Last Updated: Sept 17, 2026
SubtleZen Inc. (“SubtleZen”, “Company”, “we”, “our”, or “us”) respects your privacy and is committed to protecting personal information.
This Privacy Policy explains how we collect, use, disclose, store, transfer, and protect personal information when you access or use our websites, applications, products, services, and related offerings (collectively, the “Service”).
This Privacy Policy applies to:
By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.
SubtleZen Inc. is a corporation organized under the laws of Alberta, Canada.
For privacy-related questions, requests, or concerns, contact:
Email: support@subtlezen.com
This Privacy Policy applies to:
This Privacy Policy does not apply to third-party websites, products, services, or applications that are not owned or controlled by SubtleZen.
We collect information directly from users, from organizations using the Service, through integrated third-party services, and automatically through operation of the Service.
We may collect:
We may collect:
Customers may provide information relating to contractors, consultants, vendors, employees, and other workforce participants, including:
Customers are responsible for ensuring they have appropriate rights and permissions to provide such information to us.
We may collect:
When customers connect third-party services, we may collect information available through those integrations, including:
The Service is not designed to collect or store customer source code as part of its normal operation. However, source code, code snippets, or technical content may be incidentally included in information imported from integrated services or submitted by users.
We may collect:
Payment card information is processed directly by our payment processor and is not stored within our systems.
We may automatically collect:
We use cookies and similar technologies to:
We collect information:
We may use information to:
We may use artificial intelligence, machine learning, statistical models, and other analytical technologies to provide insights, recommendations, summaries, forecasts, reporting, trend analysis, and performance-related analytics.
When we use third-party AI service providers to process Customer Data for AI-enabled features, we use provider terms, settings, or contractual commitments that do not permit those providers to use Customer Data to train or improve their own models. Customer Data may be processed by such providers only as necessary to provide and secure the applicable AI-enabled functionality or comply with applicable law.
This restriction does not apply to information that has been aggregated, anonymized, or de-identified so that it no longer reasonably identifies a Customer, Organization, or individual, where such use is permitted by applicable law.
Such tools are intended to assist customers in evaluating operational, project, and workforce information.
AI-generated insights, recommendations, or analytics may contain inaccuracies and should not be relied upon as the sole basis for employment, contracting, compensation, disciplinary, legal, or other significant decisions.
SubtleZen does not make employment, contracting, compensation, disciplinary, promotion, termination, or other legally significant decisions on behalf of customers.
Customers remain solely responsible for decisions relating to workforce management, contractor relationships, employment matters, and business operations.
Where applicable under GDPR, UK GDPR, and similar laws, we process personal information based on one or more of the following legal bases:
Our legitimate interests may include:
Where SubtleZen acts as a data processor, the customer organization is generally responsible for determining the applicable legal basis for processing Customer Data.
Depending on the circumstances, SubtleZen may act as either a data controller or a data processor.
When organizations upload workforce, contractor, project, financial, or operational data to the Service, the customer organization generally acts as the data controller and SubtleZen acts as a data processor.
When we process information relating to website visitors, prospective customers, account holders, and business contacts, we generally act as a data controller.
Customers are responsible for ensuring that they have the necessary rights, permissions, notices, consents, and legal bases required to collect, use, and disclose information submitted to the Service.
Customers are solely responsible for determining the purposes and means of processing information they upload to the Service and for complying with applicable privacy, employment, labor, and data protection laws.
SubtleZen does not independently verify the accuracy or legality of information submitted by customers.
We do not sell personal information and do not share personal information for cross-context behavioral advertising as those terms are defined under applicable privacy laws.
We may disclose information:
We may use third-party service providers and subprocessors to support operation of the Service, including providers supporting:
Current or anticipated providers may include:
Our service providers and subprocessors may change from time to time as our business and technical infrastructure evolve.
Customers may contact us regarding material questions relating to subprocessors and data processing practices.
We may process and store information in countries other than the country where the information was originally collected.
Information may be processed and stored in the United States and other jurisdictions where our service providers operate.
Where required by applicable law, we implement appropriate safeguards for international transfers of personal information, which may include contractual protections, adequacy decisions, or other legally recognized transfer mechanisms.
We retain information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce agreements.
Customer Data remains under the control of the customer organization.
