Privacy Policy

Last Updated: June 1, 2025

1. Introduction

SUBBYWORK LIMITED (“SubbyWork,” “we,” “us,” or “our”) is fully committed to protecting your privacy. This Privacy Policy describes in detail how we collect, use, disclose, and safeguard your personal information in connection with your use of our website, its subdomains (collectively, the “Service”), and our application, SubbyWork. By accessing or using the Service, you acknowledge that you have read, understood, and agreed to the terms and practices described in this Privacy Policy, as well as our applicable Terms of Service.

This Privacy Policy applies to both SubbyWork.com (used by contractors) and Subby.Work (used by subcontractors), both operated by SUBBYWORK LIMITED. These platforms share common infrastructure and may process user data using shared systems.

2. Definitions and Key Terms

For clarity and consistency throughout this Privacy Policy, the following terms shall have the meanings set forth below:

3. What Information Do We Collect?

We collect certain personal information from you when you interact with our website or application, including but not limited to when you register on the platform, place an order, subscribe to a newsletter, respond to a survey, or complete a form. The types of personal information we may collect include the following:

Additionally, we may collect certain information from mobile devices to enhance the user experience. Such mobile-specific features are strictly optional, and users may choose whether or not to engage with them.

4. How Do We Use The Information We Collect?

The personal information we collect from you may be used in any of the following ways, each consistent with our legitimate business interests and legal obligations:

5. When Does SubbyWork Use Customer Information from Third Parties?

We receive certain types of information from third parties when you contact us or express interest in our services. For example, when you submit your email address to us to indicate your interest in becoming a SubbyWork customer, we may receive related information from third-party service providers who support our operations — including providers of automated fraud detection and verification tools. Such data is used solely for the legitimate purposes of identity verification, fraud prevention, and improving the efficiency and security of our service.

We also, from time to time, collect information that has been made publicly available on social media websites or similar platforms. This may occur, for example, if you publicly interact with our content or voluntarily share or tag SubbyWork on such platforms. This data may include your publicly accessible name, job title, or other shared information and is collected only in accordance with applicable laws and based on your publicly shared content or account configurations on those services.

You remain in control of the amount and type of information that social media platforms make public. To manage or limit the visibility of your information, you may at any time review the privacy and data-sharing settings available on the social media websites you use. SubbyWork respects your privacy choices and will only collect and use data that has been lawfully disclosed and is necessary for our business operations or communication with you as a prospective or existing customer.

6. Do We Share the Information We Collect with Third Parties?

We may disclose the information we collect — both personal and non-personal — to third parties in accordance with the terms set forth in this Privacy Policy. These third parties may include, without limitation, advertisers, contest sponsors, promotional and marketing partners, and other entities that contribute content to our Service or whose products or services we believe may be of interest to you.

In addition, we may share your information with current and future affiliated companies, subsidiaries, and business partners for the purposes of providing integrated services, improving our offerings, or facilitating joint marketing initiatives. In the event that SubbyWork undergoes a corporate restructuring, including but not limited to a merger, acquisition, asset sale, or other change in control, we reserve the right to transfer or assign the personal and non-personal information we have collected as part of such transaction to our successor(s)-in-interest.

We may also engage carefully selected and trusted third-party service providers to perform operational functions and deliver services on our behalf. These may include services such as website hosting, server maintenance, database storage and management, email management, marketing support, credit card processing, customer support, and fulfillment of orders for products or services purchased via our platform. To the extent necessary for them to perform these services, we may share your personal information — and where appropriate, certain non-personal data — with these providers, under strict contractual obligations to safeguard your information and limit its use to authorized purposes only.

Furthermore, we may share portions of our log file data, including IP addresses, with trusted third-party analytics providers, application developers, or advertising networks, for the purpose of compiling usage statistics, monitoring platform performance, and optimizing user experience. If shared, such IP address data may be used to infer general geographic location, device type, internet connection characteristics, and usage trends (such as whether a user has accessed the Service from a shared location). This information may also support the auditing, research, and performance reporting activities of our advertising partners.

