Privacy Policy

1. INTRODUCTION

Subco Group Limited (crn 14818102) (we, Subs) is the controller responsible for your personal data. This privacy notice provides information on how we collect and process your personal data. The policy will be regularly reviewed and where necessary updated. This policy is supplemental to other notices and policies, cookie policy and User Agreement.

We respect your privacy and are committed to protecting your personal data. This privacy policy aims to give you information on how we collect and process your personal data through your use of our online platform and informs you about your privacy rights and how the law protects you. Subco Group Limited is the data controller registered with the ICO with number ZB666168.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and it is therefore impossible to identify a living person from the data (anonymous data).

We may revise this statement at any time. Some of the provisions contained in this Privacy Policy may also be superseded by provisions or notices published elsewhere on our Platform. This policy does not form a contract between an individual and Subs.

2. HOW TO MAKE CONTACT

Please contact [email protected] should you have any questions or wish to exercise the rights we refer to later in this policy.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. To update your information, contact us at [email protected].

3. PLEASE NOTE

The Platform is not intended for children under 18. We do not knowingly collect data from children. If you believe we have collected data about a child, please contact us at [email protected] to request data removal.

We do not transfer personal data outside the UK and European Economic Area

To the extent that you share information whether in written communication or visual information that refers to your physical appearance and health or your lifestyle this personal data is likely to be Special Category Personal Data (formerly known as sensitive data). Any information you share regarding your racial or ethnic origin or religious or philosophical beliefs may also be Special Category Data.

We are mandated to explain our use of automation. We use cookies and other technologies to collect data about your device, browser, and interactions with the Website. This includes:

  • Device, browser, and operating system information

  • IP address

  • Clickstream data, including pages viewed and links clicked

  • Visit durations and page interaction data

This data helps us ensure the Website functions correctly, monitor traffic, and enhance user experience. For more details, refer to our Cookies Policy.

In accordance with the Online Safety Act (OSA) we use technology automatically verifies the age of Users with no right to appeal. We also use technology that monitors and if necessary prevents contents being posted on the Platform. Each are automated data processing which make decisions regarding the data processing of data subjects but the conditions of articles 22.2 are met in each instance.

4. THE DATA YOU SHARE WITH US.

Subs’ business is to provide you with a real time online creator platform (Platform) which allows users who post content (Creators) to privately contact users (Followers) who pay to view selected content from Creators. There is a referral programme that rewards Creators who introduce new Creators to the Platform and the arrangements with Agents is referred to below.

In order to register as a User you will need to provide.

  • full name;

  • address;

  • email addresses;

  • mobile number;

  • public social media accounts;

  • DoB.

You will be given a PIN and user login details.

There is a referral programme that rewards those who introduce new Creators to the Platform. This programme includes third party intermediaries who are not Followers or Creators "Agents". In order to register as an Agent you will need to provide.

  • full name;

  • address;

  • email addresses;

  • mobile number;

  • public social media accounts;

  • DoB.

You will be given a PIN and user login details.

If you are an Agent trading using a company we will need to process the personal data of others involved with the Company whether they are shareholders, officers or employees.

5. DATA WE COLLECT ABOUT YOU

As you use the Platform we will collect the following:

  • Identity Data: Name, date of birth, gender, and identification details (e.g., passport, driving licence).

  • Contact Data: Email address and billing addresses.

  • Financial Data: Bank account and payment card details.

  • Transaction Data: Details about payments made and/or received.

  • Technical Data: IP address, login data, operating system, and browser type.

  • Profile Data: Username, password, social media details, interests, feedback, and survey responses.

  • Location Data: Information about your geographical location.

  • Usage Data: Details about your use of the Website.

  • Audio Visual Data: Recordings and uploads you provide to the Website.

  • Marketing Data: Preferences for receiving marketing from us and third parties.

We partner with third parties to collect anonymous usage data and may receive personal data if you log into the Website using external accounts (e.g., Twitter, Google). When we verify applications including applications made by Agents we will analyse all relevant social media accounts and make background checks.

6. HOW WE USE YOUR PERSONAL DATA AND THE LAWFUL BASIS

We use personal data for various purposes, including:

  • Service Provision: Registering you as a subscriber and providing services (e.g., Identity, Contact, Financial Data).

  • Order Processing: Managing payments and subscriptions, recovering debts (e.g., Identity, Contact, Financial Data).

