1. Important Information and Who We Are

1.1 Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how Sublimind collects and processes your personal data through your use of the Service, including any data you may provide when you create an account, subscribe to our service, use our application, or contact us.

1.2 Controller

Bright Code Holdings SRL is the controller and responsible for your personal data (referred to as "Sublimind", "we", "us" or "our" in this Privacy Policy). We are a company registered in Romania and operate in accordance with European data protection laws, including the General Data Protection Regulation (GDPR).

1.3 Contact Details

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: [email protected]

1.4 Changes to the Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

1.5 Third-Party Links

Our Service may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Service, we encourage you to read the privacy policy of every website you visit.

2. The Data We Collect About You

We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:

2.1 Identity Data includes first name, last name, username or similar identifier.

2.2 Contact Data includes email address and, optionally, your phone number.

2.3 Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, device information, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Service.

2.4 Profile Data includes your username and password, preferences, feedback, and survey responses.

2.5 Usage Data includes information about how you use our Service, such as features used, content accessed, time spent on the app, and other usage patterns.

2.6 Subscription Data includes details about subscriptions you have purchased, including the type of subscription, duration, renewal information, and payment status.

2.7 Payment Data: We do not directly collect or store your payment card details. Payment transactions are processed through our third-party payment processors (such as Apple App Store, Google Play, or Stripe), and we only retain limited transaction information.

2.8 Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

3. How We Collect Your Data

We use different methods to collect data from and about you, including:

3.1 Direct Interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:

• Create an account on our Service;
• Subscribe to our premium services;
• Subscribe to our newsletters or other communications;
• Request marketing to be sent to you;
• Enter a competition, promotion, or survey;
• Give us feedback or contact us.

3.2 Automated Technologies or Interactions. As you interact with our Service, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

3.3 Third Parties or Publicly Available Sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from analytics providers such as Google Analytics;
• Contact and Transaction Data from providers of technical, payment, and delivery services;
• Identity and Contact Data from publicly available sources.

4. How We Use Your Personal Data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

4.1 Where we need to perform the contract we are about to enter into or have entered into with you. This includes providing you with the Service you have subscribed to.

4.2 Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, to improve and develop our Service and to conduct business analytics.

4.3 Where we need to comply with a legal obligation, such as maintaining appropriate business records or complying with applicable laws.

4.4 Where you have given consent to the processing of your personal data for one or more specific purposes, such as marketing communications.

We have set out below a description of the ways we plan to use your personal data and which of the legal bases we rely on to do so:

4.5 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You can opt out of receiving marketing communications from us at any time by following the opt-out links on any marketing message sent to you or by contacting us directly.

4.6 Cookies

Our Service uses cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

5. Disclosures of Your Personal Data

We may share your personal data with the following categories of recipients:

5.1 Service Providers: We may share your personal data with service providers who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

5.2 Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.

5.3 Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy.

5.4 Legal Requirements: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process.

5.5 Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5.6 With Your Consent: We may disclose your personal information for any other purpose with your consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

We are based in Romania (European Union), and your data is primarily processed in the EU. However, some of our service providers may be based outside of the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield or have implemented similar appropriate safeguards.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

If you delete your account, we will delete or anonymize your personal data, except where we are required to maintain this information by law.

9. Your Legal Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include:

9.1 The right to access – You have the right to request copies of your personal data.

9.2 The right to rectification – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

9.3 The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

9.4 The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

9.5 The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

9.6 The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you wish to exercise any of these rights, please contact us at [email protected]. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from children without verification of parental consent, we take steps to remove that information from our servers.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us:

Bright Code Holdings SRL

📧 [email protected]