We reserve the right to disclose both personal and non-personal information to government authorities, law enforcement agencies, regulatory bodies, or private parties when, in our sole discretion, such disclosure is necessary or appropriate: (i) to comply with legal obligations, subpoenas, court orders, or other lawful processes; (ii) to protect our rights, property, interests, or safety, or those of our customers or any third party; (iii) to prevent, detect, or investigate illegal, unethical, or otherwise actionable activities; or (iv) to enforce compliance with our Terms of Service or any other applicable legal agreements or policies.

7. Where and When Is Information Collected from Customers and End Users?

SubbyWork collects personal information that you, as a customer or end user, voluntarily submit directly to us through your interactions with our website, application, or related services. This includes, but is not limited to, information submitted when you create an account, communicate with us, complete forms, make purchases, or otherwise engage with the Service.

In addition to the information you provide, we may also receive certain personal information about you from trusted third parties, consistent with the practices described throughout this Privacy Policy. These third parties may include verification and fraud prevention services, business partners, or publicly accessible sources such as social media platforms, subject to your privacy settings on those platforms.

The timing and method of collection may vary depending on how you interact with SubbyWork. Information may be collected at the point of registration, during your active use of our services, or upon direct communication with us — whether initiated by you or automatically triggered by system interactions. All such data collection is governed by the principles of lawfulness, fairness, transparency, and relevance to our business functions and your use of the Service.

8. How Do We Use Your Email Address?

By submitting your email address through this website, you expressly consent to receive email communications from us. Such communications may include service-related announcements, promotional messages, newsletters, and other types of informational emails that may be relevant to your interaction with SubbyWork. You may opt out of receiving these communications at any time by clicking on the opt-out or unsubscribe link provided within each email.

We only send commercial or promotional emails to individuals who have authorized us to contact them, either directly or indirectly through a third party. SubbyWork does not engage in the distribution of unsolicited commercial email (“spam”), and we maintain a strict anti-spam policy to uphold your trust and our legal obligations under applicable data protection and consumer communication laws.

Furthermore, by providing your email address, you acknowledge and agree that we may use it for the purpose of targeted advertising through third-party platforms such as Facebook or similar services. Specifically, your email address may be used to create a customer audience segment for advertising purposes, whereby custom advertisements are shown to individuals who have opted in to receive communications from us. This practice is conducted in compliance with applicable digital marketing regulations and platform terms of service.

Please note that email addresses submitted solely through the order processing page are used exclusively to send you information and updates pertaining to your order, such as confirmation emails, shipping notifications, or transactional receipts. However, if you have provided the same email address to us through another method (e.g., newsletter signup or account creation), we may use it for any of the purposes outlined in this Privacy Policy.

Should you wish to unsubscribe from future email communications, we include clear and detailed opt-out instructions at the bottom of each email. Following your opt-out request, we will promptly honor your preferences and remove your email address from our marketing lists in accordance with applicable legal requirements.

9. How Long Do We Keep Your Information?

We retain your personal information only for as long as it is reasonably necessary to provide the SubbyWork services to you and to fulfill the legitimate purposes described in this Privacy Policy. This includes the retention of data to comply with our legal, regulatory, tax, accounting, or reporting obligations, resolve disputes, enforce our agreements, and maintain security and fraud prevention safeguards.

This retention principle applies equally to third parties with whom we may have shared your information in accordance with this Privacy Policy, and who carry out services on our behalf. Such parties are contractually obligated to retain your personal data only for as long as necessary to perform their designated functions and are prohibited from using it for any other purpose.

Once your data is no longer required for the stated purposes — and where we have no further legal obligation to retain it — we will securely delete, anonymize, or otherwise de-identify your information so that it can no longer be associated with or used to identify you. This process is performed in a manner consistent with industry best practices and applicable data protection laws.

10. How Do We Protect Your Information?

We implement a variety of administrative, technical, and physical security measures designed to ensure the safety and confidentiality of your personal information when you place an order or enter, submit, or access your data through our platform.

Subby.Work does not collect or process credit card information or any other payment-related data. All services offered to subcontractors are free of charge through this platform, and no financial transactions occur on the site.

