PRIVACY POLICY

Subbon, LTD STI. (“Subbon”) cares about your privacy. This Privacy Policy applies to the Subbon Website (subbon.com), Subbon IOS Application (Available at App Store), Android Application(Available at Google Play Store) and Subbon content, such as text, graphics, videos, images, information, and other material (“Content”). Scope of this privacy policy describes how the data gathered from Subbon users is collected, used, secured, and shared as well as individuals whose payment details are used to purchase Content.

 

  1. Collecting Data

Providing data is not obligatory for using free version of the Website and Applications. To have specific information about your child, Subbon needs you to create an account and provide necessary information about you and your child(ren). That information contain email address, phone number and password to provide access to your account. Specific information about your child contain gender and age specific diffractions, providing appropriate information requires limited demographic information about your child(ren). Subbon also allow you to add your profile picture, which is stored only in your device to enhance user experience. Sign up process includes a phone verification process, which you can skip, that uses third-party sms services. Subbon also allows their users to create accounts using third-party authentication services. Subbon also collects necessary information that those services provide. Such as username, name, surname, email address, birthdate, gender and etc. Subbon shares necessary information to those third-party services and is bound by their privacy policy and terms of use of those third-party services.

Additionally, Subbon collects usage statistics and crash reports. Those data are created during you experience Subbon Website and Applications. Those statistics also contain your device information to help provide appropriate content such as push notifications. Subbon also collect and store information about your operation system, browser, IP, language, unique device identifier. That information is associated with your Subbon account to keep it safe.

We may also collect and store certain information in server logs, including in third-party logs.

This may include:

  • details of how you used our Website, Applications or Content,
  • Internet protocol address,
  • device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL and (iv) cookies that may uniquely identify your browser or Subbon account.

Subbon also collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Use of cookies. We and our partners use various technologies to collect and store information when you use our Website, Applications or Content, and this may include sending one or more cookies or anonymous identifiers to your device. Cookies are small text files placed on the browser of your computer or mobile device when you visit a website or use an application.

When you visit the website or application again, the cookie allows that website or application to recognize you. We use “persistent cookies” to save your login information for future logins to our Website. We use “session ID cookies” to better understand how you interact with our Website, Applications or Content and to monitor aggregate usage and web traffic routing. Most browsers automatically accept cookies, but allow you to disable cookies through the “options” or “preferences” menu of your browser. Please be aware that disabling cookies could interfere with the functionality of our Website, Applications or Content.

Third parties whose products or services are accessible on our Website or Applications may also use cookies or similar tools. Please review their privacy policies for information about their cookies and other privacy practices.

 

  1. How We Use Your Information

We use the information we collect to operate and provide you with the Subbon Website, Applications and Content. This includes, but is not limited to:

Authenticating your login and processing your payments;

Personalizing your Subbon experience and customizing your child’s activities;

Allowing you to monitor your child’s progress in Subbon;

Customizing and delivering information about products and services that may be of interest to you;

Providing customer service and sending confirmations about your account;

Protecting our intellectual property or other rights; and

Managing and improving our business, Website, Applications, and Content.

You can opt out of receiving most emails by selecting the “unsubscribe” link on our emails, but we reserve the right to email you

  • to confirm transactions,
  • to address account issues, such as when you make a purchase, or you request a reset password or
  • as required by law.

We also reserve the right to use or share non-personal information (e.g., de-identified or aggregate data) for any purpose.

 

  1. When We Share Your Personal Information with Third Parties

We may share your personal information in the following ways:

Service providers and agents. We may share your information with certain third parties selected by us to help support our operations. These include, for example, services that help us process payments, analyze web traffic, send emails, and track customer service requests. In addition, we may share limited personal information to third parties that help us market or advertise Subbon.

Corporate affiliates. We may share your information with our corporate affiliates, such as entities under common ownership or control.

Compliance with law and law enforcement requests, and protection of our rights. We may disclose your information when we have a good faith belief it is reasonably necessary to

  • meet any applicable law, regulation, legal process, court order, governmental request or other legal mechanism,
  • enforce applicable Terms of Service, including investigation of potential violations,
  • detect, prevent, or otherwise address fraud, security or technical issues,
  • protect against harm to the rights, property, safety of Subbon, our users, or the public.

Consent. We may disclose your information when we believe we have your consent to do so, such as when you contact customer service and ask us about your account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your account.

 

  1. Accessing, Reviewing, and Deleting Your Information

We retain all data indefinitely unless we receive a request from you to have the data deleted. You may access or delete information we have collected about you by contacting us at the contact information listed below. While we will make reasonable efforts to accommodate your requests, if allowed by applicable laws, we reserve the right to impose certain requirements and restrictions on such requests, such as limiting our production of information to certain formats.

 

  1. Security of Personal Information

We have implemented and maintain reasonable security practices to protect against the unauthorized access, use, modification, destruction or disclosure of your personal information. However, no method of transmission or storage is completely secure, and we therefore cannot guarantee absolute security. It is your responsibility to protect the data that resides on your mobile device and we strongly encourage you to do so, including encryption of data and use of passwords to lock your mobile device, in case it is lost or stolen.

 

  1. Outside the Turkey Consent to Processing and Transfer of Information

If you access the Subbon Website, Applications, or Content outside of the Turkey, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection and processing of such personal information in the Turkey.

 

  1. Changes to Privacy Policy

This Privacy Policy may be updated by Subbon from time to time. If Subbon makes material changes, we will provide notice to you either by email or

  • by posting the updated Privacy Policy on our Website at least 15 days in advance of the effective date and
  • posting a notification on our Applications that the Privacy Policy have been updated. Please note that unless otherwise provided by applicable law, your continued use of our Website, Applications or Content means that you agree with, and consent to be bound by, the updated Privacy Policy.

 

  1. Contact Information

We welcome inquiries or comments about our Privacy Policy by sending a e-mail to the following address:

info@subbon.com

 

Istanbul / Turkey

Last modified on Marc19th, 2019