Subvio Privacy Policy — Ventora Systems

1Who is responsible for your data

The controller of your data is Ventora Systems SRL, with its registered office at Aleea Călărașilor nr. 5, bl. G, ap. 54, mun. Sibiu, jud. Sibiu, Romania, tax ID (CUI) 54288922, registered with the Trade Register under no. J2026018106000.

For any question about your data, write to us at privacy@ventorasystems.com.

2What data Subvio uses

Your account: your email address and password, stored encrypted. We cannot see it.
The subscriptions you add: name, price, currency, frequency, payment date, notes and status (active, paused, cancelled).
Your preferences: language, theme, main currency and notification settings.
A technical identifier for notifications, so that we can send you reminders.
The status of your Premium subscription (active or not), received from Apple, Google or Stripe, depending on where you paid. We do not receive your card details.

3What Subvio does not do

It does not connect to your bank account and does not read your emails.
It does not sell or rent your data.
It does not show ads and does not track you across other apps or websites.
It does not cancel subscriptions on your behalf.

4Why we use it and on what legal basis

To provide the app (your account, totals, payment calendar): performance of the contract (Article 6(1)(b) GDPR).
To send you reminders before payments: performance of the contract. You can turn them off at any time in Settings.
To manage Subvio Premium, based on the information received from Apple, Google or Stripe: performance of the contract.
To issue invoices for payments made on the website, through SmartBill: legal obligation (point (c)).
To keep the app secure and fix errors: legitimate interest (point (f)).
To send you news about Subvio: only with your consent (point (a)).

5How long we keep it

We keep your data for as long as you have an account. When you delete your account, we delete it from our systems within 30 days at most. Backups are automatically overwritten within 7 days.

Data that the law requires us to keep, such as invoices for payments made on the website, is not deleted together with your account: we keep it for as long as accounting and tax law requires.

6Who we work with

To operate the Subvio services, we work with providers of infrastructure, technology services and payment processing. Depending on the activities carried out, they may act as processors of Ventora Systems SRL or as independent controllers of personal data, in accordance with applicable law and the relevant contractual agreements.

ProviderWhat it doesWhere

SupabaseYour account and in-app dataEU (Ireland)

VercelThe app’s web servicesEU (Germany), with a global delivery network

ResendAccount emails and email remindersEU (Ireland)

ApplePremium payments on iPhone and notification deliveryAccording to Apple’s policy

GooglePremium payments on Android and notification deliveryAccording to Google’s policy

StripePremium payments on the website, by cardAccording to Stripe’s policy

RevenueCatManaging in-app subscriptionsUSA

SmartBillIssuing invoices for payments made on the websiteRomania (EU)

7Payment processing by Stripe

To process certain payments made through our platforms, Ventora Systems SRL uses the services of the provider Stripe.

Depending on the nature and purpose of the processing operations, Stripe may act as a processor, processing personal data on behalf of Ventora Systems SRL, or as an independent controller, when it processes data for its own purposes and legal obligations, including fraud prevention, transaction security and compliance with financial regulations.

The data processed may include name, email address, billing information, transaction identifiers and the data necessary to carry out and verify payments.

The processing of data by Stripe is subject to the contractual documents and privacy policies applicable to this provider.

Further information on Stripe’s data protection practices is available at https://stripe.com/privacy.

8Transfers outside the EU

Certain service providers used by Subvio may process or transfer personal data outside the European Economic Area, including to the United States of America.

In these situations, Ventora Systems SRL uses the legal mechanisms applicable to international data transfers, such as adequacy decisions of the European Commission or standard contractual clauses, as appropriate, together with the necessary supplementary measures.

Further information on international transfers and the applicable safeguards may be requested at privacy@ventorasystems.com.

9Your rights

You can delete your account directly in the app, under Settings → Account → Delete account. For your other rights, write to us at privacy@ventorasystems.com.

You also have the right to lodge a complaint with the Romanian Data Protection Authority (ANSPDCP – Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal), B-dul G-ral Gheorghe Magheru nr. 28–30, sector 1, București, www.dataprotection.ro.

Access to your data and a copy of it.
Rectification of inaccurate or incomplete data.
Erasure of your data (the “right to be forgotten”).
Restriction of processing.
Data portability, in an easy-to-use format.
Objection to processing based on legitimate interest.
Withdrawal of your consent, at any time, without affecting what was done before.

10Children

Subvio is not intended for people under 16.

11Changes and contact

When we change this policy, we update the date above and, if the change is significant, we let you know in the app.

privacy@ventorasystems.com · Ventora Systems SRL, Aleea Călărașilor nr. 5, bl. G, ap. 54, mun. Sibiu, jud. Sibiu, Romania.

Working draft, written to be reviewed by a lawyer before publication. Values in square brackets will be filled in at implementation.