Following the completion of a transaction, we do not retain or store your private financial information (such as credit card numbers, social security numbers, or detailed financial records) on our servers. This approach minimizes the risk of unauthorized access or data compromise related to stored financial details.

While we employ commercially reasonable efforts and security technologies to protect the information transmitted to and stored by SubbyWork, no method of transmission over the Internet or method of electronic storage is 100% secure. As such, we cannot guarantee or warrant the absolute security of any information you transmit to us or that is stored within the Service. Likewise, we cannot guarantee that such data will not be accessed, disclosed, altered, or destroyed due to a breach of any of our physical, technical, or managerial safeguards.

11. Could My Information Be Transferred to Other Countries?

SubbyWork is incorporated and operates under the laws of Ireland. Information collected through our website, via direct interactions with you, or through your use of our customer support and related services may be transferred to, processed in, or accessed from jurisdictions outside of your country of residence, including locations where SubbyWork, its affiliates, personnel, or service providers operate.

Such information may be stored, viewed, or hosted in countries that do not necessarily maintain the same level of data protection laws as your jurisdiction. This includes transfers to and processing in countries that may not provide statutory data protection safeguards equivalent to those required in the European Economic Area (EEA) or other regions with similarly robust frameworks.

To the fullest extent permitted under applicable law, by using our website or Service, or by otherwise providing us with your personal information, you explicitly consent to the international transfer, processing, and hosting of such information across borders. We will take all reasonable steps to ensure that your personal data is treated securely and in accordance with this Privacy Policy, regardless of where it is processed or stored.

12. Is the Information Collected Through the SubbyWork Service Secure?

We take the security of your personal information seriously and implement appropriate physical, electronic, and managerial procedures designed to safeguard and secure the data we collect through the SubbyWork Service. These measures are intended to prevent unauthorized access, maintain data integrity, and ensure the appropriate use of information within our systems.

Such safeguards include, but are not limited to, encryption protocols, secure data storage practices, restricted system access, routine security audits, and employee training on data protection and privacy compliance. These procedures are designed to protect your data during collection, transmission, and storage phases.

However, despite our reasonable and good-faith efforts to provide a high standard of security, no system can be guaranteed as completely infallible. Neither people nor technical systems are immune from failure, and even secure systems may be subject to intentional criminal acts, human error, or policy violations. Encryption, firewalls, and other security technologies offer strong protections but cannot fully eliminate all risks associated with online data transmission or storage.

Accordingly, while we strive to protect your personal information using industry-standard safeguards, we cannot warrant or guarantee its absolute security. If any applicable law imposes a non-disclaimable obligation on us to protect your personal data, you hereby agree that the standard for measuring our compliance with such obligation shall be that of intentional misconduct or gross negligence, as defined by applicable law.

13. Can I Update or Correct My Information?

Your rights to request updates, corrections, or deletions of personal information collected by SubbyWork depend on your relationship with us. These rights are exercised in accordance with applicable data protection laws and the nature of your interaction with our services.

For Personnel employed or contracted by SubbyWork, any updates or corrections to personal data should be processed internally in accordance with our established Human Resources procedures and internal employment policies. These policies govern how personnel information is maintained and updated within the organization.

Customers of SubbyWork have the right to request limitations on certain uses and disclosures of their personally identifiable information. You may contact us at any time in order to: (1) update or correct your personal information; (2) change your communication preferences and the types of information you receive from us; or (3) delete your personal data from our active systems by requesting the cancellation of your account. Any such request will be handled in good faith, subject to verification of your identity and the limitations outlined in this Privacy Policy.

It is important to note that any updates, corrections, changes, or deletions you make will not affect other information that we have previously collected or shared with third parties in accordance with this Privacy Policy prior to the time of your request. To protect your privacy and ensure the integrity of your account, we may take reasonable steps — such as requesting a unique password or other verification — before granting access or allowing modifications to your personal information.

You are solely responsible for maintaining the confidentiality of your account credentials, including your unique password and login information. It is essential that you take appropriate measures to safeguard this information and prevent unauthorized access to your account.