If a subscription is cancelled or expires, access to certain features of the Service may be suspended or limited. Unless otherwise required by law, Customer Data will generally remain stored within the Service until it is deleted by the customer or removed in accordance with the customer’s instructions.
Customers may delete organizations, projects, records, or other data through available Service functionality. Following a deletion request, information may be retained in active systems for up to 90 days to facilitate recovery, dispute resolution, legal compliance, system integrity, and operational purposes before being permanently deleted or anonymized.
Deletion of a project, organization, or other customer-controlled record may result in the deletion of associated synchronized data stored within the Service.
Deleted information may remain in backups or archival systems until those backups or archives are rotated, overwritten, or deleted in accordance with our backup retention practices.
System backups may be retained for up to 12 months.
Financial, accounting, billing, transaction, and tax records may be retained for up to seven years or longer where required by law.
We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.
Such safeguards may include:
Access to customer data is limited to authorized personnel and service providers who require access to perform their responsibilities.
No method of transmission or storage can be guaranteed to be completely secure.
While no system can guarantee absolute security, we maintain processes designed to detect, investigate, and respond to security incidents.
Where SubtleZen acts as a data controller and applicable law requires notification, we will notify affected individuals, regulators, or other parties within the timeframes required by applicable law.
Where SubtleZen acts as a data processor for Customer Data, we will notify the relevant customer without undue delay after becoming aware of a personal information or personal data breach affecting that Customer Data and will provide reasonable assistance to support the customer’s legal obligations.
For example, where GDPR or UK GDPR applies, controllers may be required to notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours after becoming aware of a personal data breach unless the breach is unlikely to result in risk to individuals. Under Canadian law, organizations may be required to notify affected individuals and the Office of the Privacy Commissioner of Canada as soon as feasible where a breach creates a real risk of significant harm.
Depending on your location and applicable law, you may have rights including:
To exercise privacy rights, contact:
We may request information necessary to verify your identity before responding to a request.
Residents of California may have rights under applicable California privacy laws, including rights to:
SubtleZen does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined under applicable California privacy laws.
To the extent we process information that constitutes sensitive personal information under applicable California privacy laws, we use and disclose such information only as reasonably necessary to provide the Service, maintain security, prevent fraud, comply with legal obligations, or for other purposes permitted by applicable law.
Individuals located in the European Economic Area, Switzerland, and the United Kingdom may have rights under applicable data protection laws.
Where SubtleZen acts as a processor on behalf of a customer organization, requests relating to customer-controlled information should generally be directed to the relevant customer organization.
Individuals in the EEA, UK, or Switzerland may also have the right to lodge a complaint with their local data protection supervisory authority.
If we receive a data subject request relating to information for which a customer organization is the data controller, we will promptly notify the relevant customer and provide reasonable assistance as required by applicable law.
Individuals may have rights under applicable Canadian privacy laws, including rights to access and correct personal information.
Individuals may also challenge our compliance with applicable privacy laws by contacting us using the information provided in this Privacy Policy.
We use cookies and similar technologies for the following purposes:
These cookies are necessary for:
These cookies help us:
We may use third-party providers that place cookies or similar technologies in connection with authentication, payment processing, website performance, analytics, and security.
Where required by applicable law, we will request consent or provide choices for non-essential cookies and similar technologies.
Users can manage cookie preferences through browser settings. Disabling certain cookies may affect functionality of the Service.
We may send:
Users may unsubscribe from marketing communications using available unsubscribe mechanisms.
Service-related communications may continue where necessary to provide the Service.
The Service is intended for business users and is not directed to children under the age of 18.
We do not knowingly collect personal information from children under 18.
If we become aware that personal information from a child has been collected, we will take reasonable steps to delete it.
For customers subject to GDPR, UK GDPR, or similar data protection laws, SubtleZen may make available a Data Processing Addendum (“DPA”) governing the processing of customer data.
Customers who require a DPA or have questions regarding data processing requirements may contact us at:
We may update this Privacy Policy from time to time.
If material changes are made, we may provide notice through the Service, by email, or by other reasonable means.
The updated version becomes effective upon posting unless otherwise stated.
If you have questions regarding this Privacy Policy or our privacy practices, contact:
SubtleZen Inc.
Alberta, Canada
Email: support@subtlezen.com