Privacy Policy

The terms used in SubRya’s Data Protection Notice refer to the relevant concepts and definitions used by European legislators in the General Data Protection Regulation (GDPR). We want this Data Protection Notice to explain the relevant content to the public, customers, and partners in a clear and easy-to-understand way. Therefore, before formally describing the data processing rules, we first explain some of the terms used in this Notice. In this Data Protection Notice, we specifically use the following terms:

Personal data:

“Personal data” refers to any information relating to an identified or identifiable natural person, i.e. the “data subject.” “Identifiable natural person” means a person who can be identified directly or indirectly, in particular by reference to name, identification number, location data, online identifiers, or by one or more specific factors that are related to that person’s physical, physiological, genetic, mental, economic, cultural, or social identity.

“Data subject” means any identified or identifiable natural person whose personal data are processed by the controller.

“Processing” means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, including but not limited to collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

When you log in to SubRya.com, we may set multiple cookies to save your login status, login information, and screen display preferences. Login cookies usually remain for two (2) days, while screen options cookies usually remain for one (1) year. If you select the “Remember me” feature, your login status will remain valid for the corresponding period. If you log out of your account, the relevant login cookies will be deleted.

We use cookies for purposes that include, but are not limited to:

(a) Used for analytics purposes. We may collect and analyze aggregated data about site traffic and usage through Cookies to help us understand how users access and use SubRya.com, so we can improve the website structure, content, and overall user experience; (b) Remember your settings across different browsing sessions and personalize the site to your needs and preferences, for example by displaying your language, currency, or other interface preferences; (c) Maintain the basic functions, security, and proper operation of the website, including account login, identity verification, session management, and preventing unusual access.

To achieve the purpose stated above, this website may use two basic types of cookies: (a) Session cookies: Session cookies are temporary files and are usually deleted after you log out of your account, leave the website, or close your browser; (b) Persistent cookies: Persistent cookies are stored in your browser for a longer period of time. The specific retention period depends on the duration set for the cookie itself, or until you manually delete those cookies.

Who do we share your data with

Unless otherwise provided in this Privacy Policy, or when necessary to provide the Services, comply with legal obligations, protect our legitimate interests, ensure the safety of the Platform, and prevent fraud or abusive behavior, we will not sell, rent, or disclose your personal data to any third party. When necessary, we may share your personal data with the following parties: (a) Third-party service providers that assist us with necessary services such as technical support, payment processing, data storage, customer service, identity verification, statistical analysis, or other necessary services; (b) Government authorities, regulatory bodies, law enforcement agencies, courts, or other competent entities for which disclosure of personal data is necessary in accordance with applicable laws and regulations, court orders, regulatory requirements, or lawful requests from competent authorities; (c) Relevant parties for whom disclosure is necessary to protect the legitimate rights and interests, safety, and property of SubRya, users, or third parties; (d) In the event of a company merger, acquisition, restructuring, transfer of assets, or similar transaction, the entities that receive the relevant data as required for business transfer, provided that such receiving parties must continue to process your personal data in accordance with the applicable data protection requirements.

How long we keep your data

We will retain your personal data only for as long as necessary to fulfill the purposes set out in this Privacy Policy, unless applicable laws and regulations require or permit a longer retention period. For users registered on our website, if applicable, we will store the personal information they provide in their user profile. All users may, at any time and within the scope allowed by account features, review, edit, or delete their personal information; however, information such as usernames that cannot be changed for account identification, security, or system administration purposes is excluded. Website administrators may also view and edit such information within the necessary scope. After your account is closed, the service is terminated, or you submit a deletion request, we will retain some data for a reasonable period of time, for necessary purposes such as compliance with applicable laws, business operations, security safeguards, dispute resolution, compliance audits, and the prevention of fraud or abuse.

If you choose to log in using a third-party authentication service (such as Google or Facebook), certain data such as your name and email address may be retrieved from that service. By choosing this method, you accept the above-mentioned services to communicate these data to us.

When you log in, we will ask you if you want to receive SubRya advertising promotion through whatsapp. We will send such messages only if you voluntarily provide your WhatsApp phone number and give explicit consent. You may withdraw this consent at any time by contacting customer support or by using the unsubscribe command.

If this privacy policy is translated into any other language, and there is any inconsistency or conflict between the English and translated versions of this privacy policy, the English version shall prevail.

Where the GDPR applies, you may have the following rights under the GDPR:

4.1 Right to be informed You have the right to know how we collect, use, store, disclose and process your personal data. This Privacy Policy is intended to explain the relevant processing activities to you in order to satisfy your right to be informed. 4.2 Right to erasure In the following circumstances, you have the right to request that we delete your personal data and stop processing such personal data: (a) such personal data are no longer necessary for the purposes for which they were collected or processed; (b) you withdraw your previously given consent, and we have no other lawful basis to continue processing such personal data; (c) you object to our processing of your personal data in accordance with the law, and there is no overriding legitimate basis for processing that takes precedence over your rights and interests; (d) applicable law requires us to delete such personal data. If we have disclosed to third parties personal data that should be deleted, upon your making the relevant request we will notify those third parties of the deletion of the relevant personal data to the extent reasonably practicable; however, if such notification is not possible, or would require disproportionate effort, this shall not apply.

4.3 Right to restrict processing To the extent permitted by applicable law, you have the right to request that we restrict the processing of your personal data. For example, when you contest the accuracy of your personal data, we may need to restrict processing while we verify the accuracy of those data. During the period of restricted processing, the relevant personal data will generally only be stored; unless you consent, or for the establishment, exercise or defense of legal claims, or for the protection of the rights of other natural persons or legal entities, or on the basis of important public interest, we will not process those personal data further. Where we have disclosed personal data subject to restricted processing to third parties, we will inform those third parties of the restriction on processing within a reasonable scope of what is reasonably practicable; however, where such notification is not possible or would involve disproportionate effort, we will not do so. We will inform you before the restriction on processing is lifted. 4.4 Right to object to processing You have the right to object to our processing of your personal data based on legitimate interests, including profiling based on such legitimate interests. You also have the right to object at any time to our processing of your personal data for purposes of direct marketing, including profiling related to direct marketing. If you object to data processing for purposes of direct marketing, we will stop processing your personal data for that purpose. For other processing based on legitimate interests, if you object, we will no longer process the relevant personal data unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or that the processing is necessary for the establishment, exercise or defense of legal claims. 4.5 Right to data portability To the extent permitted by applicable law, you have the right to receive your personal data that you have provided to us in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another data controller. Where technically feasible, you may also request that we transmit the relevant personal data directly to another data controller.