You should also be aware that it is not technologically feasible to remove every single instance of your information from all backup and archival systems. Due to our obligation to maintain routine data backups and to ensure business continuity in the event of data loss or disaster recovery, your personal data may persist in secured, non-erasable formats that are not readily searchable or accessible. Nonetheless, upon receiving your request, we will promptly and reasonably update, correct, change, or delete all personal information stored in our active databases and other accessible records to the fullest extent technically practicable.

If you are an end user of SubbyWork’s services and would like to update, delete, or obtain a copy of any information we have collected about you, you must contact the organization or customer that originally collected your information and with whom you have a direct relationship. SubbyWork acts as a processor of that information on behalf of the customer and cannot make modifications directly unless authorized by the controller entity.

14. Personnel

If you are an employee, contractor, or applicant associated with SubbyWork, we collect and process the information you voluntarily provide to us in connection with your engagement or application. This may include, but is not limited to, personal details, contact information, professional qualifications, prior experience, and other information relevant to the employment or engagement process.

Such information is collected exclusively for legitimate Human Resources purposes, including but not limited to administering employment-related benefits, maintaining accurate personnel records, complying with legal obligations, and evaluating candidates during the recruitment and hiring process. The collection, use, and retention of personnel data are subject to internal policies and are handled in accordance with applicable labor, employment, and data protection laws.

If you are a current or former worker or have applied for a position with SubbyWork, you may contact us at any time to: (1) update or correct the personal data we maintain about you; (2) modify your communication preferences; or (3) request access to a record of the personal data we have collected and processed in connection with your employment or application.

Please note that any such updates, corrections, changes, or deletions will not affect information that we have previously collected or disclosed to third parties in accordance with this Privacy Policy and applicable law. Requests will be processed in a timely manner, and we may take reasonable steps to verify your identity before honoring such requests, consistent with our duty to protect the privacy and security of all personnel data.

15. Sale of Business

We reserve the right to transfer or assign the personal information and other data we have collected about you to a third party in connection with any actual or contemplated sale, merger, acquisition, reorganization, bankruptcy, or other disposition of all or substantially all of the assets of SubbyWork or any of its Corporate Affiliates (as defined below), or the portion of SubbyWork or any such affiliate to which the Service relates.

In the event of such a transaction, your personal and non-personal information may be disclosed to prospective or actual purchasers, their representatives, or advisors, as necessary for the purposes of due diligence, asset valuation, or transaction execution. Any such transfer or disclosure will be subject to appropriate confidentiality obligations and carried out in accordance with applicable laws and regulations.

Should such a transaction be completed, the third party acquiring the assets, business, or control of SubbyWork or its Corporate Affiliate will assume the rights and obligations described in this Privacy Policy. The successor entity will be required to handle your personal information in a manner that is consistent with the terms of this Privacy Policy unless and until you are notified otherwise, and are given the opportunity to review and consent to a new privacy policy, where required by law.

16. Affiliates

We may disclose personal information and other relevant data about you to our Corporate Affiliates for the purposes outlined in this Privacy Policy. Such disclosures may occur in the context of shared services, administrative support, internal business operations, or where necessary to provide you with a seamless and integrated user experience across affiliated entities.

For the purposes of this Privacy Policy, the term “Corporate Affiliate” refers to any entity that directly or indirectly controls, is controlled by, or is under common control with SubbyWork, whether through ownership, voting rights, management authority, or other means. This definition includes parent companies, subsidiaries, joint ventures, and other legally affiliated entities operating under common corporate governance or financial control.

Any personal information disclosed to our Corporate Affiliates will be treated in accordance with the terms of this Privacy Policy. Our Affiliates are required to maintain confidentiality and comply with applicable data protection laws when processing your personal information, and they are prohibited from using such information for any purpose other than that which has been disclosed to you or is otherwise permitted under this Privacy Policy.

17. Governing Law

This Privacy Policy shall be governed by, construed, and enforced in accordance with the laws of Ireland, without giving effect to any choice or conflict of law provisions that would result in the application of the laws of any other jurisdiction.

