Privacy Policy

Introduction 
Your privacy and the security of your personal information are of utmost concern to us, because we know that holding onto your private information is a serious responsibility. This Privacy Policy describes how we collect, store, handle your information, under what circumstances we might share or disclose it and how your information is stored and protected.

How Subira collects your Information?
We collect both Personal Information and Non-Personal information about you. Your information is only collected with your permission; we only collect a minimal amount of personal information required to complete your transaction with us; we do not sell your personal information to third parties; and we only use it as described in this Privacy Policy document.

What information is collected and Why?
Automatically collected: IP Address, user agent, and the referring URL. When you visit Subira website we automatically receive your IP address and information such as the user-agent of your web browser. This information is provided to us and every other website that you visit on the Internet by your web browser. We collect this information for functional, security and analytical purposes.

User provided: “Personal information’ means any information that identifies or can be used to identify or contact a person if used combined together with other pieces of information may include, but not limited to, a name, mailing address or billing address, email, phone number, photo, job title, company name, payment information, an online identifier, and other information provided by the user to access our platform and use our services. If you create an account, we require some basic information at the time of account creation. Your account can be created with either a valid email and password or through (OAuth 2) authorization from a trusted service such as Google. Authorization from a trusted service will provide us with your email and basic profile information such as your name. You also have the option to give us more information if you want to, and this may include "User Personal Information." User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, improve, and optimize our website and service.

Why do we collect your Personal Information
We need your User Personal Information to create your account, and to provide the services you request.
- We use your User Personal Information, specifically your user name, to identify you on Subira.
- We use it to fill out your profile and share that profile with other users if you ask us to.
- We use your email address to communicate with you only for reasons you’ve approved. Please see our section on email communication for more information.
- We limit our use of your User Personal Information to the purposes listed in this Privacy Statement. If we need to use your User Personal Information for other purposes, we will ask your permission first. You can always see what information we have, how we're using it, and what permissions you have given us in your user profile.

What information Subira does not collect
We do not intentionally collect sensitive personal information, such as social security numbers, genetic data, health information, or religious information. Although Subira does not request or intentionally collect any sensitive personal information, we realize that you might store this kind of information in your account, such as in a document. If you store any sensitive personal information on our servers, you are consenting to our storage of that information on our servers, which are in Canada. We do not distribute or sell information that is stored in your documents. Information in your documents belongs to you, and you are responsible for it, as well as for making sure that your content complies with our Terms of Service.

Public and Shared Documents
By default, documents created in Subira are private and can only be viewed by users you specify. However, if you set a document's privacy to"public," or create a "share-link," anyone, including search engines, may view the contents of the document. If you have included private or sensitive information in your public document, such as email addresses, that information may be indexed by search engines or used by third parties.

How Subira share the information we collect
We do not share, sell, rent, or trade User Personal Information with third parties for their commercial purposes. We do not disclose User Personal Information outside Subira, except in the situations listed in this section or in the section below on Compelled Disclosure. We do not host advertising on Subira. We may occasionally embed content from third party sites, and that content may include ads. While we try to minimize the amount of ads our embedded content contains, we can't always control what third parties show. We may share User Personal Information with your permission, so we can perform services you have requested. We may share User Personal Information with a limited number of third-party vendors who process it on our behalf to provide or improve our service, and who have agreed to privacy restrictions similar to our own Privacy Statement. Our vendors perform services such as payment processing, customer support ticketing, network data transmission, and other similar services. We may share User Personal Information if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our website or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honor any promises we have made in our Privacy Statement or in our Terms of Service. View our list of sub-processors who we may share personal data with.

Cookies and tracking
Subira uses cookies to make interactions with our service easy and meaningful. We use cookies (and similar technologies, like HTML5 localStorage) to keep you logged in, remember your preferences, and provide information for future development of Subira. A cookie is a small piece of text that our web server stores on your computer or mobile device, which your browser sends to us when you return to our site. Cookies do not necessarily identify you if you are merely visiting Subira; however, a cookie may store a unique identifier for each logged in user. The cookies Subira sets are essential for the operation of the website, or are used for performance or functionality. By using our website, you agree that we can place these types of cookies on your computer or device. If you disable your browser or device’s ability to accept cookies, you will not be able to log in or use Subira’s services. Learn more: cookie disclosure

How we secure your information
Subira takes all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. For more information, see our security disclosures.

Subira's global privacy practices
Information that we collect will be stored and processed in the United States in accordance with this Privacy Statement. However, we understand that we have users from different countries and regions with different privacy expectations, and we try to meet those needs.

In particular:
- Subira provides clear methods of unambiguous, informed consent at the time of data collection, when we do collect your personal data.
- We collect only the minimum amount of personal data necessary, unless you choose to provide more. We encourage you to only give us the amount of data you are comfortable sharing.
- We offer you simple methods of accessing, correcting, or deleting the data we have collected.

General Data Protection Regulation (GDPR)
Privacy is important to us and we know it is to you too. Subira fully supports and complies with the practices and principles outlined by the GDPR. See GDPR

Contact
If you have any specific concerns or questions, please let our support team know and we'll be happy to help: [email protected].

How we respond to compelled disclosure
Subira may disclose personally-identifying information or other information we collect about you to law enforcement in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large.

How you can access and control the information we collect
If you are already a Subira user, you may access, update, alter, or delete your basic user profile information by editing your user profile. You can delete your account, all its documents, and all of the information we contain about you from your account page.

Data Retention and Deletion
Subira will retain User Personal Information for as long as your account is active or as needed to provide you services.
We may retain certain User Personal Information indefinitely, unless you delete it or request its deletion. For example, we don’t automatically delete inactive user accounts, so unless you choose to delete your account, we will retain your account information indefinitely.
If you would like to cancel your account or delete your User Personal Information, you may do so in your user profile. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, but barring legal requirements, we will delete your full profile (within reason) within 30 days.

Email communications
Emails from us
Subira may occasionally send notification emails about changes to documents you have created or others have shared with you. Depending on your email settings we may also send important policy changes, offer customer support or send marketing emails. There is an unsubscribe link located at the bottom of each of the emails we send you.

Emails from Subira users
We allow our users to send limited outbound emails for purposes such as sharing and signing documents. When a user sends an outbound email, it may be delivered with the sender's email address and other Personal Information such as their name or Subira user name. Any accounts that abuse this service may be suspended immediately and indefinitely. If you receive an email from a Subira user which violates our terms of use, please notify our support team.

Pixel tags
Our emails may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email. In certain cases, when a Subira user sends an outbound email through our services, the pixel tag information from their email may be made available to them.

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