Privacy Policy

Effective Date: August 31, 2021.  

1. Introduction and Overview.

This Privacy Policy provides a comprehensive description of how Subset, Inc. (“Subset,” “we,” “our,” or “us”) collects, uses, and shares information about you as well as your rights and choices regarding such information with respect to the Subset subscription management app (“Subset”). It applies to the Subset app, related website, as well as any online location that links to this Privacy Policy (the “Service”).

By using the Service, you agree to our Terms of Use and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree, discontinue use of the Service.  Furthermore, our Service relates to third party subscription services (“Subscription Services”) which we do not control. Your use of those Subscription Services is subject to the privacy policy of the third party Subscription Service.

If you have any questions or wish to exercise your rights and choices, please contact us as set out in the “Contact Us” section. If you are a Nevada or California resident, please see the additional disclosures at the end of this Privacy Policy.

2. Information Collection.

A. Information You Provide.

We collect information about you when you use the Service, including information you provide when you register an account, update your profile, access our content, make a purchase, participate in a promotion, or contact customer support. The categories of information we collect include:

  • Contact Data, including your first and last name, email address, and phone number.
  • Account Credentials, including your username, password, password hints, and information for authentication and account access.
  • Demographic Data, including your age, gender, and country.
  • Profile Data, including your interests, inferences, preferences and favorites.
  • Content, including content within any messages you send to us (such as feedback and questions to customer support) or publicly post on the Service (such as in product reviews or comments).
  • Subscription Service Credentials, including the username and password for the relevant Subscription Service account that you are managing or accessing. By submitting or accessing Subscription Service Credentials, you acknowledge and agree that you are solely responsible for all rights and legality associated with such Subscription Service Credentials, and complying with all applicable terms of the applicable Subscription Service.
  • Personal Contacts Data, including the first and last name and phone number of your personal contacts. In order to invite your friends or family to join you in managing a Subscription Service, you must provide their Personal Contact Data. You will then be able to text them through your device and send a URL which will invite them to our Service. By using this functionality, you acknowledge and agree that both you and your contacts are based in the U.S. and that you have your contacts’ consent to use their Personal Contact Data to fulfill your request.    

You may choose to voluntarily provide other information to us that we do not request, and, in such instances, you are solely responsible for such information.  


B. Information Provided Through Third Party Integrations

We use Plaid and other third party integrations to allow you to split payments for Subscription Services through our Service. To activate this functionality, you must affirmatively authorize the third party integration to connect to your third party bank account. When you activate this functionality, you give Subset and the third party integration the authority to act on your behalf to access and transmit your information from the relevant third party bank or other entity that provides your account. The information received from the third party bank account varies depending on the information made available by that account. You may terminate this connection at any time through your Subset account settings, although any information previously collected will not be deleted unless requested in accordance with this Privacy Policy.

Please note that Subset is not responsible for any third party’s privacy practices, including those of any third party integrations or third party bank accounts, and we strongly encourage you to review their privacy policies before activating the functionality. Plaid’s privacy policy is available at https://plaid.com/legal. Dwolla’s privacy policy is available at https://www.dwolla.com/legal/dwolla-account-terms-of-service/#legal-content.  You are responsible for the accuracy and completeness of the data provided through any third parties you connect to the Service.


C. Information Collected Automatically.

In addition, we automatically collect information when you use the Service. The categories of information we automatically collect include:

  • Service Use Data, including data about features you use, pages you visit, emails and advertisements you view, products and services you view and purchase, the time of day you browse, and your referring and exiting pages.
  • Device Data, including data about the type of device or browser you use, your device’s operating software, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address and Ad Id.
  • Location Data, including imprecise location data (such as location derived from an IP address or data that indicates a city or postal code level).


The types of tracking technologies we use to automatically collect information include:

  • Log Files, which are files that record events that occur in connection with your use of the Service.
  • Device Fingerprinting, which is the process of analyzing and combining sets of data elements from your device’s browser, such as JavaScript objects and installed fonts, to create a “fingerprint” of your device and uniquely identify your browser and device.
  • App Technologies, which are technologies included in our apps that are not browser-based like cookies and cannot be controlled by browser settings. For example, our apps may include SDKs, which is code that sends information about your use to a server, for instance through the Facebook SDK. These SDKs allow us to track our conversions, bring you advertising both on and off the Service, and provide you with additional functionality, such as the ability to connect our Service with your Subscription Service or social media account.  
  • Location-Identifying Technologies, which are technologies used to collect your location. For example, GPS, WiFi, and Bluetooth may be used to collect precise location data when you consent to precise location tracking through our apps. Location data may be used for purposes such as verifying your device’s location and delivering or restricting relevant content and advertising based on that location.