You expressly consent to the exclusive jurisdiction and venue of the courts located within Ireland for any legal action or dispute arising out of or relating to this Privacy Policy or your use of the Service. This includes, but is not limited to, matters involving data privacy, data protection, and the processing of personal information, except where legal exceptions apply, such as individuals who retain rights under the EU-U.S. Privacy Shield or the Swiss-U.S. Privacy Shield Frameworks (as applicable).

In addition to the foregoing, your access to and use of the website and Service may also be subject to other local, regional, national, or international laws and regulations depending on your place of residence or location at the time of access. You agree to comply with all such applicable laws, and acknowledge that the use of SubbyWork may be subject to additional legal requirements beyond the jurisdiction of Ireland.

By using the SubbyWork platform or contacting us directly, you confirm that you have read, understood, and accepted the terms of this Privacy Policy. If you do not agree to any portion of this Privacy Policy, you must refrain from accessing or using our website or services. Continued use of the Service after the publication of any updates to this Privacy Policy that do not materially alter your rights or our obligations shall constitute your binding acceptance of those updates.

18. Your Consent

We have updated this Privacy Policy to provide you with greater transparency regarding the nature of the personal information we collect, how it is processed, and for what purposes it may be used. These updates reflect our commitment to privacy, data security, and legal compliance.

By using our website, registering an account, or making a purchase through SubbyWork, you hereby provide your explicit and informed consent to the terms and conditions set forth in this Privacy Policy. You also acknowledge and agree that your continued use of the Service constitutes your acceptance of this Privacy Policy and any future updates made in accordance with the procedures described herein.

19. Links to Other Websites

This Privacy Policy applies solely to the SubbyWork website, application, and related services (collectively, the “Services”). It does not extend to any third-party websites, platforms, or services that may be accessible through hyperlinks, banners, embedded content, or other external references included within the SubbyWork platform.

The Services may contain links to websites that are not owned, operated, or otherwise controlled by SubbyWork. We are not responsible for the content, accuracy, legality, or reliability of information contained on such external websites, nor do we assume any obligation to investigate, monitor, or verify the completeness or validity of materials hosted by those websites. The presence of such links on our platform shall not be interpreted as an endorsement or recommendation of the linked websites, their operators, or the content, products, or services they may offer.

Please be advised that when you leave the SubbyWork Services to access a third-party website, this Privacy Policy no longer governs your interactions. Your activity on any such third-party website, including any personal information you choose to disclose, will be subject to that website’s own terms and privacy policies. We strongly encourage you to review the applicable policies of any external site before engaging with it or submitting personal information.

These third-party platforms may also use their own tracking technologies, including cookies, pixels, or scripts, to collect information about you. SubbyWork has no control over the data collected or the ways in which it may be used by such third parties, and we disclaim any responsibility for their practices.

20. Advertising

This website may include third-party advertisements as well as links to third-party websites or services. Such third-party content may be provided by advertisers, sponsors, promotional partners, or other external entities unaffiliated with SubbyWork.

SubbyWork makes no representation or warranty regarding the accuracy, reliability, legality, or appropriateness of any information, content, or materials included in third-party advertisements or linked websites. We expressly disclaim all responsibility and liability for the conduct, representations, terms, policies, or offerings of any third party, including but not limited to the quality, safety, suitability, or reliability of their goods and services.

Advertising plays an important role in supporting SubbyWork and in allowing us, as well as many other service providers, to offer products and services free of charge. We take reasonable efforts to ensure that any advertisements displayed on our website are lawful, unobtrusive, and as relevant as possible to our users.

Nevertheless, third-party advertisements or links to external sites where goods or services are marketed do not constitute an endorsement, sponsorship, or recommendation by SubbyWork. Any reliance on such advertisements or third-party links is undertaken entirely at your own risk. SubbyWork is not responsible for any representations made in advertisements or for any disputes, damages, or issues arising from your use of or reliance on products or services offered through such third parties.

21. Cookies for Advertising

We use cookies to facilitate interest-based advertising and enhance the relevance and effectiveness of advertisements displayed to you over time. These cookies collect data related to your online activity across our website and other digital properties, enabling us and our advertising partners to present you with advertisements that better reflect your preferences, behaviors, and interests.

