. Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

● Comply with a legal obligation
● Protect and defend the rights or property of the Company
● Prevent or investigate possible wrongdoing in connection with the Service
● Protect the personal safety of Users of the Service or the public
● Protect against legal liability

8. Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

9. Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

10. Analytics

We may use third-party Service providers to monitor and analyze the use of our Service.

11. Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or promotional materials and other information that may be of interest to You. You may opt-out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.

12. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

13. California Consumer Privacy Act (CCPA) Privacy Notice. This Privacy Notice applies to California consumers and supplements the Statement.

13.1. Personal Information We Collect. We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“CCPA personal information”). We have collected categories of CCPA personal information noted in the Collection and Use of Information section of this Statement within the last twelve (12) months.

13.2. Use of CCPA personal information. We use categories of CCPA personal information listed above for the purposes noted in the Collection and Use of Information section of this Statement.

13.3. Categories of CCPA personal information disclosed for a business purpose. We disclose the categories of CCPA personal information noted in the Collection and Use of Information section of this Statement for business purposes. Specifically, we disclose these categories of information for business purposes to the following categories of third parties: Subty Providers, the Netflix family of companies, an entity engaged in a business transfer, law enforcement, courts, governments and regulatory agencies.

13.4. Sources of CCPA personal information. We explain our sources of information in the Collection of and Use Information section of our Statement. (Please see that section for more information that may be of interest to you.)

13.5. Your rights under the CCPA.
You have the right to request that we disclose: what categories and specific pieces of CCPA personal information have been collected about you; the categories of sources from which CCPA personal information are collected; our business or commercial purpose for collecting, using, or disclosing CCPA personal information; the categories of third parties with whom we share CCPA personal information; the categories of CCPA personal information we have disclosed about you for a business purpose. We do not sell personal information.
You have a right to receive a copy of the specific CCPA personal information we have collected about you.
You have a right to deletion of your CCPA personal information, subject to exceptions under the CCPA.
You have a right not to receive discriminatory treatment for exercising any of your CCPA rights. We will not discriminate against you based on your exercise of any of your CCPA rights.
You can assert these rights only where we receive a verified request from you. For information on how to exercise your rights, please see the Your Information and Rights section of this Statement.
If you are a consumer under the CCPA and wish to contact us through an authorized agent, the authorized agent can submit a request on your behalf at info@subty.app along with a statement signed by you certifying that the agent is authorized to act on your behalf. In order to verify the request and your identity, we may ask you to verify your identity. Because we only collect limited information about individuals, we may be unable to verify requests to the standard required by the CCPA.

14. Links to Other Websites or 3^rd Party Services

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

15. International Data Transfers

Whenever in the course of sharing information we transfer personal information to countries outside of the EEA and other regions with comprehensive data protection laws, we will ensure that the personal information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection. We ensure that appropriate contractual, technical, and organizational measures are in place.

16. Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

17. Contact Us

If you have any questions about this Privacy Policy, You can contact us:

● By visiting this page on our website: www.subty.app
● By sending us an email: info@subty.app

Subty Inc.
228 Park Ave S PMB 85451 New York, NY 1003