Foundation of Our Relationship
Personal Information We Collect
How We Use and Share Your Personal Information
Personal Information about Children
How We Safeguard Your Personal Information
Contact Information and Manage Preferences
Our Privacy Center is designed to introduce you to our privacy practices and notices. Whether you interact with Subly Media Inc. or one or more of our affiliates (collectively, the "firm" or "Subly") directly as an individual investor, through an investment professional, or through services provided by the firm to your employer, you entrust us with your personal and financial information, and it is important that you understand how we use and care for it. We believe your relationship with us is based on trust and that you count on us to act responsibly. Thank you for your trust.
Notices applicable to you may differ depending on where you reside. Please read the Subly Corporate Privacy Notice and the other Privacy Notices that may apply to you. In the event of material changes to our Privacy Notices, we will post the revised notices on this page with a new "Last Updated" date. Changes to our Privacy Notices will become effective when posted unless indicated otherwise. We are here to answer your questions.
The Subly Corporate Privacy Notice - Click here to view our Privacy Notice.
State Notices (in addition to state disclosures in our Privacy Notice)
California Residents (CCPA) Privacy Notice - Click here to view our Privacy Notice for California Residents (CCPA)
If you live outside the U.S. other privacy laws may apply. Please contact us with any questions.
U.K. and EU (GDPR) Privacy Notice - Click here to view U.K. and EU (GDPR) Privacy Notice
People's Republic of China Privacy Notice - Click here to view People's Republic of China Privacy Notice
Hong Kong Privacy Notice - Click here to view Hong Kong Privacy Notice
Personal Information is information which uniquely identifies you, such as your name, email address, billing information, or other data that can be reasonably linked to you by Subly. We collect Personal Information to help us service your accounts and to deliver an exceptional experience.
The kind of information we collect depends on your interactions with us, the services you apply for, use, and what we need to maintain your account(s). Additionally, some service providers may share your information with us for specific purposes, such as to verify your identity and to protect your accounts and information.
You may provide Personal Information to us through our websites and applications. For example, you may register to use our services or create an account with us, which allows or requires you to provide certain information to us (e.g., contact information such as your name, email address, telephone number, date of birth, income information etc.). You provide Personal Information and other information to us when you contact us through our websites or by phone. We may also collect Personal Information from you when you subscribe to our newsletters and other subscriptions and to participate in our surveys.
We may collect Personal Information from third parties such as consumer reporting agencies to assess your creditworthiness, or other providers for identity verification services, etc.
We collect Personal Information and information about your devices, browsers, and Internet activity as you use and interact with our websites. The information we collect includes unique identifiers, browser types and settings, device types and settings, operating systems, mobile network information including carrier name and phone number, and application version numbers. We also collect information about the interaction of your browsers and devices with our websites, such as IP address, device type, system activity, wireless carrier name (when you use a wireless or mobile device), and the date, time, and referrer URL of your request.
The firm websites, mobile applications, and online services may store or retrieve information on or about your browser, mostly in the form of small files called cookies and similar technologies (together, "cookies"). Cookies ensure our websites work as intended and enable us to personalize and capture your preferences on our websites, measure the effectiveness of advertisements and web searches, and improve your experience with our products.
Necessary Cookies
Our websites need these cookies to function. Necessary cookies are usually set when you take a specific action, such as logging in, setting your privacy preferences, performing transactions, and completing forms.
Functional Cookies
These cookies help us personalize our websites and enhance how they function. Functional cookies can be set by us or by a third-party provider servicing our websites.
Analytical Cookies
These cookies help us track how our website performs, such as counting visits, traffic sources, and other data points. Analytical cookies help us learn which pages perform best, which ones need work, and how visitors like you navigate the website. The information from these cookies is analyzed at an aggregate level.
Marketing Cookies
We work with advertising partners to optimize our digital marketing. These cookies do not capture details like your name or email address. We use information from marketing cookies to measure the performance of our digital marketing. The information also may be used to show you relevant advertisements on other websites.
To disable cookies, adjust the settings on your browser (e.g., Chrome, Edge, Safari). Disabling cookies may modify your experience on or ability to navigate our websites.
Some browsers incorporate opt-out preference settings such as "Do Not Track (DNT)" or "Global Privacy Control (GPC)". These settings, when turned on, are intended to send a signal or preference to websites you visit indicating you do not wish to be tracked. We do not respond to such signals, except for those we detect from California-based IP addresses. Also, some U.S. states and jurisdictions, including California, have laws that provide you with additional means of limiting our use of such information. Please refer to relevant jurisdictional notices for more information.
Subly uses third-party online advertising companies to provide you with Subly advertisements that may be relevant to your interests, as determined by your activity on Subly and non-Subly websites. In delivering our ads, we use the Digital Advertising Alliance's (DAA) AdChoices framework to allow users to opt out of this form of tracking. You may click on the AdChoices icon on these advertisements or through the link below to opt out of receiving future interest-based ads from these third-party companies. Please note that opting out through AdChoices does not prevent you from receiving other Subly advertising that is not targeted or interest based. The collection of data for the purposes of serving interest-based advertisements and recording your opt-out preferences is implemented at the browser level using cookies. If you clear cookies or use a different browser or computer, your preferences may not be transferred or retained.
For more information about interest-based advertising, please visit http://www.aboutads.info
Process transactions at your request for content, services, products, or information.
Maintain and service your account.
Improve our service and products. We may contact you about our products and services as well as those offered by third parties that may be of interest to you.
Facilitate your participation in online activities. We may use your contact information to communicate and interact with you, such as to send you emails and text messages about our products and services. We use the IP address provided by your device to send you the data you request to display on your device.
Comply with our legal and regulatory obligations.
Maintain the safety, security, and integrity of our business.
With affiliates of Subly Media Inc. and with nonaffiliates for analysis, market research and marketing purposes as described in our Corporate Privacy Notice.
With trusted service providers who support and help develop our products and services. Our service providers are contractually committed to our standards for safeguarding your information.
To protect the rights, property, or safety of our firm, our customers, or others. This may include exchanging information with other companies and organizations for fraud protection and credit risk reduction.
Our website is not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under 13 unless the Personal Information is provided by a parent, legal guardian, or authorized adult. If you believe we might have any information directly from a child under 13, please contact us using the Company Info link on our website.
Please also visit the Federal Trade Commission website for more information on the Children's Online Privacy Protection Act (COPPA).
To protect your Personal Information from unauthorized access and use, we use security measures that comply with federal law. To learn more about security at Subly, please visit www.sublymedia.com/legal/privacy-overview.
If you would like to opt out or manage your preferences with respect to receiving advertising and marketing communications from us, or if you have any questions, concerns, complaints, or suggestions regarding any of our Privacy Notices or the ways in which we collect and use your Personal Information, have any requests related to your Personal Information pursuant to applicable laws, or otherwise need to contact us, please check your Subly statement for the most direct number at which to reach us. In some instances, specific contact information may be included on the Privacy Notice that applies to you or use the Company Info link on the homepage of our website.
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