This practice, commonly referred to as interest-based advertising or behavioral targeting, involves tracking your interaction with websites, content, and advertisements in order to deliver ads tailored to your inferred preferences. These cookies help improve your user experience by limiting the repetition of ads you have already seen, ensuring ads are displayed correctly, and helping advertisers measure the performance of their campaigns.

Without the use of these cookies, advertisers would have significant difficulty determining the effectiveness of their advertising, understanding their target audiences, or optimizing campaign performance. These cookies also help reduce the frequency of irrelevant advertising and prevent the excessive reappearance of the same ad, thereby providing a more balanced and user-friendly experience.

22. Cookies

SubbyWork uses “cookies” to identify and analyze the areas of our website that you have visited, improve functionality, and enhance the overall user experience. A cookie is a small piece of data stored on your computer or mobile device by your web browser. Cookies enable websites to recognize your browser on future visits and may retain preferences or session information to facilitate a smoother and more personalized browsing experience.

We use cookies to improve the performance and functionality of our website. These cookies are non-essential, meaning the website may still operate without them, but certain features may become limited or unavailable. For example, without cookies, certain multimedia elements may not load correctly, and you may be required to re-enter login credentials on each visit, as we would be unable to remember your authenticated session.

Most modern web browsers include settings that allow you to control or disable the use of cookies. However, if you choose to disable or block cookies, please be aware that some parts of our website may no longer function properly or be accessible. We encourage you to review your browser’s cookie management options to determine your preferred level of interaction with cookies.

SubbyWork does not store Personally Identifiable Information (PII) in cookies. Any data stored through cookies is used exclusively to support essential functionality, user preferences, and analytics purposes in accordance with this Privacy Policy.

23. Blocking and Disabling Cookies and Similar Technologies

Regardless of your geographic location, you have the ability to configure your browser settings to block or disable cookies and similar tracking technologies. However, doing so may interfere with the functionality of certain portions of our website and services. Blocking essential cookies may prevent you from using some features or accessing certain areas of the platform as intended.

Please note that if you choose to disable or block cookies, you may also lose access to certain stored preferences or settings, such as login details or user-specific customizations. This may negatively impact your user experience by requiring repeated manual entries or limiting available functionality.

Different web browsers offer varying tools and settings to manage cookies. Disabling a specific cookie or an entire category of cookies does not automatically delete those cookies from your browser. You will need to manually delete cookies via your browser’s settings. For more information on how to manage cookies, we recommend consulting the help menu or support documentation for your specific browser.

While SubbyWork supports your right to control your online privacy, we are not responsible for the consequences that may result from the full or partial blocking of cookies, especially where such actions impair essential site functionality or accessibility.

24. Remarketing Services

We use remarketing services as part of our digital marketing strategy. Remarketing, also known as retargeting, is a form of online advertising that enables us to serve targeted ads to individuals who have previously visited our website or interacted with our services. These advertisements may appear across various websites and platforms that you visit after leaving our site.

Remarketing allows SubbyWork to maintain engagement with previous visitors and present them with relevant advertising content based on their prior activity on our platform. This may include displaying customized banners, offers, or service reminders, with the intent to encourage return visits, conversions, or continued interest in our services.

These services operate through the use of cookies and other tracking technologies that record your visit to our site. The data collected through such technologies does not include personally identifiable information, but may include anonymized identifiers such as browser type, device type, pages visited, and general interaction patterns.

Remarketing campaigns are conducted in accordance with applicable privacy regulations, and users are typically provided with the ability to opt out of personalized advertising via the settings provided by the advertising platform (e.g., Google Ads, Facebook Ads). If you wish to opt out of remarketing services, you may do so through your browser settings or by visiting the opt-out pages of participating ad networks.

25. Children Privacy

We do not knowingly collect, solicit, or maintain personally identifiable information from individuals under the age of 13. The SubbyWork website and services are not directed to children, and we do not intend for them to be used by anyone under the age of 13. If you are under 13 years of age, you are expressly prohibited from using the Service and from submitting any personal information through any of its features.

