Subly Media Inc. ("Subly," "Subly®," "we," "our," or "us") operates a digital content access platform that lets readers unlock individual articles or purchase time-limited access passes from participating news publishers and magazines ("Media Partners") — without requiring a separate subscription to each publisher. This Privacy Statement explains what personal information we collect, how we use and share it, and the choices available to you.
This Statement applies to the Subly® website, the Subly® app, and the Subly® payment and access widget that appears on Media Partner websites when you unlock or purchase access to content. It is intended for residents of the United States. Our services are currently available to US residents only.
If we make material changes to this Statement we will post the revised version here with a new "Last Updated" date. Continued use of our services after changes take effect constitutes acceptance of the updated Statement.
Subly's platform connects three parties: you (the reader), Media Partners (the publishers whose content you access), and Subly (the technology and payment layer in between).
When you unlock an article or purchase an access pass, your primary relationship for that content is with the Media Partner. The Media Partner controls the content you are accessing and sets its price. Subly processes the token transaction, records the unlock event, and pays out the Media Partner's share of the revenue.
Subly acts as the controller of your account data and transaction data for the purposes described in this Statement. Media Partners receive limited information about unlock activity related to their own content, as described in the "How We Share Your Information" section below. Subly does not sell your personal information to Media Partners or to third parties for advertising purposes.
Personal Information is information that identifies you or can reasonably be linked to you. The specific information we collect depends on how you interact with our services.
When you create a Subly account we collect your name, email address, and, where applicable, other contact or identity verification information you provide.
When you load tokens into your Subly wallet or set up auto-reload, we collect payment card information. Card processing is handled by our payment processor; Subly retains only the information necessary to identify the payment method (such as the last four digits and card type) and to process refunds or disputes.
Each time you unlock an article or use an access pass, we record a transaction that includes your user account identifier, a timestamp, an identifier for the content you accessed, the name of the Media Partner, the number of tokens used, and the token value at the time of the transaction. These records form part of our financial ledger and are retained as described in the "Data Retention" section below.
When you initiate a content unlock or token purchase, we collect your location. We derive location from your device's IP address. We use this location information to determine the applicable tax jurisdiction for your transaction — this is a legal obligation under applicable state sales tax laws for digital goods — and to comply with our obligation to make the service available to US residents only.
We retain your location coordinates as part of your transaction record. We may also use retained location data for service analytics and improvements. See the "Data Retention" section for how long transaction records are kept.
You may provide additional information when you contact our support team, respond to surveys, or otherwise communicate with us. We retain this information to respond to your inquiry and to improve our services.
When you visit the Subly website or app, or when the Subly access widget loads on a Media Partner's website, we automatically collect certain technical information about your device and browser session. This includes IP address, browser type and version, operating system, referring URL, pages or content viewed, and the date and time of your activity. This information is used to operate and improve our services and to detect and prevent fraud.
We use the personal information we collect for the following purposes:
We use your account, payment, and transaction information to create and maintain your account, process token purchases and content unlocks, display your wallet balance and transaction history, and deliver the features of our service.
We collect location information at the time of each transaction as required by law to determine whether sales tax applies to that transaction and, if so, which jurisdiction's rate applies. We pass the resolved jurisdiction code to our tax compliance service provider (see "How We Share Your Information" below). We are required to retain financial transaction records, including the tax jurisdiction associated with each transaction, for as long as required by applicable federal and state audit and recordkeeping obligations.
We use transaction data, device information, and IP address to detect and prevent fraudulent activity, unauthorized access, and abuse of our services.
We use aggregated and de-identified data about how our services are used to understand performance, fix problems, and develop new features. We do not use your individual transaction history for personalized advertising.
We use your email address to send you transactional communications (such as purchase confirmations and low-balance notices) and, where you have opted in, promotional communications about Subly. You may opt out of promotional email at any time using the unsubscribe link in the message.
We use your information as necessary to comply with applicable law, respond to legal process, enforce our Terms of Use, and protect the rights, property, and safety of Subly, our users, and Media Partners.
