1. Introduction

Subba Inc. ("Subba," "we," "our," or "us" ) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our subscription management and payment services, including our website, mobile application, and the Subba Card (collectively, the "Services"). By using our Services, you consent to the data practices described in this Privacy Policy. If you do not agree with the data practices described in this Privacy Policy, you should not use the Services.

Information supplied or gathered via websites run by other entities or organizations that we may link to or that others may connect to us is not governed by this privacy policy. The activities and privacy practices of third-party websites are not within our responsibility

2. Information we collect

2.1 Personal Information

We collect personal information that you provide directly to us when you use our Services. This may include:

• Contact information (e.g., name, email address, phone number, postal address)
• Financial information (e.g., bank account details, credit card information)
• Government-issued identification numbers (e.g., Social Security Number, driver's license number)
• Login credentials for your Subba account
• Information about your subscriptions and recurring expenses
• Transaction history and payment information

2.2 Information Collected Automatically

We may automatically collect certain information about your device and how you interact with our Services, including:

• Device information (e.g., IP address, browser type, operating system)
• Usage data (e.g., pages visited, features used, time spent on the Services)
• Location information (with your consent)
• Your device content like images (with your consent)
• Information collected via cookies

2.3 Information from Third Parties

We may receive information about you from third parties, including:

• Financial institutions and payment processors (e.g., through our integration with Plaid and Stripe)
• Credit bureaus and identity verification services
• Publicly available sources

3. How We Use Your Information

We use your personal information for various purposes, including:

• Providing and improving our Services
• Processing transactions and managing your account
• Analyzing your financial data to offer personalized insights and recommendations
• Assessing eligibility for our Sub-now-pay-later (SNPL) feature
• Detecting and preventing fraud, security breaches, and other potentially prohibited or illegal activities
• Complying with legal obligations and enforcing our terms of service
• Communicating with you about our Services, including sending important notices and promotional materials (subject to your communication preferences)

4. Legal Basis for Processing (for EEA Users)

If you are located in the European Economic Area (EEA), we collect and process your personal information based on one or more of the following legal grounds:

• Performance of a contract (e.g., to provide you with our Services)
• Your consent (e.g., to send you marketing communications)
• Compliance with legal obligations
• Our legitimate interests, provided that such interests are not overridden by your rights and freedoms

5. How We Share Your Information

We may share your personal information with third parties in the following circumstances:

• With service providers and business partners who assist us in providing our Services (e.g., payment processors, cloud storage providers)
• With financial institutions and payment networks to facilitate transactions
• With credit bureaus and identity verification services to assess creditworthiness and prevent fraud
• In response to legal process or government requests, or to protect our rights, privacy, safety, or property
• With your consent or at your direction

We do not sell your personal information to third parties for their own marketing purposes.

6. Data Retention and Security

We retain your personal information for as long as necessary to provide our Services, comply with legal obligations, resolve disputes, and enforce our agreements. We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information, including:

• Access and portability: You can request a copy of your personal information or transfer it to another service provider.
• Correction: You can request that we update or correct inaccurate or incomplete information.
• Deletion: You may delete your account, by logging into your account or calling us at 214- 310-4702. Please note that we may retain certain information as required by law or for our legitimate business purposes.
• You can request that we delete your personal information, subject to certain exceptions.
• Objection and restriction: You can object to or request restriction of certain processing activities.
• Withdrawal of consent: You can withdraw your consent at any time for processing activities based on consent.

Please note that we may retain certain information as required by law or for our legitimate business purposes. To exercise these rights, please contact us using the information provided in the "Contact Us" section below.

8. Children's Privacy

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information from our files as soon as possible.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes.

10. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:
Email: [email protected]
Phone at: 214-310-4702.

11. Additional Information for California Residents

If you are a California resident, you have certain rights under the California Consumer Privacy Act (CCPA). One of such rights permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you're a California resident and would like to make such a request, please contact us at:
Email: [email protected]
Phone at: 214-310-4702.