If you are a parent or legal guardian and you become aware that your child has provided us with personal data without your consent, we strongly encourage you to contact us immediately. Upon verification of the claim, we will promptly take steps to delete such information from our records and prevent any further collection or use of the child’s data.

If we discover that we have inadvertently collected personal data from a child under the age of 13 without verifiable parental consent, we will take all reasonable measures to remove that data from our systems in accordance with applicable laws, including the Children’s Online Privacy Protection Act (COPPA) or any equivalent legislation that may apply based on your jurisdiction.

26. Changes to Our Privacy Policy

We reserve the right to amend, update, or otherwise modify this Privacy Policy from time to time in order to reflect changes in our services, legal obligations, technological advancements, or internal business practices. Any such modifications will be made in accordance with applicable data protection laws and will be posted on our website with an updated “Last Updated” date at the top of the page.

Unless otherwise required by applicable law, we will provide notice of material changes by means reasonably designed to inform you — for example, by posting a notice on our Service or sending a direct communication — prior to such changes taking effect. We will also give you an opportunity to review the revised policy before it becomes effective, where required.

Continued use of the Service after any such updates have been posted, and after any applicable notice period has passed, constitutes your binding acceptance of the revised Privacy Policy. If you do not agree to the terms of the updated policy, you retain the right to discontinue use of the Service and, if applicable, delete your account and request removal of your personal information in accordance with this Privacy Policy.

27. Third-Party Services

Our Services may display, include, or provide access to third-party content, data, tools, applications, and other materials or services (“Third-Party Services”), including but not limited to links to external websites, embedded features, or integrations with third-party platforms.

You acknowledge and agree that SubbyWork does not control and is not responsible for any Third-Party Services, including the accuracy, completeness, reliability, legality, decency, validity, copyright compliance, security, or any other aspect of such services. The presence of a Third-Party Service on our platform does not constitute an endorsement, sponsorship, or affiliation with SubbyWork, unless explicitly stated otherwise.

SubbyWork disclaims all liability and responsibility for any damages, losses, or issues arising from your access to or use of any Third-Party Service, or your reliance on content provided through such services. Any interaction between you and a third-party provider is strictly between you and that third party, and is governed by the third party’s own terms of use and privacy policies.

Third-Party Services are provided solely as a convenience to you, and your decision to access or use them is undertaken entirely at your own risk. We recommend that you carefully review the applicable terms and privacy policies of any Third-Party Service before using or providing any personal data through such platforms.

28. Tracking Technologies

29. Information About General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), please be advised that SubbyWork may collect and process personal data in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”). This section explains the legal basis, purpose, and protective measures associated with the collection and processing of such data.

The GDPR establishes comprehensive privacy and data protection requirements that apply to companies processing the personal data of individuals located within the EEA. These provisions are binding on any organization — including SubbyWork — that offers goods or services to EEA residents or monitors their behavior, regardless of the organization's location.

Accordingly, SubbyWork undertakes to collect, use, store, and process personal data of EEA residents in compliance with GDPR requirements. This includes ensuring that all such data is processed lawfully, fairly, and transparently; collected only for specified and legitimate purposes; and retained only for as long as necessary to fulfill those purposes, unless otherwise required by law.

We are committed to implementing appropriate technical and organizational measures to protect personal data from unauthorized access, disclosure, alteration, or destruction, and to support our users in exercising their GDPR rights, as further described in the following sections of this Privacy Policy.

30. What is GDPR?

The General Data Protection Regulation (“GDPR”) is a comprehensive privacy and data protection law enacted by the European Union. It governs how companies collect, process, store, and protect the personal data of individuals residing in the European Economic Area (EEA). GDPR applies not only to businesses established within the EU, but also to organizations worldwide that offer goods or services to individuals in the EU or monitor their behavior within the region.

GDPR significantly strengthens the rights of individuals with respect to their personal data and imposes robust obligations on organizations that process such data. Its key objectives include increasing transparency, enhancing accountability, and empowering individuals to control how their personal information is collected and used.

