Privacy Policy

1) Information about the Collection of Personal Data and Contact Details of the Controller

1.1 General Information

We are pleased that you are using our application Subio (hereinafter referred to as the “Application” or “App”).

In the following provisions, we inform you comprehensively about the processing of your personal data when using our Application and related services.

Personal data means any information relating to an identified or identifiable natural person. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or other characteristics specific to their identity.

1.2 Controller

The controller responsible for data processing within the meaning of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 is:

Unlock Futurix Ltd
71–75 Shelton Street
Covent Garden
London
WC2H 9JQ
United Kingdom

Email: support@unlockfuturix.com

The controller is the natural or legal person who determines the purposes and means of processing personal data.

1.3 Security and Encryption

For security reasons and to protect the transmission of personal data and other confidential content, the Application uses industry-standard encryption technologies (such as TLS/HTTPS) where data is transmitted.

Subio is designed with a privacy-first architecture. Subscription data entered or imported by you is stored locally on your device. We do not operate user accounts and do not maintain centralized user profiles.

2) Categories of Data Processed

2.1 No User Accounts

Subio does not require registration or login.

We do not collect or store:

• Names

• Email addresses (unless you contact us)

• Passwords

• User profiles

Subscription data is stored locally on your device.

2.2 Subscription Data Stored on Your Device

When using Subio, you may enter or import:

• Subscription names

• Prices

• Billing cycles

• Renewal dates

• Notes

• Categories

This information is stored locally on your device and is not transmitted to us unless you explicitly share information for support purposes.

2.3 Import and AI Processing

Subio may allow you to import information from:

• Screenshots

• Receipts

• PDFs

• Text

Where supported, Subio uses Apple-provided on-device technologies for text recognition and data extraction.

Processing takes place locally on your device.

You review and approve extracted information before it is saved. Nothing is added automatically.

We do not store or analyze your imported documents on our servers.

2.4 Crash Reporting (Sentry)

To ensure stability and improve technical performance, we use Sentry.

Sentry may process:

• Anonymous crash reports

• Error logs

• Device model

• Operating system version

• App version

• Performance diagnostics

This data:

• Does not intentionally include your subscription content

• Does not include names or email addresses

• Is used solely for debugging and reliability improvements

Legal basis: Article 6(1)(f) UK GDPR (legitimate interest in ensuring technical stability and security).

2.5 Analytics (Amplitude)

We use Amplitude to collect limited, anonymous usage analytics.

Amplitude may process:

• Feature usage events

• Screen views

• App interaction metrics

• Device metadata

• Anonymous installation identifiers

This data is used to:

• Improve features

• Understand aggregated usage trends

• Identify product improvements

We do not use analytics for advertising or profiling.

Legal basis: Article 6(1)(f) UK GDPR (legitimate interest in product improvement).

2.6 Website Analytics (Microsoft Clarity)

If you visit our website, Microsoft Clarity may collect:

• Click and scroll interactions

• Device and browser information

• Website usage behavior

This applies only to the website, not in-app subscription data.

Legal basis: Article 6(1)(f) UK GDPR.

2.7 Push Notifications (OneSignal)

If you enable notifications, we use OneSignal to deliver reminders.

OneSignal may process:

• Device push token

• Notification delivery metrics

• Device metadata necessary for delivery

You may disable notifications in your device settings.

Legal basis: Article 6(1)(a) UK GDPR (consent, where required).

2.8 Subscription Management (Adapty & App Store)

We use Adapty to manage subscription validation and paywall presentation.

Adapty may process:

• Subscription status

• Purchase confirmations

• Renewal and trial events

• Anonymous installation identifiers

All payments are processed by Apple App Store (and Google Play in the future).

We do not receive or store payment card details.

Legal basis: Article 6(1)(b) UK GDPR (contract performance).

2.9 Contact and Support

If you contact us via:

• Email

• Tawk.to chat

• Tally forms

We may process:

• Your name (if provided)

• Email address

• Message content

• Attachments

We use this data solely to respond to your inquiry.

Legal basis:

• Article 6(1)(f) UK GDPR (legitimate interest in responding to inquiries)

• Article 6(1)(b) UK GDPR (if related to contractual performance)

3) Legal Bases of Processing

Processing is based on:

• Article 6(1)(a) UK GDPR – Consent

• Article 6(1)(b) UK GDPR – Contract performance

• Article 6(1)(c) UK GDPR – Legal obligation

• Article 6(1)(f) UK GDPR – Legitimate interests

4) Retention and Deletion of Data

We retain personal data only for as long as necessary for the stated purposes or as required by law.

• Subscription data remains on your device until deleted by you.

• Crash and analytics data are retained according to provider retention settings.

• Support communications are deleted once resolved unless legal retention applies.

5) Your Rights as a Data Subject

You have the following rights under UK GDPR:

• Right of access (Article 15)

• Right to rectification (Article 16)

• Right to erasure (Article 17)

• Right to restriction (Article 18)

• Right to data portability (Article 20)

• Right to object (Article 21)

• Right to withdraw consent (Article 7(3))

• Right to lodge a complaint (Article 77) with the Information Commissioner’s Office (ICO)

Because Subio does not maintain user accounts, we may not always be able to identify you in our systems unless you contact us directly.

6) Transfers to Third Countries

Some service providers (Sentry, Amplitude, OneSignal, Adapty, Microsoft Clarity, Tawk.to, Tally) may process data outside the United Kingdom.

Where data is transferred outside the UK or EEA, we rely on safeguards in accordance with Articles 44–49 UK GDPR, including Standard Contractual Clauses where applicable.

7) Automated Decision-Making

We do not use automated decision-making, including profiling, within the meaning of Article 22 UK GDPR.

8) Children’s Privacy

Subio is not intended for children under 13.

We do not knowingly collect personal data from children. If we become aware of such collection, we will delete the information.

9) No Affiliations

Subio is not partnered with, sponsored by, or connected to any subscription services you track. It is an independent product.

10) Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in legal requirements or improvements to Subio.

The updated version will be published with a revised “Last updated” date.

11) Contact

If you have questions regarding this Privacy Policy:

Unlock Futurix Ltd
71–75 Shelton Street
London WC2H 9JQ
United Kingdom

Email: support@unlockfuturix.com