Privacy Policy

  1. Introduction

    SubHub Apps Inc. (hereinafter “SubHub”, “we”, or “us”) respects individual privacy and values the confidence of our customers, employees, consumers, business partners and others. This privacy policy (“Policy”) explains how we collect, use and share information from our users of our Services. If you are located in the European Economic Area (“EEA”), this Policy informs you of your choices and our practices in relation to your Personal Information (as defined below).

    For the purposes of this Policy, “Personal Information” means any information relating to an identified or identifiable individual. This includes Personal Information collected and processed by us when you access our websites, (including https://www.refilliate.com (the “Website”)), the SubHub payments app, and/or any of our services that link to this Policy (collectively, our “Services”).

    This Policy describes the Personal Information that we gather from you on the Services, how we use and disclose such Personal Information, your rights and choices with respect to your Personal Information, and how you can contact us if you have any questions or concerns.

    Beyond this Policy, your use of our Services is also subject to our Terms of Service. If you are a California resident, our CCPA Policy provides more information about your California privacy rights and explains how you can exercise those rights.

  2. Information for our Merchants

    When you install the Services, we receive Personal Information about you as set forth below:

    • We collect your name, email, business address, phone number, and time zone.
      • We require this information to provide you with our service, for example to be able to contact you, properly show dates on your Ambassador Portal & Admin Portal, and correctly format invoice information.
    • We collect information about the SubHub hosted websites you visit, as well as information about how and when you visit, your network information (such as the IP address).
      • We need this information to give you access to and improve our Services.
    • We collect Personal Information on your customers that you share with us or that customers provide you when purchasing products from your site.
      • We use this information to provide you with our Services and so that you can process orders.
    • We will also use Personal Information in other cases where you have given us your permission.
    • We may anonymize, de-identify, and aggregate this information for purposes of creating and distributing case studies industry reports and for conducting research and development efforts in connection with improving our Services.

  3. Information for our Merchants’ Customers

    When you purchase something from a store for which the SubHub App is installed or connected, we collect the Personal Information your customers provide us as set forth below.

    • We collect each customer’s name and email address.
      • We require this information in order to provide you and your customer with our Services.
    • When customers browse your checkout and create orders, we collect information about their computer and network traffic.
      • We use this information for security purposes and to provide you and your customer with our Services.
    • We will also use Personal Information in other cases where you have given us your express permission.
    • We may anonymize, de-identify, and aggregate this information for purposes of creating and distributing case studies industry reports and for conducting research and development efforts in connection with improving our Services.

  4. Consent

    How do you get my consent?

    When you provide us with personal information to complete a transaction, verify your credit card, place an order, arrange for a delivery or return a purchase, we imply that you consent to our collecting it and using it for that specific reason only.

    If we ask you for your Personal Information for a secondary reason like marketing, we will either ask you directly for your express consent or provide you with an opportunity to opt out of such uses of your Personal Information.

    How do I access my personal information?

    You can access, amend, and correct your Personal Information anytime. Both merchants and their customers have full access to update or delete their Personal Information from the merchant admin access or the Customer Portal. If you are unable to change any Personal Information, please contact us to make the changes. It is important to remember if you delete or limit the use of your Personal Information, our Services may not function properly.

    How do I withdraw my consent?

    If after you opt-in, you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at [email protected] or mailing us at:

    SubHub Apps Inc.
    21781 Ventura Blvd
    PMB 10065
    Woodland Hills, CA 91364

    What if I am based in the EEA?

    • If you are located in the European Economic Area, you have the additional rights described below.
    • You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. You also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.
    • You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
    • You may exercise these rights by contacting us using the contact details at the end of this Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases promptly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

    What if I am a California resident?
    If you are a California resident, you can review our CCPA Privacy Policy for more information about your rights and choices under California law.

  5. Our Use of European Personal Information

    If you are located in the European Economic Area, we only process your Personal Information when we have a valid “legal basis”, including when:

    • Consent. You have consented to the use of your Personal Information, including, for example, to send you marketing communications or to use cookies and similar technologies.
    • Contractual necessity. We need your Personal Information to provide you with the Services, including, for example, to respond to your inquiries.
    • Compliance with a legal obligation. We have a legal obligation to use your Personal Information, including, for example, to comply with tax and accounting obligations.
    • Legitimate interests. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

  6. Disclosure

    Except as described in this Policy, we will not disclose your Personal Information that we collect on the Services to third parties without your consent. We may disclose Personal Information to third parties if you consent to us doing so, as well as in the following circumstances:

    • Affiliates. We may share any Personal Information we receive with our affiliates for any of the purposes described in this Policy.
    • Vendors and Service Providers. We may share any Personal Information we receive with vendors and service providers retained in connection with the provision of our Services as described in Section 9 below regarding “Information shared with Third-Party Services”.
    • Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect Personal Information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
    • Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/ ) or the Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN ). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
    • As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through the Services.
    • Merger, Sale, or Other Asset Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
    • Consent. We may disclose your Personal Information with your consent.

