Private Policy

Last Updated: Sep 16, 2024

Subly LLC (“Subly”, “We”, “Us”, “Our”) is committed to ensuring the privacy of its users and maintaining robust protections for their data. This Privacy Policy outlines how Subly collects, uses, shares, and safeguards personal information in connection with the Subly mobile application (“App”). By using Subly, you consent to the practices described in this policy. If you have any questions about this Privacy Policy, please contact us at tony@sublynyc.com

1. Acceptance of Privacy Policy

By accessing, downloading, or using Subly, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as outlined in this Privacy Policy. If you do not agree with this policy or any part thereof, you are required to discontinue the use of Subly’s services immediately.

2. Information We Collect

Subly collects both Personal Information and Non-Personal Information to provide, improve, and enhance the user experience.

Personal Information

Personal Information refers to data that identifies, relates to, or could reasonably be linked with an individual. Subly collects the following categories of Personal Information:

• Name: Automatically collected when users log in through Google or Apple accounts.

• Email Address: Automatically retrieved from third-party login methods (Google or Apple).

• Social Media Handles (Optional): Users may voluntarily provide their social media handles for the purpose of verifying identity within the app. This information is accessible only to other users within the App and is not shared externally.

• Photographs and Videos: Collected when hosts upload media associated with their sublet listings.

• Apartment Location (Approximate): Hosts are required to provide the location of their apartment when creating a listing. However, the location is deliberately broad, often covering a radius of approximately one mile to protect user privacy.

Non-Personal Information

Non-Personal Information refers to data that does not directly identify an individual. Subly collects and uses the following Non-Personal Information:

• Video Engagement Data: Data related to user interactions with videos, including the number of views, likes, chats, and shares. This data helps Subly identify and promote popular listings.

• Firebase Analytics Data: Subly uses Firebase Analytics to collect anonymized data about app usage, session duration, user behavior, and interactions. This information is used to optimize app performance and user experience.

3. Use of Collected Information

Subly utilizes the collected Personal and Non-Personal Information for the following purposes:

• Service Enhancement: Personal Information is used to facilitate user interactions within the App, including communication between hosts and subtenants. Non-Personal Information, such as video engagement data, is used to optimize and personalize the user experience.

• User Verification: Social media handles, provided voluntarily, are used to allow users to verify host or subtenant information. This information is not shared with external parties and remains within the Subly app.

• Protection of Privacy: Apartment locations provided in sublet listings are approximate and generalized, allowing users to maintain their privacy while still offering a reference point for prospective subtenants.

4. How We Use and Share Information

Personal Information

Except as otherwise provided in this Privacy Policy, we do not sell, trade, rent, or otherwise share your Personal Information with third parties for marketing purposes without your explicit consent. From time to time, we may engage third-party service providers, such as analytics and hosting providers, to assist us in delivering or enhancing Subly’s services. These third parties may have limited access to Personal Information solely for the purpose of performing specific tasks on our behalf and are not permitted to use this information for any purpose other than as directed by Subly.

In general, the Personal Information you provide to us is used to facilitate communication and interaction between you and Subly. We may use your Personal Information to:

• Respond to your inquiries or requests;

• Solicit feedback about your experience using the App;

• Provide technical support and resolve any issues you may encounter;

• Inform you of promotional offers, updates, or changes to our services.

Sensitive Personal Information, such as your date of birth, is used internally to verify your identity for the purpose of enhancing community safety and is not shared with third-party websites or affiliates.

Non-Personal Information

We use Non-Personal Information to improve the functionality and user experience of Subly. This data may be aggregated and analyzed to monitor user behavior, identify usage trends, and improve the performance of the App. As this information does not personally identify you, there are no restrictions on our ability to share Non-Personal Information with third parties, including advertisers, partners, and service providers.

Business Transactions

In the event of a corporate transaction such as a merger, acquisition, or sale of all or part of Subly’s assets, your Personal Information may be transferred as part of the transaction. You acknowledge and consent to such transfers, which are permitted by this Privacy Policy. Any entity that acquires Subly’s assets may continue to process your Personal Information in accordance with this Privacy Policy.

