Privacy Notice

Last updated: 30/04/2025

1. About this Notice

1.1. This Privacy Notice

This Privacy Notice ("Notice") explains how we collect, share, and use any information that, alone or in combination with other information, relates to you ("Personal Data") when you ("you" and "your") use our website https://www.subler.co (the "Website"), or when you contract with us as a customer or a supplier.

1.2. Rights

This Notice also sets out the rights that you have in relation to the Personal Data that we process about you and how you can exercise them.

1.3. Privacy Obligations

We treat compliance with privacy obligations seriously. This is why we have developed this Notice, which describes the standards we apply to protect Personal Data.

1.4. Data Controller

For the purposes of this Notice, we act as the data controller for the Personal Data that is collected via the Website. As a data controller, we are responsible for ensuring that the processing of Personal Data complies with applicable data protection law, and specifically with the General Data Protection Regulation.

1.5. Read Carefully

Please take the time to read this Notice carefully. If you have any questions or comments, please contact ankit@subler.co.

2. What Personal Data do we collect and why?

2.1. Personal Data Collection and Processing

The types of Personal Data that we collect about you, and the reasons why we process it, are as follows:

• Email address, electronic identification data (e.g., when you sign up through Google or Outlook):

  • Why we collect it: Providing our services to our clients (including free-trial users), including managing access to our services and enabling the pooling feature
  • Legal grounds for processing: Contractual necessity

• Identification data, electronic identification data, and Internet connection utilization data:

  • Why we collect it: To draw up commercial and usage statistics related to the use of our services
  • Legal grounds for processing: Our legitimate interest in knowing the popularity of our services in order to take action to optimize its visibility or interface

• Identification data, electronic identification data, and Internet connection utilization data:

  • Why we collect it: To provide tailored responses to your requests for information through the chatbot or when you contact us
  • Legal grounds for processing: Our legitimate interest in responding to requests

• Email address, identification data:

  • Why we collect it: Managing our relationship with customers and suppliers (including invoices and payments)
  • Legal grounds for processing: Contractual necessity

• Name and surname, email address:

  • Why we collect it: Sending you marketing updates and messages regarding our services
  • Legal grounds for processing: Consent (unless a legal exception applies, in which case we rely on our legitimate interest in promoting our services)

• Any information relevant or potentially relevant to a dispute or legal proceeding affecting us:

  • Why we collect it: Disputes and legal proceedings
  • Legal grounds for processing: Our legitimate interest in defending our rights and interests in court

2.2. Automatic Information Collection

We also collect certain information automatically from your device. This includes:

• IP address
• Device type
• Unique device identification numbers
• Browser type
• Broad geographic location (e.g., country or city-level)
• Technical information
• Interaction data (e.g., pages accessed, links clicked)

3. Who do we share your Personal Data with?

We disclose your Personal Data to the following categories of recipients:

• Third-party vendors and service providers who process data on our behalf or for purposes described in this Notice. This includes vendors for:

  • Invoice and payment services
  • Customer and lead support
  • Website hosting
  • Marketing and newsletters
  • Data analytics

• Law enforcement, regulatory, government agencies, courts, or third parties where required by law or regulation, or to exercise, establish, or defend our legal rights, or to protect vital interests.

• Auditors, advisors, legal representatives, and agents for legitimate business purposes, under contractual restrictions on usage.

• Potential buyers and their agents in connection with any business acquisition, provided they use your data only as described in this Notice.

• Other parties with your consent.

4. How We Protect Your Privacy

We process Personal Data in accordance with this Notice as follows:

• Fairness: We process your Personal Data fairly and transparently.
• Purpose limitation: We process Personal Data for specified and legitimate purposes only.
• Data minimization: We collect only the Personal Data necessary for the purposes described.
• Accuracy: We keep your Personal Data accurate and up to date.
• Storage limitation: We retain Personal Data only for as long as necessary.
• Integrity and confidentiality: We use appropriate security measures to protect your Personal Data.