For further information on how we use tracking technologies for analytics and advertising, and your rights and choices regarding them, see the “Analytics and Advertising” and “Your Rights and Choices” sections below.


D. Information from Other Sources.

We also collect information from other sources. The categories of sources from which we collect information include:

  • Data brokers from which we purchase data to supplement the data we collect.
  • Social networks with which you interact.
  • Partners that offer co-branded services, sell or distribute our products, or engage in joint marketing activities.
  • Publicly-available sources, including data in the public domain.

3. Use of Information.

We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information and for which we have collected and used information include:

  • Operating, providing, and managing our Service.
  • Performing services requested by you, such as responding to your comments, questions, and requests, and providing customer service.
  • Sending you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages.
  • Preventing and addressing fraud, breach of policies or terms, and threats or harm.
  • Monitoring and analysing trends, usage, and activities.
  • Conducting research, including focus groups and surveys.
  • Improving the Service and other Subset websites, apps, marketing efforts, products and services.
  • Developing and sending advertising, direct marketing, and communications about our and other entities’ products, offers, promotions, rewards, events, and services.
  • Conducting promotions, including verifying your eligibility and delivering prizes in connection with your entries.
  • Fulfilling any other purpose at your direction.
  • With notice to you and your consent.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.

4. Sharing of Information.

We share information we collect in accordance with the practices described in this Privacy Policy. The categories of parties with whom we share information, and have shared information, include:

  • Service Providers. We share information with service providers that process information on our behalf. Service providers assist us with services such as facilitation of payments, data analytics, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.
  • Vendors and Other Parties. We share information with vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics and Advertising” section below.
  • Affiliates. We share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.
  • Partners. We share information with our partners in connection with offering co-branded services, selling or distributing our products, or engaging in joint marketing activities.
  • Third Party Integrations. We share information with third party integrations (such as Plaid and other third party providers) in connection with you using them through our Service. You may terminate this connection at any time through your Subset account settings, although any information previously collected will not be deleted unless requested in accordance with this Privacy Policy.
  • Other Users. We share certain information about your use of our Service with those Users with whom you share a Subscription Service (i.e., your friends and family).  Other Users may be able to view your Service profile information, contact information, and information relating to the shared Subscription Services, such as subscription cost-splitting amounts.
  • Promotions. Our promotions may be jointly sponsored or offered by other parties. When you voluntarily enter a promotion, we share information as set out in the official rules that govern the promotion as well as for administrative purposes and as required by law (e.g., on a winners list). By entering a promotion, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other entities to use your name, voice and/or likeness in advertising or marketing materials.
  • Public Forums. We share information you make public through the Service, such as information in your profile or that you post on public boards. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the “Your Rights and Choices” section below.
  • Merger or Acquisition. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business.
  • Security and Compelled Disclosure. We share information to comply with the law or other legal process, and where required, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also share information to protect the rights, property, life, health, security and safety of us, the Service or anyone else.
  • Facilitating Requests. We share information at your request or direction.
  • Consent. We share information with notice to you and your consent.

Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.

5. Other Parties.

We offer parts of our Service through websites, platforms, and services operated or controlled by other parties that you  may manage using our Services. In addition, we integrate technologies operated or controlled by other parties into parts of our Service.

Please note that when you interact with other parties, including when you leave our Service, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

6. Analytics and Advertising.

We use analytics services, such as Google Analytics, to help us understand how users access and use the Service. In addition, we work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own Service (including our website and emails) as well as into our ads displayed on other websites and services. Some of these tracking technologies may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you (“Interest-based Advertising”).

We also use audience matching services (which is a type of Interest-based Advertising) to reach people (or people similar to people) who have visited our Service or are identified in one or more of our databases (“Matched Ads”). This is done by us providing a list of hashed email addresses to an ad partner or incorporating a pixel from an ad partner into our own Service, and the ad partner matching common factors between our data and their data.

As indicated above, vendors and other parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

For further information on the types of tracking technologies we use on the Service and your rights and choices regarding analytics, Interest-based Advertising, and Matched Ads, please see the “Information Collected Automatically” and “Your Rights and Choices” sections.

7. Your Rights and Choices.

A. Account Information.

You may access, update, or remove certain information that you have provided to us through your account by visiting your account settings. Please note that we will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you are a California resident, please see the additional disclosures at the end of this Privacy Policy.


B. Tracking Technology Choices.
  • Do Not Track. Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals.  For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
  • App and Location Technologies. You can stop all collection of information via an app by uninstalling the app. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you. You can stop all collection of precise location data through an app by uninstalling the app or withdrawing your consent through your device settings.

Please be aware that if you disable or remove tracking technologies some parts of the Service may not function correctly.


C. Analytics and Interest-Based Advertising.

Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/.  

