Subbi's Privacy Policy

1. INTRODUCTION

1.1 This Privacy Policy explains how SUBBI Pty Ltd (ACN 684 736 507) ("Subbi", "we", "our", or "us") collects, uses, stores, discloses, and protects your personal information when you use the Subbi App and Services.

1.2 By downloading, accessing, or using the Subbi App and the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

1.3 We are committed to protecting your privacy and handling your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and other applicable privacy laws (collectively, "Privacy Laws").

2. PERSONAL INFORMATION WE COLLECT

2.1 We collect the following types of personal information:

(a) Account Information: When you create an Account, we collect information such as your email address, username, first name, last name, and password.

(b) Financial Information: To provide our Services, we collect financial information including income, expenses, health insurance details, HECS debt information, employment details, and GST registration status.

(c) Usage Data: We collect information about how you use the Subbi App, including log data, device information, location information, and usage patterns.

(d) Feedback: During the Beta Testing Term, we collect feedback you provide about the Subbi App's functionality, performance, and user experience.

2.2 We collect personal information directly from you when you:

(a) Create an Account on the Subbi App;

(b) Input financial and accounting information into the Subbi App;

(c) Provide feedback during the Beta Testing Term;

(d) Communicate with us via email, social media, or other channels; or

(e) Otherwise interact with the Subbi App and Services.

3. HOW WE USE YOUR PERSONAL INFORMATION

3.1 We use your personal information for the following purposes:

(a) To provide and improve the Subbi App and Services;

(b) To create financial and accounting budgets, forecasts, and tax calculations;

(c) To track and monitor your savings and spending activities;

(d) To create end of year financial and accounting reports;

(e) To communicate with you about your Account, the Services, or updates to the Subbi App;

(f) To improve and update the Subbi App based on your feedback during the Beta Testing Term;

(g) To analyze usage patterns, trends, and statistical data to improve user experience;

(h) To comply with our legal obligations; and

(i) For other purposes for which you provide consent.

4. DISCLOSURE OF YOUR PERSONAL INFORMATION

4.1 We may disclose your personal information to:

(a) Our personnel who need access to provide the Services;

(b) Our Affiliates (as defined in the Terms and Conditions) for the purposes of providing, operating, maintaining, or improving the Services;

(c) Third-party service providers who assist us in operating the Subbi App and providing the Services (such as hosting providers, payment processors, and analytics providers);

(d) Professional advisors such as lawyers, accountants, and auditors;

(e) Regulatory authorities, government agencies, law enforcement bodies, and courts, as required by law; or

(f) A purchaser or prospective purchaser in the event of a sale or potential sale of all or part of our business.

4.2 We will not sell, rent, or trade your personal information to third parties for marketing purposes without your explicit consent.

4.3 When we disclose your personal information to third parties, we take reasonable steps to ensure they handle your personal information in accordance with this Privacy Policy and applicable Privacy Laws.

5. SECURITY OF YOUR PERSONAL INFORMATION

5.1 We take reasonable steps to protect your personal information from misuse, interference, loss, unauthorized access, modification, or disclosure.

5.2 We implement appropriate technical and organizational measures to safeguard your personal information, including:

(a) Encryption of sensitive data;

(b) Password protection and secure access controls;

(c) Secure data storage systems;

(d) Regular security assessments and testing; and

(e) Staff training on data protection practices.

5.3 While we strive to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. Therefore, we cannot guarantee absolute security of your personal information.

5.4 You are responsible for maintaining the confidentiality of your Account login credentials and notifying us immediately of any unauthorized access to your Account.

6. RETENTION OF YOUR PERSONAL INFORMATION

6.1 We retain your personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements.

6.2 Upon termination or expiration of the Beta Testing Term, we will securely destroy your Account and User Content in accordance with clause 13 of the Terms and Conditions. However, we may retain certain personal information as required by applicable laws.

7. YOUR RIGHTS AND CHOICES

7.1 You have the right to:

(a) Access and correct your personal information held by us;

(b) Request deletion of your Account and personal information, subject to our legal obligations to retain certain information;

(c) Withdraw your consent to the collection, use, or disclosure of your personal information (where we rely on consent as the legal basis);

(d) Lodge a complaint if you believe we have breached the Privacy Laws; and

(e) Opt out of receiving marketing communications from us.

7.2 To exercise these rights, please contact us using the details provided in section 10 of this Privacy Policy.

8. COOKIES AND SIMILAR TECHNOLOGIES

8.1 The Subbi App may use cookies, pixel tags, local storage, and similar technologies to collect information about how you use the App and to improve your user experience.

8.2 You can manage your cookie preferences through your device or browser settings. However, disabling certain cookies may affect the functionality of the Subbi App.

9. CHANGES TO THIS PRIVACY POLICY

9.1 We may update this Privacy Policy from time to time to reflect changes in our practices, the Services, or applicable laws.

9.2 We will notify you of any material changes by posting the updated Privacy Policy on the Subbi App or Website, or by other means as required by applicable law.

9.3 Your continued use of the Subbi App and Services after any changes to this Privacy Policy constitutes your acceptance of the updated Privacy Policy.

10. CONTACT US

10.1 If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: engineering@subbi.com.au

10.2 We will respond to your inquiry as soon as reasonably practicable.

11. DEFINITIONS

11.1 Terms not defined in this Privacy Policy have the same meaning as in the Subbi App Beta Testing Terms and Conditions.

Last Updated: [2nd of March 2025]