Privacy Policy

Your privacy is important to us

Last Updated: November 16, 2025

At Subtle, we are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application and services.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the application.

1 Information We Collect

We collect information that you provide directly to us when using our application:

  • Personal Information: Name, email address, phone number, and profile information
  • Account Information: Username, password, and account preferences
  • Booking Information: Property details, reservation dates, payment information, and transaction history
  • Communication Data: Messages, reviews, and customer support inquiries
  • Device Information: Device type, operating system, unique device identifiers, and mobile network information
  • Location Data: Approximate location based on IP address or precise location if you grant permission
  • Usage Information: App usage statistics, pages viewed, and interaction data

2 How We Use Your Information

We use the information we collect for the following purposes:

  • To provide, maintain, and improve our services
  • To process your bookings and transactions
  • To communicate with you about your account and reservations
  • To send you updates, promotional materials, and service announcements
  • To personalize your experience and provide customized content
  • To detect, prevent, and address technical issues and fraud
  • To comply with legal obligations and enforce our terms of service
  • To analyze usage patterns and improve our app functionality

3 Information Sharing and Disclosure

We may share your information in the following circumstances:

  • Service Providers: We share information with third-party vendors who perform services on our behalf, such as payment processing, data analysis, and customer service
  • Property Hosts: We share necessary booking information with property owners to facilitate your reservation
  • Legal Requirements: We may disclose information if required by law or to protect our rights and safety
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred
  • With Your Consent: We may share information with your explicit permission

Important: We do not sell your personal information to third parties for their marketing purposes.

4 Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Regular security assessments and updates
  • Restricted access to personal information on a need-to-know basis
  • Secure payment processing through certified payment gateways

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

5 Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will securely delete or anonymize it.

Account information is retained for the duration of your active account and for a reasonable period afterward to comply with legal obligations and resolve disputes.

6 Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

  • Access: Request access to the personal information we hold about you
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal information
  • Portability: Request a copy of your data in a structured, machine-readable format
  • Objection: Object to the processing of your personal information
  • Withdraw Consent: Withdraw consent where we rely on consent to process your information
  • Opt-out: Unsubscribe from marketing communications at any time

To exercise these rights, please contact us using the information provided in the Contact Us section.

7 Children's Privacy

Our application is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without parental consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

8 Third-Party Services

Our application may contain links to third-party websites, services, or integrations. We are not responsible for the privacy practices of these third parties. We encourage you to read the privacy policies of any third-party services you access through our app.

Third-party services we may integrate include:

  • Payment processors (for secure payment transactions)
  • Analytics services (to understand app usage)
  • Social media platforms (for social sharing features)
  • Map services (for location-based features)

9 International Data Transfers

Your information may be transferred to, stored, and processed in countries other than your country of residence. These countries may have data protection laws that differ from those of your country.

We take appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Policy when transferred internationally.

10 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about your browsing activities. These technologies help us:

  • Remember your preferences and settings
  • Understand how you use our application
  • Improve our services and user experience
  • Provide personalized content and recommendations

You can control cookie preferences through your device settings, but disabling certain cookies may limit your ability to use some features of our application.

11 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

  • Posting the updated policy on our application
  • Updating the "Last Updated" date at the top of this policy
  • Sending you a notification through the app or email

Your continued use of our application after any changes indicates your acceptance of the updated Privacy Policy.

12 Account Deletion

Account Deletion

You can delete your Subtle account directly from within the app. To delete your account:

  • Open the Subtle app
  • Go to: Profile → Settings → Delete Account
  • Tap "Delete Account" and follow the confirmation steps (password or OTP).
  • After confirming, a summary will show which data will be deleted and which will be retained.

What Will Be Deleted

  • Profile information: name, avatar, bio (except where legal requirements prevent removal).
  • Chat history associated with your account, subject to retention rules.
  • Property listings and media you uploaded (hosts), or listings will be unpublished/removed as applicable.
  • Non-sensitive operational data linked to your account (some booking details may be deleted or canceled).

What Will Be Retained and Why

  • Payment and transaction records for accounting and legal compliance (retained per local law — e.g., up to 7 years).
  • Information required to investigate fraud, resolve disputes, or comply with legal obligations.

Timeframe

We aim to process deletion requests within 7 business days. Backups and caches may be purged within an additional 30–90 days.

Security & Verification

We verify requests are made by the account owner (authenticated session + password/OTP). You will receive an email confirmation when the request is received and after it is completed.

Need Help?

If you cannot access the Delete Account button or need assistance, contact us at: support@subtle.com.

12 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Subtle

Email: privacy@subtle.com

Email: support@subtle.com

We will respond to your inquiry within a reasonable timeframe.

13 Legal Compliance

This Privacy Policy is designed to comply with applicable data protection laws and regulations, including:

  • General Data Protection Regulation (GDPR) for users in the European Union
  • California Consumer Privacy Act (CCPA) for users in California
  • Children's Online Privacy Protection Act (COPPA) for users under 13
  • Other applicable local and international privacy laws

We are committed to maintaining compliance with all applicable privacy regulations and protecting your rights as a user.