The companies we work with to provide you with targeted ads are required by us to give you the choice to opt out of receiving targeted ads. Most of these companies are participants of the Digital Advertising Alliance (“DAA”) and/or the Network Advertising Initiative (“NAI”). To learn more about the targeted ads provided by these companies, and how to opt out of receiving certain targeted ads from them, please visit: (i) for website targeted ads from DAA participants, https://www.aboutads.info/choices; (ii) for app targeted ads from DAA participants, https://www.aboutads.info/appchoices; and (iii) for targeted ads from NAI participants, https://www.networkadvertising.org/choices/. Opting out only means that the selected participants should no longer deliver certain targeted ads to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., in connection with the participants’ other customers or from other technology services).

To opt out of us sharing your data with a third party as part of a customer list for Matched Ads, please contact us as set forth in the “Contact Us” section below and specify that you wish to opt out of Matched Ads. We will remove your data from any subsequent lists shared with third parties for Matched Ads.  Alternatively, you may directly contact the applicable party to opt out.

You may also limit our use of information collected from or about your mobile device for purposes of serving targeted ads to you by going to your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices).

Please note that if you opt out using any of these methods, the opt out will only apply to the specific browser or device from which you opt out. We are not responsible for the effectiveness of, or compliance with, any opt out options or programs, or the accuracy of any other entities’ statements regarding their opt out options or programs.


D. Communications.
  • E-mails. You can opt-out of receiving promotional emails from us at any time by following the instructions as provided in emails to click on the unsubscribe link, or emailing us at the email address set out in the “Contact Us” section below with the word UNSUBSCRIBE in the subject field of the email. Please note that you cannot opt-out of non-promotional emails, such as those about your account, transactions, servicing, or our ongoing business relations.
  • Push Notifications. If you have opted-in to receive push notification on your device, you can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

Please note that your opt out is limited to the email address, device, and phone number used and will not affect subsequent subscriptions.  

8. Children.

The Service is intended for general audiences, and is not directed at children under 13 years old. We do not knowingly collect personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, contact us at subset@coil.com. We will remove the personal information in accordance with COPPA. We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

9. Data Security.

We implement and maintain reasonable and appropriate administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.  

10. International Transfer.

We are based in the U.S. and the information we collect is governed by U.S. law.  If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy.  

11. Changes to this Privacy Policy.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice to your email address.  

12. Contact Us.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us:

By email: subset@coil.com

This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us at subset@coil.com.

13. Additional Disclosures for Nevada Residents.

Nevada law (NRS 603A.340) requires each business to establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. A sale under Nevada law is the exchange of personal information for monetary consideration by the business to a third party for the third party to license or sell the personal information to other third parties. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at subset@coil.com.

14. Additional Disclosures for California Residents.

These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt-out, and requires businesses collecting or disclosing personal information to provide notices and means to exercise rights.  


A. Notice of Collection.

In the past 12 months, we have collected the following categories of personal information, as described in the CCPA:

  • Identifiers, including name, email address, and online identifiers (such as IP address).  
  • Customer records, including phone number, personal contacts data, and information relating to your Subscription Service accounts.
  • Characteristics of protected classifications under California or federal law, including gender.  
  • Commercial or transactions information, including records of products or services purchased, obtained, or considered.
  • Internet activity, including your browsing history on the Service, your search history on the Service, and your interactions with a Subscription Service, website, email, or advertisement.
  • Geolocation data. Data inferred from an IP address.
  • Inferences drawn from the above information about your predicted characteristics and preferences.

For further details on information we collect, including the sources from which we receive information, review the “Information Collection” section above. We collect and use these categories of personal information for the business purposes described in the “Use of Information” section above, including to manage our Service.

Under the CCPA, “sell” is defined broadly, and some of our data sharing practices may be considered a “sale.”

To the extent “sale” under the CCPA is interpreted to include the activities set out in this Privacy Policy, such as those disclosed in the “Analytics and Advertising” section above, we will comply with applicable law as to such activity. We disclose the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. Please review the “Sharing of Information” section above for further details about the categories of parties with whom we share information.


B. Right to Know and Delete.

You have the right to know certain details about our data practices in the past 12 months. In particular, you may request the following from us:

  • The categories of personal information we have collected about you;  
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

In addition, you have the right to delete the personal information we have collected from you.

To exercise any of these rights, please submit a request through our Online Form or  by emailing us at subset@coil.comIn the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.


C. Right to Opt-Out.

To the extent Company sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information or emailing us at subset@coil.com

D. Authorized Agent.

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and verify your identity directly.


E. Right to Non-Discrimination.

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.


F. Shine the Light.

Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please write us at the email or postal address set out in “Contact Us” above and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.