Privacy Policy

Last updated: 20th of April 2023

Welcome!


BetterSub respects your privacy and is committed to protecting the personal data we hold about you. BetterSub is the data controller of the personal data collected and is responsible for the processing of your personal data.

This Policy describes the BetterSub policies and procedures for collecting, processing, transferring, and storing information when you use the Services and the website and tell you about privacy rights and how the law protects your Personal Data.

This applies to information we collect through, or in association with, our website at www.better-sub.com, and the services that we may offer via our website, our related social media sites, or otherwise through your interactions with us..

The Policy complies with Articles 12, 13, and 14 of the GDPR and the CCPA provisions.

Please read our Privacy Policy carefully to know how we handle your information. Please write to us if you have questions, comments, or concerns about our Privacy Policy.

1. Definitions and Interpretations


Interpretation

The words in which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear singular or plural.


Definitions

“Buyer” means a User who buys Content from a Seller or subscribes to a Seller.

“BetterSub”, “we”, “our”, and “us” means the company operating Better-sub.com, located at Viru tänav 4, 10140, Tallinn, Estonia, and incorporated under the number 16716663.

“GDPR” means general data protection rules relating to the protection of natural persons about the processing of personal data and rules relating to the free movement of Personal Data.

“Personal Data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, an online identifier, etc.

“Processing” means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Seller” means a User who has set up their BetterSub account as a Seller account to post Content on BetterSub to be viewed or bought by other Users, as well as receiving Subscriptions.

“Services” means an online services platform for Sellers and Buyers, where Buyers can Subscribe, make donations, and purchase Content from sellers.

“Usage Data” refers to data collected automatically, either generated using the Website infrastructure itself (for example, the duration of a visit, website usage, and the number of users).

“User”, “you”, and “your” means any user of BetterSub, whether a Buyer or a Seller, or both.


2. Collecting and using your Personal Data



Personal Data

While using the Services and our website(s), you may provide certain personally identifiable information that can be used to contact or identify you. Personal Data that we collect may include, but is not limited to:

  • Full legal name and surname for your account and billing information;

  • Nickname for providing or receiving transfers via our Services;

  • Email;

  • Phone number;

  • Country of residence;

  • Correspondence and billing address.

BetterSub has the right, at any time, at its sole discretion, to request you confirm your personal information or any other information related to providing Services.

There are three basic ways we collect information:

  • Information you choose to give us;

  • Information we get automatically when you use our Services; and

  • Information we get from third parties.

Below are details about each of these categories.


Information You Choose to Give Us

When you interact with our Services, we collect the information you choose to share. For example, most of our services require you to set up a basic account, so we need to collect a few essential details about you: a unique username you’d like to go by, a password, and an email. We may collect identifying information from you, such as a real name, alias, postal address, internet protocol address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

For Sellers, we may ask you for additional information to enable features or make it easier for others to find you, such as a phone number, date of birth, profile pictures, physical details, interests, etc.

Spending or receiving money through our Services may require you to provide us with more sensitive data about yourself; we would like to address the two most common cases.

Credit Card Credentials: We do not store any credit card numbers on our servers; we simply transmit them to our trusted third-party payment providers. When you make a payment processed by a payment provider, you will provide that third party with your credit card number, expiration date, and security code, which they process and store subject to their privacy policy and terms of service. We do not receive your credit card number, expiration date, or security code. Our payment providers follow the market standards for credit card payment security - they comply with the highest PCI DSS level (Payment Card Industry Data Security Standards).

ID Forms: We may request you to prove your identity to keep using our Services to comply with specific local regulations or if we suspect unlawful activities. We also require all of our Sellers to submit ID documentation, as well as for any person appearing in the content they sell with us. This information is stored securely (encrypted in a secure vault) by our partner ID analyser and is only accessible to our qualified support personnel. ID analyser requires that you submit your passport or other government identification document and use facial analysis software to verify your identity.




Information We Get Automatically When You Use Our Services

When you use our Services, we collect information about which Services and how you’ve used them. We may know that you searched for certain terms, viewed some particular videos, and posted a comment. Below is a more detailed explanation of the types of information we collect when you use our Services.

Usage Information: We collect information about your activity through our Services. For instance, we may collect information about the following:

  • How you interact with the Services, such as which pages you consult, the content you purchase, or what categories you browse.

  • How you communicate with the other users and us, such as the time, date, sender, recipient, the body of a message, the number of messages you exchange with other users, and your interactions with messages (such as when you open a message or click a link in it)

Content Information: We collect the content you provide and information about that content, such as who views the content, interacts with the content, and the metadata that is provided with the content.

Device Information: We collect device-specific information, such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information. We also collect device information that will help diagnose and troubleshoot problems in the event you experience any crash or other problem while using our Services.

Camera and Photos: Certain of our Services require us to collect images and other information from your device’s camera and photo, for example, if you want to capture and submit content right away. We never access the camera or photos unless you consent to do so.

Location Information: When you use our Services we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.

Information Collected by Cookies and Similar Technologies: Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique device identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners.