  7. International Data Transfers

    The Services are hosted in the United States and are intended for visitors located within the United States. If you choose to use the Services from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing, which may not have the same data protection laws as your jurisdiction.

    If you are based in the European Economic Area, your Personal Information may also be held, processed and accessed outside the European Economic Area to countries that have not been determined by the European Commission to provide an adequate level of data protection, for instance the United States. In any such transfer, we will put in place appropriate data protection safeguards (e.g. European Commission’s Standard Contractual Clauses). Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.  To obtain a copy of the relevant transfer mechanism or additional information on the transfers, please contact us using the contact information below.

  8. Security

    We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the personal Information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.

  9. Retention

    We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various factors, such as the type of Services provided to you, the nature and length of our relationship with you, and any mandatory retention periods provided by law and the statute of limitations.

  10. Cookies and Similar Technologies

    What is a cookie? A cookie is a small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. We assign a different cookie to each device that accesses our website. Cookies contain information that is transferred to your computer’s hard drive. We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of the Services. This aids your experience when you use the Services and also allows us to improve the functionality of the Services. When you use our Services, we collect certain information by automated means, using technologies such as cookies and browser analysis tools. In many cases, the information we collect using cookies and other tools is used in a non-identifiable way, without any reference to personal data.

    We use cookies to recognize your device and provide you with our service and a personalized experience. We may use Cookies to make website usage more efficient and to tailor your browsing preferences and improve the functionality of our Website. Cookies can be used for performance management, collecting information on how our Website is being used for analytics purposes. They can also be used for functionality management, enabling us to make the user’s visit more efficient by, for example, remembering language preferences, passwords and log-in details.

    We may also use web beacons, tracking technology and other automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our web pages and promotions.

    Below is an overview of the types of cookies we and third parties may use to collect Personal Information.

    • Strictly necessary cookies. Some Cookies are strictly necessary to make the Services available to you. We cannot provide you with the Services without this type of cookies.
    • Functional cookies. These are used to recognize you when you return to the Services. This enables us to adapt our content for you, and remember your preferences (for example, your choice of language or region).
    • Analytical or Performance cookies. We also use cookies for website and app analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics cookies or use third-party analytics providers such as Google Analytics and Hubspot to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. You can opt out of Google Analytics without affecting how you visit our Services by going to https://tools.google.com/dlpage/gaoptout.
    • Advertising cookies. These cookies are used by advertising companies to collect information about how you use the Services over time.  These providers use this information to show you ads they believe will be relevant to you within the Services and elsewhere, and to measure how the ads perform. We use third-party advertising networks such as Bing Advertising in order to customize advertising. You can opt out of Bing Advertising by visiting https://account.microsoft.com/privacy/ad-settings/signedout?ru=https:%2F%2Faccount.microsoft.com%2Fprivacy%2Fad-settings.

    Where required by applicable law, we obtain your consent to use cookies. Your options for controlling what information cookies and similar technologies collect about you include:

    • Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Services may not work properly. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies, you may experience some inconvenience in your use of our Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit our Services.
    • Industry association opt-outs. You may opt out of receiving interest-based advertising on websites through members of the Network Advertising Initiative by clicking here or the Digital Advertising Alliance by clicking here. Please note that we also may work with companies that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms linked above.
    • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

  11. Children’s Privacy

    By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

    We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our Services are directed to children under 13. If you learn that a child has provided us with Personal Information in violation of this Policy, you may notify us at [email protected].

  12. Changes to This Privacy Policy

    We will post any adjustments to this Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

  13. Questions and Contact Information

    If you have any questions, comments or concerns about our processing activities, or would like to access, correct, amend or delete any personal information we have about you, please contact our Privacy Compliance Officer at [email protected] or by mail at:

    SubHub Apps Inc.
    21781 Ventura Blvd
    PMB 10065
    Woodland Hills, CA 91364

    14. Last updated on Auguest 23, 2022