SUBBD PRIVACY POLICY

INTRODUCTION

• This privacy policy sets out how we use and protect your personal data when you use the Website including any data you may provide when you register sign up or otherwise participate or contribute on the Website.
• This Website is not intended for children and we do not knowingly collect data related to children.
• The Website is not intended for users based in Afghanistan, Armenia, Bahrain, Bangladesh, Belarus, Botswana, Brunei, Cambodia, China, Equatorial Guinea, Eritrea, Indonesia, Iran, Kuwait, Laos, Malaysia, Maldives, Nepal, North Korea, Oman, Pakistan, Qatar, Saudi Arabia, South Korea, Syria, Tanzania, Thailand, Turkey, Turkmenistan, Uganda, United Arab Emirates, Uzbekistan, Vietnam, and Yemen.

DEFINITIONS AND INTERPRETATIONS

• The “Website” is www.subbd.com
• The “Company” or "We" or "Us"- Ionix Labs International Limited
• The terms “Controller,” “Data Subject,” “Personal Data,” “Processing,” and “Processor”as used in these Controller Terms have the meanings given by either (a) Applicable Data Protection Legislation; or (b) absent any such meaning or law, the GDPR.
• “Applicable Data Protection Legislation” means, as applicable to the processing of Controller Personal Data, any national, federal, EU, state, provincial, or other privacy, data security, or data protection law or regulation, including European Data Protection Legislation, the LGPD, U.S. State Data Protection Laws, and Japan Privacy Laws.
• “EU GDPR” means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
• “GDPR” means, as applicable: (a) the EU GDPR; and/or (b) the UK GDPR.
• “UK GDPR” means the EU GDPR as amended and incorporated into UK law under the UK European Union (Withdrawal) Act 2018, and applicable secondary legislation made under that Act.
• “Swiss FDPA” means, as applicable, the Federal Data Protection Act of 19 June 1992 (Switzerland) (with the Ordinance to the Federal Data Protection Act of 14 June 1993) or the revised Federal Data Protection Act of 25 September 2020 (with the Ordinance to the Federal Data Protection Act of 31 August 2022).
• "Japan Privacy Law" means Japan's Act on the Protection of Personal Information (Act No. 57 of 2003).

CONTROLLER

• Unless otherwise indicated, the Company is the controller and responsible for your personal data. The company will comply with the obligations applicable to it under the Applicable Data Protection Legislation regarding the processing of Personal Data.
• You can contact our Data Protection Officer via email atprivacy@subbd.com.

THE TYPE OF PERSONAL DATA WE COLLECT ABOUT YOU

• Personal data means any information about an individual from which that person can be directly or indirectly identified.
• We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, date of birth, and gender.
• Contact Data includes billing address, delivery address, email address, and telephone numbers.
• Financial Data includes bank account, cryptocurrency wallet address, and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you interact with and use our website, products, and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

• We also collect, use, and share aggregated data, such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyze general trends in how users are interacting with our website to help improve the website and our service offering.

HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you, including through:
• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• apply for our products or services;

  create an account on our website;

  subscribe to our service or publications;

  request marketing to be sent to you;

  enter a competition, promotion, or survey; or

  give us feedback or contact us.

• Automated technologies or interactions.As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties or publicly available sources.We may receive personal data about you from various third parties and public sources as set out below:

• Analytics providers such as Google based outside the UK;

  Advertising networks inside or outside the UK;

  Search information providers based inside or outside the UK;

  Contact, Financial and Transaction Data is collected from providers of technical, payment, and delivery services inside or outside the UK;

  Identity and Contact Data collected from data brokers or aggregators; and

  Identity and Contact Data collected from publicly available sources such as Companies House and the Electoral Register based inside the UK.

HOW WE USE YOUR PERSONAL DATA

• Legal basis
The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example, to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

• We have set out below in a table format a description of all the ways we plan to use the various categories of your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Direct Marketing

• During the registration process on our website when your personal data is collected, you may be asked to indicate your preferences for receiving direct marketing communications from us.
• We may also analyze your Identity, Contact, Technical, Usage, and Profile Data to form a view of which products, services, and offers may be of interest to you so that we can then send you relevant marketing communications.

Opting out of Marketing

• You can ask to stop sending you marketing communications at any time by following the opt-out links within any marketing communication sent to you.
• If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes, for example, relating to order confirmations, updates to our Terms and Conditions, checking that your contact details are correct, and other related circumstances.

Cookies

• We use cookies to enhance your browsing experience by:
• Enhancing and personalizing your browsing experience.
• Analyzing how our website is used, helping us to address any problems, and improve our services.
• Remembering your preferences for future visits.
• Providing more relevant content and advertisements to you.
For more information about the cookies we use and how to change your cookie preferences, please seehttps://www.subbd.com/cookies.

INTERNATIONAL TRANSFERS

• Whenever we transfer your personal data out of the UK or EU to countries which have laws that do not provide the same level of data protection as UK or EU law, we always ensure that a similar degree of protection is afforded to it.
For Data Transfer to the United States, we rely on the EU-US and Data Privacy framework, which includes:
• EU Commission Adequacy decision
• UK ICO Adequacy Decision
• Swiss Adequacy Decision
• We may use specific standard contractual terms approved for use in the UK, which give the transferred personal data the same protection as it has in the UK, such as the International Data Transfer Agreement, the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at the contact details provided above.

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.

DATA RETENTION

• We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
• 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, regulatory, tax, accounting, or other requirements.
• By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.
• In some circumstances, you can ask us to delete your data: see below for further information.
• In some circumstances, we will 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.

YOUR LEGAL RIGHTS

• You have a number of rights under data protection laws in relation to your personal data.
• You have the right to:
• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful, but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
  • You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.
• If you wish to exercise any of the rights set out above, please contact us at the contact details provided above.

No fee usually required

• 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.

What we may need from you

• 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. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to Respond

• 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.

COMPLAINTS

• If you have any concerns about how we handle your personal data, please contact us atprivacy@subbd.com, and we will do our best to resolve your issue promptly. You also have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issueswww.ico.org.uk . However, we encourage you to reach out to us directly so we can address your concerns before you approach the ICO.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

• We keep our privacy policy under regular review. We reserve the right to modify this privacy policy at any time. We encourage users to frequently check this section for any changes. Your continued use of the WEBSITE after the posting of changes to this document will be deemed your acceptance of those changes.
• It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example, a new address or email address.

THIRD PARTY LINKS

• This website 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 website, we encourage you to read the privacy policy of every website you visit.