Log Information: We collect log file information when you use our Services. That information includes, but is not limited to, details about how you’ve used our Services, device information, such as your web browser type and language, access times, pages viewed, your IP address, pages you visited before navigating to our Services, cookies that may uniquely identify your device or browser.


3. Tracking technologies and cookies

BetterSub uses Cookies and similar tracking technologies to track the activity on the Website and in the Software and store certain information. Tracking technologies are beacons, tags, and scripts to collect and track information and improve and analyze the Software and the website.

The technologies that BetterSub uses may include (but are not limited):

  • Cookies or Browser Cookies. A cookie is a small file placed on your Device. You can instruct the browser to refuse all Cookies or to indicate when Cookie is being sent. However, if you do not accept Cookies, you may be unable to use some parts of the website.

  • Flash Cookies. Certain features of the Website may use locally stored objects (or Flash Cookies) to collect and store information about your preferences or activity on the website. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies.

  • Web Beacon. Certain sections of the website emails may contain small electronic files known as Web Beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit BetterSub, for example, to count guests who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal devices when you go offline, while Session Cookies are deleted as soon as you close the web browser.

BetterSub uses both Sessions, and Persistent Cookies for the purposes set out below:

Necessary/Essential Cookies
Type: Session Cookies
Administered by BetterSub
Purpose: These Cookies are essential for providing you with services available through the website and enabling you to use some of its features. They help to authenticate users and prevent fraudulent use of your accounts. Without these Cookies, the services you have asked for cannot be provided, and BetterSub only uses these Cookies to provide you with those services.

Cookies Policy/Notice Acceptance Cookies
Type: Persistent Cookies
Administered by BetterSub
Purpose: These Cookies identify if you have accepted cookies on the website.

Functionality Cookies
Type: Persistent Cookies
Administered by BetterSub
Purpose: These Cookies allow the Website to remember the choices you make when using the website, such as remembering your login details or language preference. The purpose of these Cookies is to provide you with a more personal experience and avoid having to re-enter preferences every time you use the website.

Advertising Cookies
Type: Persistent Cookies
Administered by BetterSub
Purpose: Those cookies can be turned on and off by the Website to deliver our potential customers the best advertising experience. They do not contain personal information and are based on your actions on the website.


GOOGLE ANALYTICS: personal data and information obtained by way of such cookies concern the use that you make of the Website and will be transmitted from your browser to Google Inc., with registered office at 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States of America, and stored on Google’s servers. Google’s norms on privacy, which we kindly invite you to read, are available at the following URL: http://www.google.com/intl/it/privacy/privacy-policy.html.

The information on personal data concerning Google Analytics services is available at the following URL: http://www.google.com/intl/en/analytics/privacyoverview.html.

BROWSING DATA: computer systems and procedures responsible for the correct functioning of the Website automatically acquire, whilst operating, some Personal Data concerning the User's browsing history. For instance, within this category, BetterSub may find:

  • IP addresses;

  • Number of accesses to the website;

  • Visited pages;

  • Date and time of access;

  • Browser type;

  • Adopted operating system.

Data voluntarily provided by you: Data freely and optionally provided by you via email to one of the email addresses indicated on the Website or in this Information may be acquired for purposes communicated to you from time to time. Besides email addresses required to answer you, additional Personal Data included within the same communication received by BetterSub may be processed. Personal Data collected as such will be retained and processed solely for the purpose of preserving them and sending correspondence and for no further purpose.


4. Use of Your Personal Data

BetterSub may use Personal Data for the following purposes:

  • To provide and maintain the website and the Services, including monitoring the usage of the Services.

  • For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services you have purchased or of any other contract with BetterSub through the website.

  • To provide you with news, special offers, and general information about services and events that BetterSub offers, like those you have already used unless you have opted not to receive such information.

  • To manage your requests: To attend to and manage your requests to the website.

  • For business transfers: BetterSub may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or another sale or transfer of some or all BetterSub assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by BetterSub about the website and the Services users is among the assets transferred.

  • For other purposes: BetterSub may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of the website’s and the Service’s promotional campaigns, evaluating and improving the website and the Services, products, and services, marketing, and your experience.

BetterSub may share your Personal Data in the following situations:

  • With service providers: BetterSub has the right to share your Personal Data with service providers to monitor and analyze the use of the website and the Services and to contact you.

  • For business transfers: BetterSub may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of BetterSub’s assets, financing, or acquisition of all or a portion of BetterSub’s business to another owner.

  • With Affiliates: BetterSub has the right to share your Personal Data with BetterSub affiliates, in which case BetterSub will require those affiliates to honor this Privacy Policy. Affiliates include BetterSub parent company and any other subsidiaries, joint venture partners, or other companies that BetterSub controls or that are under common control with BetterSub.

  • With business partners: BetterSub has the right to share your Personal Data with business partners to offer you certain products, services, or promotions.

  • With your consent: BetterSub has the right to disclose your Personal Data for any other purpose only with your advance consent.


