Privacy Policy

Last updated: June 12, 2025

This Privacy Policy explains how Subly (“we”, “us”, or “our”) collects, uses, discloses, and protects your personal information when you access or make a purchase from shopsubly.com (the “Site”) or otherwise interact with us through any of our services (collectively, the “Services”).

By using our Services, you agree to the terms of this Privacy Policy. Please read it carefully.

1. Information We Collect

We collect personal information that you provide directly and information collected automatically through your device.

a. Information you provide:

Full name
Email address
Billing and shipping addresses
Phone number
Account information (if created)
Order and payment details (via third-party processor)
Feedback, reviews, or survey responses

b. Information collected automatically:

IP address, browser type, operating system
Device type and unique identifiers
Site usage data (pages visited, time on site, links clicked)
Cookies and tracking technologies (see Section 5)

c. Payment data:
We do not store full credit card or payment information. Payments are securely processed by third-party providers like Stripe or PayPal.

2. How We Use Your Information

We use your data for the following purposes:

To process and fulfill your orders
To communicate with you about your order or inquiries
To provide customer support
To send transactional and marketing communications (if you opt in)
To personalize and improve the Site
To analyze traffic and user behavior
To detect fraud and maintain platform security
To comply with legal obligations

3. Lawful Bases for Processing (for UK/EU Customers)

If you are in the UK or EU, we process your personal data based on one or more of the following legal bases:

Performance of a contract (e.g., fulfilling your order)
Consent (e.g., for marketing)
Legitimate interests (e.g., fraud prevention, analytics)
Legal obligation (e.g., accounting, taxes)

4. How We Share Your Information

We may share your information with:

Payment providers (e.g., Stripe, PayPal)
Shipping carriers (e.g., USPS, Royal Mail, Australia Post)
Customer service platforms
Email and SMS platforms (e.g., Klaviyo)
Analytics & advertising tools (e.g., Google Analytics, Meta Pixel)
Legal and governmental authorities, where required

We do not sell or rent your personal data.

5. Cookies & Tracking Technologies

We use cookies and similar technologies to:

Recognize your device
Maintain session functionality
Personalize your experience
Measure site performance and traffic
Deliver relevant ads

If you are located in the EU or UK, we request your explicit consent before placing non-essential cookies (e.g., for ads or analytics). You can withdraw consent at any time via the cookie banner or browser settings.

6. Data Transfers

Your data may be stored and processed outside your home country (e.g., in the US). We ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs)
Adequacy decisions (e.g., UK-AU data protection agreement)

7. Security

We implement industry-standard security measures to protect your personal information, including:

SSL encryption on all transactional pages
Access control and authentication for sensitive systems
Regular platform updates and vulnerability scanning
Limited employee access based on role

Despite these measures, no online system is ever 100% secure.

8. Data Retention

We retain your personal information only as long as necessary to:

Provide our Services
Comply with legal obligations
Resolve disputes
Enforce our agreements

You can request deletion of your data (see Section 9).

9. Your Privacy Rights

Depending on your location, you may have the following rights:

Under GDPR / UK GDPR (EU/UK):

Right to access and receive a copy of your data
Right to correct inaccuracies
Right to request deletion (“right to be forgotten”)
Right to restrict or object to processing
Right to data portability
Right to withdraw consent at any time

Under CCPA (California):

Right to know what personal info we collect and share
Right to request deletion
Right to opt out of “sale” of personal data (we do not sell)
Right to non-discrimination for exercising your rights

Australia (Privacy Act 1988):

Right to access and correct personal data
Right to lodge a complaint with the OAIC

To exercise any of these rights, email support@shopsubly.com with the subject line “Privacy Request”.

10. Profiling & Automated Decisions

We may use limited profiling (e.g., past purchase behavior) to personalize marketing. We do not make fully automated decisions that have a legal or similarly significant effect on you.

11. Children’s Privacy

Subly is not intended for children under 18 years of age. We do not knowingly collect or process data from minors. If we discover this, we will delete the data immediately.

12. Third-Party Links

Our Site may contain links to third-party websites (e.g., Instagram, payment portals). We are not responsible for their privacy practices. We recommend reviewing their privacy policies separately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make significant changes, we will notify you via email or update the “Last updated” date at the top of this page.