Privacy Policy

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Privacy Policy

Last updated: May 28, 2021.

At Subul (referred to as either the "Company", "We", "Us" or "Our"), we understand that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits https://www.subul.org (hereinafter referred to as the “Website”). We will only collect and use personal data in ways that are described in this Privacy Policy, and in a way that is consistent with our obligations under the General Data Protection Regulation (“GDPR”) of the European Union.

Please read this Privacy Policy carefully as it becomes legally binding for you when you use our Website. Further, please check back with us regularly to stay updated on any changes to our Privacy Policy. 

1. Information About Us

Our Website is owned and operated by Subul OÜ, registered in Estonia with a registered address at Harjumaa, Tallinn city, Ahtri tn 12, 10151. Our registry code is 16006223 and the VAT number is EE102306686.

2. What is Personal Data?

Pursuant to the GDPR, personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3. Collection of Information

When you access and use our Website, and use our services we may collect the following personal information from you: 

(a) Information you provide to us

  1. When you enter any personal information on data entry fields on our Website, including when you request information or request support using the contact forms on the Website. 
  2. When you contact us via telephone, electronic mail or regular mail, we may keep a record of that correspondence.
  3. When you post comments or opinions on third party websites where we have a profile or presence (e.g. social media pages) we may collect and store information provided by you. 

(b) Information we receive through your use of Our Website

Automated information: when you visit our Website we receive and collect information, which may in certain circumstances constitute personal information, and which includes your Internet Protocol (“IP”) address, browser software, operating system, date/time you access our Website, duration you are on it, selections and choices you make, preferences that you set when browsing our Website, and your actual location (usually an approximate location which is no more precise than city level that can be determined from your IP address).

Information Logs: when you visit our Website, view content provided by us, use our services, request technical assistance concerning our services, or send us an email we automatically collect and store certain information in log files. This includes your IP address, URL, browser software, operating system, date/time, requests type to our website and error responses returned by our website. 

Website Analytics tools: We use analytics services by third parties to collect information about your use of our Website, such as number of visits, pages visited, popularity of certain content.                Analytics tools use tracking technologies (like cookies) to recognize your device and compile             information about you.

4. Personal Information Usage

We use your personal data for the following purposes.

  • To provide you with the features of our services, functionality changes in our Website, inform you about any service interruptions or updates, service improvements or new products in accordance with our Terms and Conditions and relevant applicable laws. 
  • To diagnose problems with our servers, to administer our Website and services. This is not directly linked to any personal information, unless it is necessary to prevent fraud or abuse on our Website and systems. 
  • To enhance our services and give you a better user experience on our Website. 
  • To notify you about changes to our services, and address complaints, comments and issues you have in relation to your use of our Website. 
  • To prevent, detect and investigate illegal activities, breaches of any agreements entered into between you and us and threats to the security of our website. 
  • To produce aggregate statistical information about users of and their activities on our website from which individuals cannot be identified.


5. Legal Basis of Data Processing 

When you access our Website or use our services, we need to collect, use, and otherwise process your information, as set out in this Privacy Policy. We rely on a number of legal bases to collect, store and process your personal information, as set out in this Policy: 

Consent: we rely on your consent to store and use your personal information you provided to us. You may withdraw your consent at any time by contacting us using the details set out in the "Contact Us" section of this Policy. 

Contract: we rely on the contractual relationship for the use of your information which is necessary to perform any contractual obligations in order to provide any services to you; 

Legal obligations: we rely on legal obligations we have which we are required to comply with (e.g. a legal obligation, a court order, or to exercise or defend legal claims) in order to store and use your personal information. For example, when we are requested to disclose your personal information to regulatory bodies or law enforcement authorities; or to use your personal information for tax matters. 

Our legitimate interests: we also count on our legitimate interests to use your information, such as to: 

• deliver, modify, enhance our services; 

• detect and prevent fraudulent activities; 

• enhance the security of our network and information systems; 

• better understand how people interact with our website.


6. Sharing of Personal Information

All personal information collected by us is treated as confidential. We do not share any of your personal information with any third parties for any purposes, subject to the certain exceptions. We disclose entire or part of your personal information in the limited circumstances described below and with appropriate safeguards applicable thereto:

Legal requirement: we will disclose personal information about you in response to a subpoena, court order, or other legitimate governmental requests. 

