PRIVACY POLICY

Last updated on 23 Jun 2026

DATA CONTROLLER

The controller of Your personal data is Applabtech Limited, Myrtiotissis, 13 AQUA MANSIONS, Flat/Office 1, Germasogeia, 4041, Limassol, Cyprus ("Controller", "Company", "we", "our", or "us").

If You have any questions regarding this Privacy Policy or the processing of Your personal data, You may contact us at:

Email: support@mysubtracker.app

Postal Address:
Applabtech Limited
Myrtiotissis, 13 AQUA MANSIONS, Flat/Office 1
Germasogeia, 4041
Limassol, Cyprus

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy describes how we collect, use, disclose, store, and otherwise process personal data in connection with Your use of the SubTracker mobile application, website, and related services (collectively, the "Services").

By accessing or using the Services, You acknowledge that Your personal data may be processed as described in this Privacy Policy.

ELIGIBILITY

The Services are intended solely for individuals who are at least eighteen (18) years old.

We do not knowingly collect personal data from individuals under eighteen (18) years of age. If we become aware that personal data of a person under eighteen (18) has been collected through the Services, we may delete such information and terminate the relevant account.

PERSONAL DATA WE COLLECT

Depending on how You use the Services, we may collect and process the following categories of personal data:

account information, including Your name, email address, username, and other information provided when creating or maintaining an account
financial account information obtained through connected financial accounts and third-party providers, including account identifiers, financial institution information, transaction history, recurring payment information, subscription-related transaction data, merchant names, transaction amounts, and billing dates
communications and support information provided when You contact us
device and technical information, including IP address, device identifiers, operating system information, app version, crash reports, and diagnostic information
usage information relating to Your interaction with the Services, including features used, subscription monitoring activity, and account activity
any other information You voluntarily provide to us

INFORMATION RECEIVED THROUGH PLAID

We may use Plaid Technologies, Inc. ("Plaid") and other financial data providers to enable financial account connectivity and provide certain features of the Services.

When You connect a financial account, Plaid may collect information from Your financial institution and provide such information to us to facilitate the Services.

Your use of Plaid is subject to Plaid's own privacy practices and terms. We encourage You to review Plaid's privacy policy before connecting any financial account.

We do not control and are not responsible for the privacy practices of Plaid or any financial institution.

PURPOSES AND LEGAL BASES FOR PROCESSING

We process personal data for the following purposes:

providing, maintaining, operating, and improving the Services (Article 6(1)(b) GDPR)
creating, administering, and maintaining user accounts (Article 6(1)(b) GDPR)
identifying, monitoring, analyzing, and managing recurring subscriptions and payments (Article 6(1)(b) GDPR)
communicating with users and responding to inquiries, requests, and support tickets (Article 6(1)(f) GDPR)
complying with legal and regulatory obligations (Article 6(1)(c) GDPR)
preventing fraud, abuse, unauthorized access, and security incidents (Article 6(1)(f) GDPR)
establishing, exercising, or defending legal claims (Article 6(1)(f) GDPR)
sending marketing communications where consent is required by applicable law (Article 6(1)(a) GDPR)

SHARING OF PERSONAL DATA

We may share personal data with the following categories of recipients where necessary to operate the Services:

financial data connectivity providers, including Plaid and similar providers
cloud hosting, infrastructure, analytics, customer support, and technology service providers
payment processors and subscription management providers
professional advisers, including legal, accounting, compliance, and audit advisers
competent courts, regulatory authorities, law enforcement agencies, and other governmental authorities where required by applicable law
a purchaser, investor, successor, or other participant in a merger, acquisition, financing, reorganization, sale of assets, or other corporate transaction involving the Company

We do not sell Your personal data.

SERVICE PROVIDERS AND PROCESSORS

We engage third-party service providers that process personal data on our behalf for purposes such as hosting, analytics, customer support, payment processing, subscription management, infrastructure operations, communications, security, and fraud prevention.

Such service providers are authorized to process personal data only as necessary to provide services to us and in accordance with applicable data protection laws.

INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to and processed in countries other than the country in which You reside.

Where required by applicable law, we implement appropriate safeguards to protect personal data transferred internationally, including the use of Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms.

DATA RETENTION

We retain personal data only for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, enforce our agreements, and protect our legitimate interests.

Retention periods may vary depending on the type of data, the purpose of processing, and applicable legal requirements.

When personal data is no longer required, we will delete, anonymize, or securely dispose of it in accordance with applicable law.

YOUR PRIVACY RIGHTS

Subject to applicable law, You may have the following rights regarding Your personal data:

the right to request access to Your personal data
the right to request correction of inaccurate or incomplete personal data
the right to request deletion of Your personal data
the right to request restriction of processing
the right to object to certain processing activities
the right to request portability of Your personal data
the right to withdraw consent where processing is based on consent, without affecting the lawfulness of processing carried out before such withdrawal
the right to lodge a complaint with a competent data protection authority

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

ADDITIONAL RIGHTS FOR U.S. RESIDENTS

Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws, including the right to:

know whether we process their personal data and access such data
request correction of inaccurate personal data
request deletion of personal data
obtain a copy of certain personal data in a portable format
opt out of the processing of personal data for targeted advertising, the sale of personal data, or certain profiling activities, where applicable

SubTracker does not sell personal data for monetary consideration.

To exercise any applicable privacy rights, please contact us using the contact information provided in this Privacy Policy.

We will not discriminate against any individual for exercising privacy rights available under applicable law.

SECURITY MEASURES

We implement appropriate technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access.

Such measures may include access controls, encryption, secure storage practices, monitoring procedures, and other safeguards appropriate to the nature of the personal data processed.

However, no method of transmission over the Internet or electronic storage is completely secure. Accordingly, we cannot guarantee absolute security of personal data.

CHANGES TO THIS PRIVACY POLICY

We may modify or update this Privacy Policy from time to time.

Where required by applicable law, we will provide notice of material changes through the Services or by other reasonable means.

The "Last Updated" date at the top of this Privacy Policy indicates when the latest revisions became effective.

Your continued use of the Services following the effective date of any updated Privacy Policy constitutes Your acknowledgment of such changes.

CONTACT US

If You have any questions regarding this Privacy Policy, the processing of Your personal data, or if You wish to exercise any of Your privacy rights, please contact us at:

Applabtech Limited

Myrtiotissis, 13 AQUA MANSIONS, Flat/Office 1
Germasogeia, 4041
Limassol, Cyprus

Email: support@mysubtracker.app