Last updated:** [2026.3.19]
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You. We use Your Personal Data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
This Privacy Policy applies to all users who access or use the **SubSmart** Application. It does not apply to any third-party websites, services, or applications that may be linked to our Service (please refer to the "Links to Other Websites" section for more details).
## 1. Interpretation and Definitions
### 1.1 Interpretation
The words whose initial letters are capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
### 1.2 Definitions
For the purposes of this Privacy Policy:
- **Account** means a unique account created for You to access our Service or parts of our Service.
- **Affiliate** means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- **Application** refers to **SubSmart**, the software program provided by the Company.
- **Company** (referred to as either "the Company", "We", "Us" or "Our" in this Privacy Policy) refers to **SubSmart**.
- **Country** refers to the country/region where you access and use the Service, including but not limited to the United States and the People's Republic of China.
- **Device** means any device that can access the Service such as a computer, a cell phone or a digital tablet.
- **Personal Data** is any information that relates to an identified or identifiable individual. We use "Personal Data" uniformly throughout this Privacy Policy to ensure consistency.
- **Service** refers to the Application.
- **Service Provider** means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- **Usage Data** refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit). Usage Data may include diagnostic data (e.g., app crash logs, device performance information).
- **You** means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
## 2. Collecting and Using Your Personal Data
### 2.1 Types of Data Collected
#### 2.1.1 Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to, information you provide when setting up an Account or using the Service’s features (such as your name, email address).
#### 2.1.2 Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data (e.g., app crash logs, device performance information).
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device's unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit Our Service or when You access the Service by or through a mobile device.
#### 2.1.3 Subscription and Purchase Data
When You make a purchase or subscribe to Our Service, We use RevenueCat, a third-party service provider, to process and manage Your subscription. For more information about how RevenueCat handles Your data, please review their Privacy Policy at: https://www.revenuecat.com/privacy.
### 2.2 Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
- To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
- 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 Us through the Service.
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
- To provide You with news, special offers, and general information about other goods, services and events which We offer that are similar to those that you have already purchased or inquired about unless You have opted not to receive such information.
- To manage Your requests: To attend and manage Your requests to Us.
- For business transfers: We may use Your Personal Data to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
- To process subscriptions and purchases: We use RevenueCat to manage in-app subscriptions, verify purchase receipts, and ensure You have access to the features You have paid for. This includes tracking subscription status, renewal dates, and handling subscription-related customer support.
### 2.3 Sharing of Your Personal Data
We may share Your Personal Data in the following situations:
#### 2.3.1 With Service Providers
We may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to contact You, and to process subscriptions. Specifically:
- **RevenueCat**: We use RevenueCat to manage in-app subscriptions and purchases. RevenueCat may collect device identifiers, purchase history, and subscription status to provide subscription management services. RevenueCat is contractually obligated to use Your data only for providing services to Us and to maintain appropriate security measures.
- **Analytics Providers**: Currently, we do not use any third-party analytics providers. If we use analytics services in the future, we will update this Privacy Policy to disclose the provider's name and the type of data shared.
## 3. Retention of Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if We are required to retain Your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Where possible, We apply shorter retention periods and/or reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the retention periods below are maximum periods ("up to") and We may delete or anonymize data sooner when it is no longer needed for the relevant purpose. We apply different retention periods to different categories of Personal Data based on the purpose of processing and legal obligations:
### 3.1 Account Information
User Accounts: retained for the duration of your account relationship plus up to 24 months after account closure to handle any post-termination issues or resolve disputes.
### 3.2 Usage Data
Application usage statistics: up to 24 months to understand feature adoption and service improvements.
Server logs (IP addresses, access times): up to 24 months for security monitoring and troubleshooting purposes.
### 3.3 Subscription and Purchase Data
Purchase receipts and transaction records: retained for up to 7 years to comply with financial and tax regulations.
Subscription status and history: retained for the duration of your subscription plus up to 36 months after cancellation for customer support and dispute resolution purposes.
Device identifiers linked to subscriptions: retained for the duration of your subscription plus up to 12 months after cancellation.
Usage Data is retained in accordance with the retention periods described above, and may be retained longer only where necessary for security, fraud prevention, or legal compliance.
We may retain Personal Data beyond the periods stated above for different reasons:
- Legal obligation: We are required by law to retain specific data (e.g., financial records for tax authorities).
- Legal claims: Data is necessary to establish, exercise, or defend legal claims.
- Your explicit request: You ask Us to retain specific information.
- Technical limitations: Data exists in backup systems that are scheduled for routine deletion.
You may request information about how long We will retain Your Personal Data by contacting Us. You may also request to shorten the retention period of your Personal Data (to the extent permitted by law) by contacting us. We will review your request and respond promptly, and take reasonable steps to adjust the retention period if your request is valid.
When retention periods expire, We securely delete or anonymize Personal Data according to the following procedures:
- Deletion: Personal Data is removed from Our systems and no longer actively processed.
- Backup retention: Residual copies may remain in encrypted backups for a limited period consistent with our backup retention schedule and are not restored except where necessary for security, disaster recovery, or legal compliance.