Our group companies, subsidiaries, employees, and independent contractors: we will            disclose your personal information to our group companies, subsidiaries, business partners, external consultants, auditors, collaborators or other third parties, some of our employees, and individuals who are our independent contractors that need to know the information in order to assist us provide our services, or to process the information on our behalf and also for administrative purposes, billing and tax and all other purposes related to the management of your account. Please note, we require all of them to comply strictly with this Privacy Policy and educate them regularly on the importance and value of your personal information. 

Third Party Vendors: we will share information with third party vendors that help us provide our services such as payment providers that process your credit card information or information about alternative payment methods and invoicing, and accounting companies as well as vendors that help us prevent fraud. This group also includes trusted vendors we partner with that perform analysis of our services or user demographics and do market research that help us understand and enhance our services. This group also includes third party providers that perform analytics services. We will only share information about you that is necessary for the third party vendor to provide the requested service. These parties will process the provided data under instructions of Subul and in compliance with this Privacy Policy. We do not authorize vendors to retain, share, store or use your personal information for any secondary purposes. The third party vendors may include companies that operate in different industries such as Fraud Detection, Technology Service, Internet Information Providers, Payments and Data Processors, Specialty Finance, Media, Internet Content & Information Industries, Legal & Consulting, that are located in the territory of the European Union.

Business Transfers: in connection with any merger, acquisition of all or a portion of our business by another company, sale of company assets, or in the unlikely event that Subul goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events happens, we will make sure to take any relevant and reasonable steps to notify you and this Privacy Policy would continue to apply to your information and the party receiving your information shall continue to use your information, but only consistent with this Privacy Policy. 

7. Data Retention Periods

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. You can always request that we suspend or remove your personal data by writing to support@subul.org.

8. Security Measures and Trainings

We use Secure Sockets Layer (SSL) software to encrypt the information you enter on our Website in order to protect its security during transmission to and from our website. We also use servers which use strong encryption techniques for data at rest. 

Further, we apply access restrictions to your personal data by our employees. We make sure to educate and train our employees about the importance of confidentiality and privacy of customer personal information on a continuous basis. We maintain appropriate safeguards to protect your personal information from unauthorized access by our employees. 

Please note, despite all the measures we take to maintain the safety and security of your personal information, no transmission over the Internet can ever be guaranteed to be secure. Consequently, we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.


9. Data Subject Rights

You have the following rights which are accorded to you either by laws and regulations we are bound by, or by our commitment to respect certain data protection and privacy principles. We will always do our best to uphold your following rights:

  1. The right to be informed about our collection and use of your personal data. 
  2. The right to access the personal data we maintain about you. 
  3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
  4. The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. 
  5. The right to restrict (i.e. prevent) the processing of your personal data.
  6. The right to object to us for using your personal data for a particular purpose or purposes.
  7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
  8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
  9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For any right of yours in relation to your personal information, you can always contact us by writing to ______________ to ask for more detailed information. 

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with appropriate authorities. That said, we would welcome the opportunity to resolve your concerns ourselves, so please contact us first, using the details provided in section “Contact Us”.

10. Cookies

We use cookies and similar storage technologies (“Cookies”) to collect some of the information set out in this Policy. A cookie is a tiny piece of data, stored in text files sent from a website and stored in your web browser on your device while you are browsing a website.

11. Restrictions for Minors

Our services are not directed, in any way, to children under the age of 13. If a child under 13 submits personal information to us, and we find out about this, we will immediately take reasonable steps to remove such personal information from our databases. If you happen to believe that we might have any personal information from a child under 13, please contact us using the details provided in section “Contact Us”.

13. Third-Party Links

Our Website may contain links to third party websites. When you click on a link to any other website or location (“outside websites”), you will leave our Website and/or services and go to another site. Another entity may collect personal information or anonymous data from you. Please note that we have no control over and are not responsible for these outside websites or their content. Please be advised that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. Thus, we strongly encourage you to read the privacy policies of every website you visit. 

13. Changes

We retain the right to change this Privacy Policy from time to time. This may be necessary, for example, if the laws and regulations which we are bound by change, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Website. Therefore, we strongly recommend that you revisit this page regularly to keep up-to-date. Please note, you will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations.

14. Contact Us

In order to contact us with regard to anything concerning your personal data and data protection, including to make a subject access request, please use the following details:

Email address: info@subul.org.

Telephone number: +372 605 7178.

Postal Address: Ahtri tn 12, Tallinn, Estonia - 10151.