We are Subsets, offering an AI-based subscription retention platform. This Privacy Notice explains how Subsets (“Subsets”, “Company”, “we”, “us” or “our”) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites accessible via Subsets, the Webapp, platform, services, products, integrations and other functionality offered on or through our services (collectively, the “Services”). It does not address our privacy practices relating to Subsets job applicants, employees and other personnel.

Subsets is the controller of the personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used.

I. What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean any data or information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information.”

II. Our Collection and Use of Personal Information

We collect personal information in a variety of ways. For example, you may provide us your personal information when you register for an account or contact us.
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Personal Information Collected from You

We may collect the following categories personal information submitted to us by individuals through the Services:

• Contact Information, including first and last name, business email address, business postal address, employer, job title, your area of responsibility, company name, phone number, your country or region and communication preferences. We use this information to fulfill your request or transaction, to communicate with you directly and to enhance the services we offer to our users and to manage and grow our organization.
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• Account Information, including business email address, user ID and password. We use this information to provide access to our Webapp and administer your account, provide you with the relevant service and information, for customer support purposes and to diagnose or fix technology problems and to maintain the safety, security and integrity of our property and Services, technology assets and business.
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• Inquiry and Communications Information, including information provided in custom messages sent through our online forms or to our email address, such as to request a demo or submit a testimonial. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization.
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• Feedback Information. We may also collect feedback and ratings you provide relating to our services or products. We use this information to communicate with you, to conduct market research, inform our marketing and advertising activities and improve and grow our business.
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• Business Representative Contact Information. If you are a business representative, we collect your information in connection with the performance of the agreement or potential agreement with us. This information may include your first name, last name, company contact information (e.g., email, phone, address), job title, and any other information related to the performance of the agreement with us.

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Personal Information Automatically Collected

We use a cookie-free analytics tool, Pirsch Analytics (https://pirsch.io/), to understand how our Site is used. This privacy-focused service processes:

• Page views
• Visit duration
• Entry and exit pages
• Referrer information
• Browser information
• Operating system information
• Screen resolution
• Geographic location (country/city level only)

This analysis is performed without cookies and in a privacy-preserving way that doesn't track individual users across sessions or websites. The data is processed within the EU in compliance with GDPR requirements.

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How We Use Your Information

For website visitors, we use the information collected to:

• Provide and maintain our Site
• Notify you about changes to our Site or Service
• Allow you to participate in interactive features
• Provide customer support
• Gather analysis or valuable information to improve our Site
• Monitor the usage of our Site
• Detect, prevent, and address technical issues
• Provide you with news, special offers, and general information about our products and services

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III. Our Disclosure of Personal Information

We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
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• Your Employer / Company: If you interact with our Services through your employer or company, we may disclose your information to your employer or company, including another representative of your employer or company.
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• Marketing Providers: We coordinate and share personal information with our marketing providers in order to communicate with individuals about the Services we make available.
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• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, website hosting, infrastructure provisioning, IT services, analytics services, employment application-related services, payment processing services, and administrative services.
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• Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on our Services, on other websites and services, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see the Third-Party Data Collection and Online Advertising section.
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• Business Partners: From time to time, we may share personal data with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
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• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
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• Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  
  - in connection with the establishment, exercise, or defense of legal claims;
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  - to comply with laws or to respond to lawful requests and legal process;
  
  - to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
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  - to detect, suppress, or prevent fraud;
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  - to protect the health and safety of us and others; or
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  - as otherwise required by applicable law.
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• With Your Consent or At Your Direction: We may disclose personal information about an individual to certain other third parties or publicly with their consent or at their direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or Service-related publications.
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• For any other lawful purpose, or other purpose that you consent to.
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IV. Control Over Your Information

You may control your information in the following ways:
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• Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
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• Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at founders@subsets.com. We may not be able to modify or delete your information in all circumstances.
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• Online Ads: To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
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Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles. may control your information in the following ways:
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V. Children’s Personal Information

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If an individual is under the age of 16, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 16, we will promptly delete that personal information.
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VI. Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
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VII. State-Specific Disclosures

• Nevada: If you are a resident of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us at founders@subsets.com with the subject line “Nevada Opt Out Request” to submit such a request.

VIII. Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
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IX. Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to founders@subsets.com.

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