- Anonymization: In some cases, We convert Personal Data into anonymous statistical data that cannot be linked back to You. This anonymized data may be retained indefinitely for research and analytics.
## 4. Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.
Where required by applicable law, We will ensure that international transfers of Your Personal Data are subject to appropriate safeguards and supplementary measures where appropriate. The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with 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 data and other personal information.
To ensure the security of international data transfers, we will use Standard Contractual Clauses (SCCs) approved by relevant data protection authorities, or rely on other valid transfer mechanisms, to ensure that your Personal Data is protected to the same standard as required by your jurisdiction.
## 5. Delete Your Personal Data
You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You. Our Service may give You the ability to delete certain information about You from within the Service.
You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any Personal Data that You have provided to Us.
Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so. We will complete the deletion or anonymization of your Personal Data within 15 working days after receiving your valid request, in line with relevant regulatory requirements.
## 6. Disclosure of Your Personal Data
### 6.1 Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
### 6.2 Law Enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
### 6.3 Other Legal Requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
## 7. Security of Your Personal Data
The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.
We adopt classified management, encryption and de-identification measures for your Personal Data, formulate data security emergency plans, and conduct regular security assessments to ensure the security of your data in accordance with relevant laws, regulations and industry standards.
## 8. Third-Party Service Providers
We use carefully selected third-party service providers to help Us operate and improve Our Service. These providers have access to Your Personal Data only to perform specific tasks on Our behalf and are obligated not to disclose or use it for any other purpose. We will obtain your separate consent before providing your Personal Data to any third party, in line with regulatory requirements.
### 8.1 Subscription Management - RevenueCat
We use RevenueCat, Inc., a third-party service provider, to manage in-app subscriptions and purchases. RevenueCat helps Us:
- Process and validate purchases made through the Apple App Store
- Manage subscription status, renewals, and cancellations
- Provide seamless subscription access across Your devices
- Handle subscription-related customer support inquiries
- Prevent subscription fraud and unauthorized access
#### 8.1.1 Data Shared with RevenueCat
When You subscribe to Our premium features, the following information may be shared with RevenueCat:
- Anonymous device identifiers (to link Your subscription to Your device)
- Purchase receipts and transaction data from the App Store
- Subscription status (active, expired, cancelled, in trial period)
- Subscription type and pricing tier
- Subscription start date, renewal date, and expiration date
- App version and platform information
- App usage related to subscription features
#### 8.1.2 RevenueCat's Data Practices
- RevenueCat acts as a Service Provider and processes data on Our behalf
- They do not sell Your Personal Data to third parties
- They do not use Your data for advertising or marketing purposes
- They maintain SOC 2 Type II compliance and industry-standard security measures
- They retain subscription data only as long as necessary to provide services
RevenueCat retains the subscription data shared by us in accordance with the retention periods specified in the "Retention of Your Personal Data" section of this Privacy Policy, and will securely delete or anonymize the data once the retention period expires.
Your subscription is processed through the Apple App Store, and Your payment information is handled directly by Apple. We do not have access to Your credit card or payment details. Apple's privacy practices are governed by their Privacy Policy.
For more information:
- RevenueCat Privacy Policy: https://www.revenuecat.com/privacy
- Apple App Store Privacy: https://www.apple.com/legal/privacy/
- Manage Your Subscriptions: https://support.apple.com/en-us/HT202039
#### 8.1.3 Data Storage and Security
RevenueCat stores subscription data on secure servers located in the United States. They use encryption in transit (TLS 1.2+) and at rest, access controls, and regular security audits to protect Your data.
#### 8.1.4 Your Rights
You have the right to:
- Access Your subscription data by contacting Us
- Request deletion of Your subscription history (subject to legal retention requirements)
- Cancel Your subscription at any time through Your App Store account settings
- Request a copy of the data We have shared with RevenueCat
To exercise these rights or if You have questions about how RevenueCat processes your data, please contact Us at: carolsheng0215@gmail.com
## 9. Children's Privacy
Our Service is not designed for users under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18.
We comply with the Children's Online Privacy Protection Act (COPPA) and other applicable laws regarding the collection of information from children. We do not knowingly collect personal information from children under the age of 13 without verifiable parental consent.
If You are a parent or guardian and You are aware that Your child under 18 has provided Us with Personal Data directly, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from our servers. If you are a parent or guardian, you may request access to the information you have provided about your child, request deletion of such information, or refuse to allow further collection or use of such information, by contacting us at carolsheng0215@gmail.com. We will respond to your request promptly.
## 10. Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
## 11. Changes to this Privacy Policy
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page. If our App has more than 10 million monthly active users, we will publicly solicit opinions for no less than 7 working days before revising this Privacy Policy.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. If the revised Privacy Policy involves changes to the scope of your Personal Data collected, used or disclosed, we will re-obtain your consent.
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.
## 12. Contact Us
If you have any questions, requests, or complaints regarding this Privacy Policy or the processing of your Personal Data, you can contact us via the following method:
By email: carolsheng0215@gmail.com (we will respond to all inquiries within 7 business days)