Compliance

GDPR 🇪🇺

At Subscriby, we use the General Data Protection Regulation (GDPR) as our primary guideline for designing our software and websites. Our commitment to GDPR principles ensures robust data protection for all users:

• Data Protection by Design Privacy measures are integrated from the earliest stages of development, ensuring that data protection is a core component of our products.
• Lawful Processing All data processing activities have a valid legal basis under GDPR, such as user consent or legitimate business interests.
• User Rights We facilitate the easy exercise of GDPR rights, including access, rectification, erasure, and data portability.
• Transparency Clear and comprehensive privacy policies are provided, detailing how we collect, use, and protect user data in plain language.
• Data Minimization We collect only the data necessary for specific purposes and establish clear retention periods.
• Breach Notification Robust procedures are in place for detecting, investigating, and reporting data breaches promptly.
• International Transfers When transferring data outside the EEA, we ensure appropriate safeguards are in place to maintain GDPR-level protection.
• Vendor Management We carefully select and work only with GDPR-compliant third parties, implementing Data Processing Agreements.

Privacy Policy

We maintain a comprehensive Privacy Policy that details how we collect, use, and share information about you. It covers our data collection practices, your choices regarding your information, and other important privacy matters.

Sub-Processors

We prioritize your privacy and data security. We work with the following third-party service providers (sub-processors) to deliver our Services. We select these partners based on their security standards and compliance with data protection laws.

Connected platforms such as Telegram are independent services under their own terms, not our sub-processors, and the payment providers a creator connects are the creator's own processors. Our live support chat and our email system run on infrastructure we operate ourselves.

Data Processing Agreement (DPA)

Subscriby offers a Data Processing Agreement to every customer who needs one under the GDPR, the UK GDPR or a similar law. It sets out what each side owes the other whenever Subscriby processes personal data on your behalf.

• Who is the controller You are the controller of your members' personal data: the names, usernames, emails and payment references your community brings. Subscriby is the processor, acting on your instructions through the product.
• Your own account data For the data of your own Subscriby account, Subscriby is the controller, as the Privacy Policy describes.

The DPA covers:

• The subject matter, duration, nature and purpose of the processing, and the categories of data and of data subjects.
• The sub-processors listed on this page, with notice before a new one is added and the right to object.
• The technical and organisational security measures Subscriby maintains.
• Breach notification without undue delay, and assistance with data-subject requests, impact assessments and audits.
• Deletion or return of the data when the service ends.
• International transfers under the EU Standard Contractual Clauses, with the UK Addendum where data leaves the United Kingdom.

Global Data Protection Laws

We design our practices to meet the GDPR and the UK GDPR, and to respect the principles of these laws where they apply to us:

• California Consumer Privacy Act (CCPA)
• Brazil's General Data Protection Law (LGPD)
• Canada's Personal Information Protection and Electronic Documents Act (PIPEDA)
• Australia's Privacy Act

Accessibility

We aim to meet these standards; tell us where we fall short and we will fix it:

• Web Content Accessibility Guidelines (WCAG) 2.1
• Americans with Disabilities Act (ADA) standards

If you find any accessibility issues with our products, please contact us.

DMCA

Subscriby respects intellectual property rights and complies with the Digital Millennium Copyright Act (DMCA). We have established a clear process for addressing copyright infringement claims.

The content members pay for lives on the platforms a creator connects; Subscriby sells and controls the access to it. A valid notice therefore leads to the paid access being disabled and the creator being told, while the content itself is removed by the platform that hosts it, which you should notify as well.

• Your physical or electronic signature, or that of the person authorised to act for the rights holder.
• The copyrighted work you say is infringed, or a representative list if there are many.
• Where the infringing material is: the portal address, the plan and, where you can, the place or the post.
• How we can reach you: name, address, telephone number and email.
• A statement that you believe in good faith that the use is not authorised by the rights holder, their agent or the law.
• A statement, under penalty of perjury, that the notice is accurate and that you are the rights holder or authorised to act for them.

• We promptly review all properly submitted notices and take appropriate action, including removing or disabling access to the allegedly infringing content.
• The creator receives a copy of the notice. A creator who believes the material was removed by mistake can send a counter-notice with the same identifying details and a consent to jurisdiction; unless the complainant files a court action within ten to fourteen business days of receiving it, the access is restored.
• We have a policy to terminate accounts of repeat infringers when appropriate.
• Knowingly misrepresenting that material is infringing, or that it was removed by mistake, makes the sender liable for the resulting costs and damages.

To submit a DMCA notice or for any copyright-related inquiries, please contact us at support@subscriby.net.