Although GDPR is an EU regulation, its scope is global. SubbyWork recognizes that the privacy of our users is important regardless of geographic location. Therefore, we have voluntarily adopted GDPR-compliant practices as our baseline data protection standard for all users, worldwide. This commitment ensures consistent privacy safeguards, even for users located outside the European Union.

Our approach includes clearly stating the purposes of data collection, minimizing the amount of data collected, limiting access to that data, and giving users full control over their personal information wherever legally required. We believe that adopting GDPR principles is not only a legal necessity — it is also the ethical foundation of user trust and transparency.

31. What is Personal Data?

Under the GDPR and other applicable privacy laws, “personal data” refers to any information that relates to an identified or identifiable natural person. An identifiable person is one who can be directly or indirectly identified, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.

Personal data encompasses a broad range of information that, on its own or when combined with other data, can be used to identify an individual. It extends far beyond just a name or email address. Examples of personal data include, but are not limited to:

GDPR mandates that personal data be collected and processed according to strict principles. These include, but are not limited to, the following requirements:

32. Why is GDPR Important?

GDPR introduces significant new requirements regarding how organizations collect, store, process, and safeguard the personal data of individuals. It is designed to give individuals greater control over their personal information, enhance transparency around data practices, and ensure that companies implement strong data protection and governance measures.

Under the GDPR, organizations must adhere to strict standards when obtaining consent, notifying individuals of data collection, responding to data access requests, and securing personal information. The regulation also mandates that companies demonstrate accountability and be able to document their compliance efforts. Non-compliance with GDPR can result in substantial administrative fines and legal consequences, including penalties of up to 4% of annual global turnover or €20 million — whichever is greater.

At SubbyWork, we view GDPR as more than just a legal obligation. We believe that safeguarding user data is an ethical responsibility and a cornerstone of user trust. Our commitment to data privacy is reflected in our implementation of security and privacy practices that exceed minimum legal requirements and are applied consistently across our operations, regardless of user location.

We recognize the value of your personal information and are committed to processing it lawfully, securely, and transparently. By aligning our practices with GDPR, we aim to uphold the highest standards of privacy and to ensure that our users have full confidence in how their data is handled.

33. Individual Data Subject’s Rights – Data Access, Portability, and Deletion

SubbyWork is committed to supporting the rights of data subjects under the General Data Protection Regulation (GDPR), and we provide mechanisms to ensure that our users can effectively exercise those rights. These rights apply to individuals whose personal data is processed by SubbyWork, particularly if they reside in the European Economic Area (EEA), but we extend these protections more broadly as part of our global privacy standards.

We process and store all personal data with the assistance of carefully vetted, Data Processing Agreement (DPA)-compliant third-party vendors who meet our strict data protection and security standards. As a general practice, we retain user communications and personal data for a period of up to six (6) years, unless a valid deletion request is submitted or the account is otherwise terminated. In such cases, we will delete all user data in accordance with our Terms of Service and this Privacy Policy — and in any event, no later than sixty (60) days from the date of the deletion request.

If you are a customer working with individuals located in the EU, it is your responsibility to ensure that those data subjects have access to their rights under GDPR. This includes the ability to access, update, retrieve, restrict processing of, or request the deletion or transfer of their personal data. SubbyWork provides tools and internal procedures that enable you to manage your data responsibly and transparently.

We have built our system to be self-service from the outset, empowering you to access and manage both your data and your customers’ data efficiently. You can update or delete personal information through your account dashboard, or you may submit a formal request to our support team for any data subject rights-related inquiries.

Our dedicated customer support team is available to assist with any questions or issues related to your data, your customers' data, or how we handle privacy compliance. We will make every effort to fulfill data subject rights requests in a timely and legally compliant manner.

34. Contact Us

If you have any questions, concerns, requests, or complaints regarding this Privacy Policy, our data handling practices, or your personal information, we encourage you to contact us directly. We take privacy matters seriously and are committed to addressing inquiries in a timely and compliant manner.

You may contact us using the information below:

SUBBYWORK LIMITED
Attn: Legal Department – Data Protection and Privacy
The Black Church, St. Mary’s Place
Dublin 7, D07 P4AX
Ireland
Email: legal@subby.work