5. Transfer of Your Personal Data

Your information, including Personal Data, processing by BetterSub’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers outside your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy, followed by submission of such information, represents your agreement to that transfer.

BetterSub will take all steps reasonably necessary to ensure that your Personal Data is treated securely and following this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your Personal Data and other personal information.


6. Retention of Your Personal Data

BetterSub will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy.

BetterSub will retain and use your Personal Data to the extent necessary to comply with BetterSub’s legal obligations (for example, if we are required to retain BetterSub’s Personal Data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

BetterSub will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this Personal Data is used to strengthen the security or to improve the functionality of the Website, or BetterSub is legally obligated to retain this data for longer periods.

BetterSub will retain your personal data in databases while using the best practices to provide the safest and most stable data protection.


7. Information We Collect from Third Parties

We may collect information that other users provide about you when they use our Services. For example, if another user has referred you to our Services, we may combine the information we collect from that user with other information we have collected about you. We may also obtain information from other third-party sources and combine and combine that with the information we collect through our Services.


8. Disclosure of Your Personal Data

Business Transactions

If BetterSub is involved in a merger, acquisition, or asset sale, your Personal Data may be transferred. BetterSub will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, BetterSub may be required to disclose your Personal Data if required by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

BetterSub may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with legal obligations.

  • Protect and defend the rights or property of BetterSub.

  • Prevent or investigate possible wrongdoing in connection with the Services.

  • Protect your personal safety, the Services, or the public.

  • Protect against legal liability.


9. Legal Bases for Processing

We process your personal data for, or based on, one or more of the following legal bases:

  • Performance of a contract: By using our Services, you have contracted with us through the Terms and Conditions, and we will process certain personal data to perform under that contract.

  • Legitimate interests: We may process your personal data for our legitimate interests, including complying with any applicable law, rule or regulation, investigation, or remedy; enforcing our Terms and Conditions; protecting our, our user’s, or others’ rights, property, and safety; and detecting and resolving any fraud or security concerns.

  • Compliance with legal obligations and protection of individuals: We may process your personal data to comply with our legal obligations, including as required by valid legal processes and governmental requests, and to protect those individuals who use our Services and others.


10. Information You Choose to Share with Third Parties

The Services may also contain third-party links, integrations, or a co-branded or third-party-branded service that’s being provided jointly with or by another company. By going to those links, using third-party integrations, or using a co-branded or third-party-branded service, you may be providing information directly to the third party, us, or both. You acknowledge and agree that we are not responsible for how those third parties collect or use your information. We encourage you to review the privacy policies of every third-party website or service you visit or use, including those third parties you interact with through our Services.


11. Protecting your Personal Information

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of Personal Data. Those safeguards include:

  • The encryption of personal data where we deem appropriate

  • Taking steps to ensure personal data is backed up and remains available in the event of a security incident; and

  • Periodic testing, assessment, and evaluation of the effectiveness of our safeguards.

While we use measures designed to protect your personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that the information you transmit through our Services is or will be secure.


12. Choice and Control over Your Information

We pledge to do our best to grant you control of your information and whom you share it with. We let you update or correct your basic account information by editing your settings. We’ll also add new features to keep track of the information you share, mainly when using third-party integrations.

Should you have any difficulty modifying your personal data, please contact us at support@better-sub.com.


13. Analytics and Advertising Services Provided by Others

We may let other companies use cookies, web beacons, and other tracking technologies on the Services. These companies may collect information about how you use the Services and other websites and online services over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

Additionally, some companies may use the information they collect on our Services to deliver targeted advertisements on behalf of us or other companies, including on third-party websites and apps.


14. Revisions to the Privacy Policy

This privacy policy is subject to change from time to time. Whenever we change it, we’ll let you know by revising the date at the top of the page. In case of important changes, we would also provide you with additional notice, for example by notifying you.


15. GDPR notice

The legal basis for processing your Personal Data is Art. 6 sec. 1 a) b), f) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals about the processing of personal data and the free movement of such data and repealing Directive 95/46 / MI Laws UE.L.2016.119.1) (GDPR), where the legitimate interest of BetterSub is related to providing the Software for you.

Personal Data will be processed for a period until an objection to data processing or termination is made, but no longer than 10 (ten) years.

You have the right to access, correct, delete, or restrict his or her Personal Data or to object to the processing, as well as the right to transfer the Personal Data and the right to complain to the supervisory authority.

In the case of obtaining data and processing them based on Art. 6 sec. 1-year a) GDPR – you have the right to withdraw consent at any time, without prejudice to the lawfulness of the processing carried out based on consent to its withdrawal.

Under the GDPR, BetterSub is a data controller for the Personal Data collected from all categories of data subjects listed above, with the following exceptions: BetterSub is a data processor of user logs, administrative user logs, and some account settings information. In addition, BetterSub is a data processor for any of the information you provide through the Website and/or the Software that transit. Where BetterSub is a data processor, BetterSub processes data on your behalf under your data processing instructions.


16. Dispute resolution

If you have an unresolved privacy or data use concern that BetterSub has not addressed satisfactorily, please contact us via support@better-sub.com.