5. Data Security

Subly is committed to ensuring that your Personal Information is protected. We implement various security measures, including encryption, firewalls, and secure socket layer (SSL) technology, to prevent unauthorized access or disclosure of your Personal Information. While we strive to protect your data, no system can be guaranteed as 100% secure. By using the App, you acknowledge and accept the inherent risks of data transmission over the internet and agree that Subly will not be liable for any data breaches beyond our control.

6. User Rights

You have the following rights concerning your Personal Information:

• Access and Correction: You may access and update your Personal Information at any time via your account settings within the App.

• Deletion: You may request the deletion of your account and associated data by contacting Subly at tony@sublynyc.com. Upon request, we will delete your data unless required to retain it for legal or business purposes.

• Opt-Out of Communications: You have the right to opt out of receiving marketing communications from Subly. You can do this by following the unsubscribe instructions provided in promotional emails or by managing your communication preferences in the App.

Please note that administrative communications, such as those related to account management or policy updates, are not subject to the opt-out option.

7. Children’s Privacy

Subly is not directed toward individuals under the age of 18. We do not knowingly collect or solicit Personal Information from anyone under the age of 18. If we learn that we have inadvertently collected information from a minor, we will take immediate steps to delete such information from our records.

8. Retention of Personal Information

Subly retains Personal Information for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Once your Personal Information is no longer needed, it will be securely deleted or anonymized to ensure that it cannot be associated with you.

If you deactivate your account, we will take reasonable steps to delete your Personal Information, except where we are required to retain certain data for legal or regulatory purposes, such as compliance with tax laws or dispute resolution.

9. Third-Party Services

Subly integrates with third-party service providers, such as Apple, Google, and Firebase Analytics, to facilitate login authentication and track anonymous app performance data. While Subly ensures that these third parties adhere to applicable privacy laws and best practices, we are not responsible for the privacy practices of these providers. By logging into Subly through a third-party service (e.g., Apple or Google), you agree to the privacy policies of those platforms. We encourage you to review their respective privacy policies for more information.

10. Social Media and External Links

The Subly App may contain links to external websites or services operated by third parties. These links are provided solely for your convenience. Subly does not control, endorse, or assume responsibility for the content, privacy policies, or practices of these third parties. If you access or interact with third-party services through the App, your information will be subject to the privacy policies of those third parties. We encourage you to review their privacy policies before interacting with their services.

11. Your Rights Regarding the Use of Your Personal Information

You have the right to manage how your personal information is used for marketing purposes. If you receive promotional communications from Subly and wish to stop receiving them, you may opt out at any time by following the unsubscribe instructions included in each promotional email. Additionally, you can adjust your marketing preferences within the App’s settings.

Please note that, even if you opt out of receiving promotional communications, Subly may continue to send you administrative emails, which include essential updates such as modifications to this Privacy Policy, account-related information, or other necessary service notifications. These communications are not subject to the marketing opt-out option, as they are integral to the functioning of our services.

12. California Consumer Privacy Act (CCPA)

For residents of California, the California Consumer Privacy Act (CCPA) grants you specific rights concerning your Personal Information, including the right to:

• Request that we disclose the categories and specific pieces of Personal Information we have collected about you.

• Request the deletion of your Personal Information, subject to certain exceptions as permitted by law.

• Opt-out of the sale of your Personal Information, though Subly does not engage in the sale of Personal Information.

If you wish to exercise any of these rights under CCPA, please contact us at tony@sublynyc.com

13. Changes to This Privacy Policy

Subly reserves the right to modify this Privacy Policy at any time. If we make material changes to this policy, we will notify you by email or through a prominent notice in the App. The effective date of the updated Privacy Policy will be provided at the top of this document. By continuing to use the App after changes have been made, you acknowledge and accept the revised terms.

14. Contact Information

If you have any questions or concerns about this Privacy Policy or the practices of Subly, please contact us at:

• Email: tony@sublynyc.com

• Mail: Subly LLC, 418 Broadway, STE N, Albany, NY 12207