We do not sell your personal information. We share information only as described below.
When you unlock content from a Media Partner, we share with that Media Partner the fact that an unlock occurred, the content item accessed, and the transaction timestamp. We do not share your name, email address, or payment information with Media Partners without your consent. Media Partners may use unlock data to calculate their revenue share and for their own analytics regarding content performance.
We use a third-party payment processor to handle payment card transactions. Your card data is transmitted directly to the payment processor under their privacy policy and security standards. We share only the information necessary to initiate, confirm, or dispute a payment.
We use a third-party tax jurisdiction lookup service to determine the applicable sales tax for each transaction. To perform this lookup we transmit the location coordinates collected at the time of your transaction. We do not share your name or account identity with this vendor in connection with individual transactions.
We work with trusted third-party vendors who provide services such as cloud hosting, data analytics, fraud detection, email delivery, and customer support tooling. These vendors process your information only on our behalf and under contractual obligations consistent with this Statement.
We may disclose your information if required by law, court order, or other legal process, or if we believe in good faith that disclosure is necessary to protect the rights, property, or safety of Subly, our users, or others.
If Subly is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your information.
We retain personal information for as long as necessary to provide our services and fulfill the purposes described in this Statement, subject to the following specific retention rules:
Records of token purchases, content unlocks, and payouts — including the tax jurisdiction and location coordinates associated with each transaction — are retained for as long as required by applicable federal and state financial recordkeeping and audit obligations.
Location coordinates collected at the time of each transaction are retained as part of the transaction record for the same seven-year period described above.
We retain your account information for as long as your account is active. If you close your account, we will delete or de-identify your account profile within a reasonable time, subject to our obligation to retain financial transaction records as described above.
Records of support interactions are retained for [retention period — to be confirmed] to allow us to follow up on open issues and to improve service quality.
We use cookies and similar technologies on the Subly website and app, and the Subly access widget that appears on Media Partner websites uses similar technologies to operate the unlock flow. The following describes the categories of cookies we use.
These cookies are required for our services to function. They enable actions such as logging in, managing your session, and completing a token purchase or content unlock. The Subly access widget on Media Partner sites uses session cookies to authenticate your wallet and complete the transaction. These cookies cannot be disabled without preventing the service from working.
These cookies remember your preferences and settings (such as your language preference) to improve your experience. They may be set by Subly or by third-party providers operating on our behalf.
These cookies help us understand how our services are used — for example, which pages are visited most often and where errors occur. The data is used in aggregate to improve performance and reliability.
We may use cookies to measure the performance of our own marketing campaigns. We do not use your transaction history or content-reading behavior for third-party behavioral advertising.
To manage or disable cookies, adjust the settings in your browser. Disabling certain cookies will prevent some features of our service from working, including the ability to complete a content unlock.
Some browsers transmit opt-out preference signals such as "Do Not Track" or "Global Privacy Control." We honor Global Privacy Control signals from California-based IP addresses in accordance with the California Consumer Privacy Act. We do not respond to Do Not Track signals at this time.
Our services are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we may have collected information from a child under 13, please contact us using the information below and we will promptly delete it.
For more information on children's online privacy, please visit the Federal Trade Commission's guidance on the Children's Online Privacy Protection Act (COPPA).
You have the following choices regarding your personal information:
You may access and update your account information at any time by logging into your Subly account. If you believe any information we hold about you is inaccurate, please contact us.
You may opt out of promotional email at any time using the unsubscribe link in the message or by contacting us. Opting out of promotional email does not affect transactional communications such as purchase confirmations.
You may close your account by contacting us. Closing your account does not affect the retention of financial transaction records as described in the "Data Retention" section.
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information, including the right to know what information we have collected about you, the right to request deletion, and the right to opt out of the sale of your personal information. We do not sell personal information. To exercise your rights under the CCPA, please contact us using the information below.
If you have questions, concerns, or requests regarding this Privacy Statement or the personal information we hold about you, please contact us at:
Subly Media Inc.
privacy@subly.ink
We will respond to your request within the time required by applicable law.