  • Content Utilisation: Using recordings and uploads for distribution (e.g., Identity, Contact, Profile Data).

  • Product Development: Analysing and improving services (e.g., Identity, Contact, Financial Data).

  • Legal Compliance: Adhering to laws and managing risks (e.g., Identity, Contact, Financial Data).

  • User Engagement: Managing relationships and responding to inquiries (e.g. Identity, Contact, Profile Data).

As a data controller we can only process data if we have a lawful basis. The lawful basis are set out below.

  1. We will use your personal data to perform the obligations contained in the User Agreement or Agents’ Terms. This processing is necessary to perform a contractual obligation.

  2. With reference to the following it is in our legitimate interests as a data controller to process this personal data as the processing will enhance your user experience in terms of the Platform’s functionality and capabilities and your use of the Platform:

    • To deliver content and advertisements to you;

    • To make recommendations to you about goods or services offered by third parties which we consider may interest you. This will either be derived from data we collate from your use of the Platform or aggregated user data. It is in our legitimate interest to do so. We will select the third parties and you can always request that we no longer include you in our marketing campaigns. To stop receiving marketing messages, use the unsubscribe link in communications or contact us at [email protected];

    • To measure and analyse the effectiveness of the advertising we serve you;

    • To monitor trends so we can improve the Platform;

    • To administer and protect our business and this Platform including troubleshooting, data analysis and system testing.

  3. The nature of the Platform means that we have to process data to comply with a legal obligation. The Acceptable Use policy sets out rules. We have statutory duties including the OSA which classifies our Platform as U2U to ensure that all Users comply with the Acceptable Use Policy. This obligation extends to viewing social media accounts and other information about Users or Agents.

    • We will use AI software to review all content. If any images or communication is contrary to the Acceptable Use policy or regarded as an illegal harm under the OSA we will review all the circumstances and the contribution of users. We will work with law enforcement agencies.

    • Creators and Agents will generate income from the Followers and we may have to share your financial data with HMRC or other agencies.

    • Although as of now we are satisfied that no child can access the Platform we are under a duty to monitor and if necessary conduct children access assessments.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal grounds upon which we are relying on to process your personal data.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

7. THIRD PARTIES

We will share your personal data with third parties. These third parties will be separate data controllers. On request we will give you details of any third party with whom we have shared your personal data. If you have any concerns as to how these third parties have processed your personal data then you will have to raise these with the third party. We will conduct due diligence on these third party providers so that we can be confident as to how they process personal data.

  • Compliance. The OSA obliges us to verify the age and identities of Users and exclude Illegal Harm. To do so we work with third parties who have the technology. Your personal data will be disclosed to these providers and if you wish to continue to be a user you will have no right to prevent these third parties processing your personal data.

  • Marketing: we will be working with companies that consider offering services that may be of interest. As stated above you will always have the right to unsubscribe from all or particular companies.

  • Third Party Partners: from time to time we will work with third parties that provide services that are ancillary to our business. These include fraud prevention organisations, service providers for website functionality, analytics and search engine providers.

  • Our company group members. In the future we may revise our structure and set up a corporate group.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. This will typically be for six years and is a regulatory and statutory requirement. However, we may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you or your use of the Platform.

When you leave the Platform we will immediately delete the personal data that we do not need to retain.

If we have to verify and retain your identification documents then we will retain these for the duration of your membership and in certain circumstances for longer. This is a compliance obligation which overrides the right you have to request deletion of personal data or the restriction of processing. Verification also includes working with third parties and sharing your personal details.

9. DATA SECURITY

All information you provide to us is stored on our secure servers. You are responsible for keeping your password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

10. YOUR RIGHTS

Subject to the basis upon which we lawfully process your personal data you may have the following rights:

  • Access: to be provided with a copy of your personal data;

  • Rectification: to require us to correct any mistakes in your personal data;

  • To be forgotten: (in certain situations) to require us to delete your personal data;

  • Restriction of processing: to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data;

  • Data portability: (in certain situations) to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party;

  • Object: at any time to your personal data being processed for direct marketing (including profiling) or in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.

For further information on each of those rights, please contact us or see the Guidance from the ICO on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please email, [email protected]; and let us:

  • have enough information to identify you (e.g. your full name, address and user details);

  • have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and

  • know what right you want to exercise and the specific information to which your request relates.

As a general rule we will not charge you when you access these rights but we reserve the right to do so in exceptional circumstances