Subotiz and/or its Affiliates (“Subotiz”, "we", "us" or "our") is committed to protecting your privacy. This Privacy Policy describes how Subotiz collects, uses, shares and otherwise processes the Personal Data of individuals covered by this Privacy Policy (the “Policy”), including choices and rights available to such individuals with respect to their Personal Data.

This Privacy Policy applies to all Subotiz Users, End-Customers, visitors to the Websites, anyone contacting and individuals who engage with us or we engage with, whereby we control or determine the means and purposes of processing their Personal Data, or otherwise only process their Personal Data as per the data controller’s instruction (“you” or “your”). Please note that not all provisions of this Policy will apply to you and your Personal Data, as this will depend on your specific relationship with us. The capitalized terms used in this Policy but not defined herein shall have the same meaning as defined in the Terms of Service.

We may collect your Personal Data in various ways, which could either be directly from you or from third parties.

Depending on who you are and how we are engaging with you, we may collect and process information including:

In most cases, we collect your Personal Data on the basis of your desire to utilize the Services from us or engage with us, including to complete a transaction using our Services. Therefore, our processing in many cases occurs on the basis of your consent or the need to perform a contract or commitment that we may have with you. However, in addition to this, there are other bases on which we may collect or process your Personal Data. These are as follows:

The purposes for which we collect and process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:
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4.1 To Provide Websites and Services: 

We offer products and services in multiple countries and regions. You understand that your Personal Data may be transferred to a location outside of your country/region for storage or processing. In general, your Personal Data will be stored in the United States. However, for the purposes of providing services, statistics, or analysis, we may transfer your Personal Data across borders to regions outside the United States. In such cases, we will ensure that your Personal Data is provided with an equivalent level of protection in your country or region and that cross-border data transfers are conducted through encrypted channels.

We will retain your Personal Data only for the period necessary to achieve the purposes for which we collected it. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of your Personal Data, the potential risks of unauthorized use or disclosure of your Personal Data, the purposes for processing, and whether we can achieve these purposes through other means or in accordance with applicable legal requirements. We will also retain and use your Personal Data to the extent necessary to comply with legal obligations, resolve disputes, and enforce our policies. The criteria for determining the retention period include:

After the retention period has expired, we will delete or anonymize your Personal Data in accordance with applicable legal requirements.

Please note that when you successfully delete your Subotiz Account, we will delete or anonymize your Personal Data.

Due to applicable legal and security technology limitations, we may not be able to immediately delete the corresponding information from our backup systems. We will securely store your Personal Data and restrict any further processing until the backup can be deleted or anonymized.

If we terminate our Services, we will notify you at least thirty days in advance and, after termination, delete or anonymize your Personal Data.

We do not knowingly collect or solicit Personal Data from a child under the age of 18 (or the age of majority in your jurisdiction of residence), nor do we knowingly allow children to use our Service. If you are a child under 18 (or the age of majority in your jurisdiction of residence), please do not send any information about yourself to us, including but not limited to your name, address, telephone number, or email address. No one under the age of 18 may provide any Personal Data. If you believe that we have collected Personal Data from a child, please contact us at the email and address provided below under “Contact Us”. In the event that we learn that we have collected Personal Data from a child, we will delete that information as soon as commercially practicable.

We take reasonable and appropriate measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other Personal Data entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis. We have also implemented specific security measures such as firewalls, intrusion detection systems, and access control to protect your Personal Data.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your Personal Data.

In the event of any actual or suspected breach or compromise of Personal Data (a "Data Breach"), we will immediately initiate our emergency response plan, conduct an internal investigation, and cooperate with regulatory authorities in their investigation. Meanwhile, we will provide notice by email, posting a notice in your Subotiz Admin or any reasonably effective communication method in a timely manner, which contains information about: the basic situation and possible impact of the Data Breach, any reasonable actions have been taken or will be taken, any reasonable preventions to mitigate any future Data Breach risk, in accordance with the requirements of laws and regulations. At the same time, we will report the Data Breach to the relevant regulatory authorities whereas it is required in accordance with the requirements of the regulatory authorities.
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We may share your information with third parties listed below for the purposes set forth in this Privacy Policy, subject to a lawful basis and in compliance with applicable laws  (including, as applicable, after providing you additional notice, or obtaining your consent).

To operate our business, we may engage our affiliates and third parties to provide services such as technical infrastructure services, function development, operation and maintenance services, cloud hosting services, customer service technical support, and message push services. Therefore, your Personal Data may be sent and processed to our affiliates and service providers, available at Subotiz’s Subprocessors. 

Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including Personal Data, as described in this Policy. We will not transmit your Personal Data until we have complied with the applicable laws and regulations regarding cross-border transmission. We will take reasonable measures to ensure that your Personal Data is subject to appropriate safeguards.
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To the extent permitted by applicable laws, you may have certain rights relating to your Personal Data, including but not limited to the following:

To submit a request to exercise the above rights or solve your trouble in exercising such rights, you may contact us via the contact information provided in this Policy and we will help you upon verification of your identity within the proper period or the period prescribed by the law of your jurisdiction.  In certain cases, we might require additional information from you in order to address your request or to verify your identity. We will look into your requests and respond within the timelines prescribed under applicable law. Occasionally, taking into account the nature of the request we receive, we might, to the extent permitted under applicable law and subject to conditions therein, either seek for additional time or reject your request. In such cases, we endeavor to keep you informed.

In cases where you object to or opt-out of certain types of processing, We will retain your Personal Data to the extent required to ensure we do not reach out to you or process your information for such purposes, such as adding it to an opt-out or do-not-disturb list.

We or our third-party partners may obtain and use your information through cookies and web beacon and save this information as log information.​ For more details, please refer to our Cookie Policy.

By using cookies, we offer users a personalized web experience that is simple and user-friendly. Cookies are small data files sent from a web server to your browser and stored on your computer's hard drive. We use cookies to benefit users, such as speeding up the login process for the Service. Cookies help us determine your connection to web pages and content, the time spent on certain services, and the services you select.​

You should have control over whether and how your browser accepts cookies. Please consult your browser's documentation for more information.​

Your browser or device may include “Do Not Track” functionality. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to "Do Not Track" signals. However, we provide you with the ability to opt-out of the use of tracking technologies to send you interest-based advertising.
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We may update this Privacy Policy to reflect changes to our privacy practices. If we make any material changes adversely affecting your rights, we may notify you by means of a notice on this website prior to the change becoming effective, or where you are a Subotiz User, by sending communication to the email address to the administration console of your Account. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this Policy. We encourage you to periodically review this page for the latest information on our privacy practices.
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If you have any question, comment, complaint,request or advice regarding this Privacy Policy or any other privacy-related matters, please contact us at:

Attn: Legal Department

Address: 407 W Duarte Rd, Unit 3, Arcadia, California 91007

Email:  service@subotiz.com

Upon receiving your query or request, we will, upon verification of your identity, reply to you within the period prescribed by the applicable law. We will endeavor to deal with your request as soon as possible. This is without prejudice to your right to make a complaint with a relevant data protection authority, where applicable.