Last updated April 13, 2022
Thank you for choosing to be part of our community at Subvrsive, Inc. (“Subvrsive”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org.
Table of Contents
- What information do we collect?
- How do we use your information?
- Will your information be shared with anyone?
- How long do we keep your information?
- Do we collect information from minors?
- How do we store and secure your information?
- What are your privacy rights?
- Controls for do-not-track features
- Do California residents have specific privacy rights?
- Do we make updates to this policy?
- How can you contact us about this policy?
1. What information do we collect?
In short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our Services, when participating in activities on the Services or otherwise contacting us, including through website input fields (including advertisements), phone, email (including email campaigns), web chat, or in other such ways. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the Services you use. The personal information we collect can include the following:
- Publicly Available Personal Information. We collect email addresses, business email, business phone number, first name, maiden name, last name, nickname, IP address and other similar data.
You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
2. How do we use your information?
In short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, to protect the vital interests of you, our customers or the public, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, to protect the vital interests of you, our customers or the public, with your consent, and/or for compliance with our legal obligations.
We use your personal information:
- To send you marketing and promotional communications. We and/or our third party marketing partners may use your personal information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time; we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below (see the “What are your privacy rights” below).
- To request feedback. We may use your information to request feedback and to contact you about your use of our Services.
- To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).
- To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- For other Business Purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may publish, share, distribute, or disclose personal information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated from the aggregate data and identified as originating from you, to third parties, including Subvrsive partners, sponsors, and advertisers. Such information may help Subvrsive identify and analyze training, demographic, and psychographic trends and information, and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, ads, or other materials. We may also use such data for research purposes.
3. Will your information be shared with anyone?
In short: We only share information with your consent, to comply with laws, to provide you with Services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
- Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
More specifically, we may need to process your data or share your personal information in the following situations:
- Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Please note that our partners may contact you as necessary to obtain additional information about you, facilitate any use of the Services, fulfill orders, or respond to a request you submit.
5. How long do we keep your information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. Do we collect information from minors?
In short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com.
7. How do we store and secure your information?
In short: We take technological an organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure or modification.
We take technological an organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure or modification. For example:
- We transmit data over secured communication channels using SSL Login credentials
- All personal information is stored by trusted third party providers (e.g., HubSpot and AWS)
- All systems used to provide the Services are password protected
- All Services usage is restricted on a per-user basis on the principle of least privilege.
We rely on HubSpot’s and AWS’ security programs to protect personal information while stored in their respective controlled facilities. For more information on AWS’ security practices and processes, please see https://aws.amazon.com/security/. For more information on Hubspot’s security practices and processes, please see https://fs.hubspotusercontent00.net/hubfs/742851/Privacy%20and%20Security%20documents/HubSpot%20Security%20Overview%20-%20October%202021.pdf
Subvrsive complies with applicable data protection laws, including applicable security breach notification requirements.
Data Transfer. Our databases are currently located in the United States. Subvrsive makes no claim that its Services are appropriate or lawful for use or access outside the United States. If you access the Services from outside the United States, you are consenting to the transfer of your personal information from your location to the United States. You are solely responsible for complying with all local laws, rules and regulations regarding online conduct and access to the Services. By sending us your information, you further consent to its storage within the United States.
8. What are your privacy rights?
In short: You may review, change, or terminate your account at any time.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
9. Controls for Do-Not-Track Features
10. Do California residents have specific privacy rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
11. Do we make updates to this policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
12. How can you contact us about this policy?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by mail to:
440 E St Elmo Rd
Austin, TX 78745