SUBI Privacy Policy

Last Updated: March 30, 2026

Subi Incorporated and its affiliates and subsidiaries (“Subi,” “Marian,” “we,” “us,” or “our”) respect
your privacy. This Privacy Notice (“Notice”) describes the processing of Personal Information (defined
below) that is provided, collected, or disclosed while providing our products or services to you through
the Subi app, (“Services”) and on the websites, other applications, and online platforms that link to this
Notice (collectively, the “Site”). It also describes rights you may have under applicable laws. Please read
this Notice carefully to understand our policies and practices regarding your Personal Information and
how we will treat it.

Personal Information We Collect

We collect several categories of Personal Information from and about users of the Site. “Personal
Information” means information that uniquely identifies, relates to, describes, or is reasonably capable of
being associated with or linked to you. The categories of Personal Information we collect may include:

  • Contact Information – If you submit an inquiry, register for an account, or provide information on
    or through the Site, we may collect your contact information including your name, mailing
    address, email address, and phone number.
  • Commercial Information – If you submit an inquiry, or provide information through the Site, we
    may collect commercial information including information about your purchases, subscriptions,
    and Services you have shown interest in.
  • Usage Information – When you use the Site, we may automatically record information, including
    your Internet Protocol address (IP Address), geolocation of your device (which may be precise or
    approximate depending on your device settings and permissions), including for mileage tracking
    purposes, browser type, referring URLs, domain names associated with your internet service
    provider, and any other information regarding your interaction with the Site.
  • Communication Information – We may collect Personal Information contained within your
    communications with us via email, chat functionality, social media, telephone, or otherwise, and
    in certain cases we may use third-party service providers to do so. Where permitted by applicable
    law, we may collect and maintain records of calls and chats with our agents, representatives, or
    employees via message, chat, post, or similar functionality. If you allow the Site to access or
    integrate your email, texts, calls, or any other communication forum, we may collect Personal
    Information contained within your communications with third parties via email, text, call, or
    otherwise.
  • Financial Information – If you choose to upgrade to a premium subscription, we will collect and
    process financial information, such as credit card details, to upgrade your subscription.
  • Transaction Information – If you upload or allow the Site to access documents related to real
    estate transactions, including but not limited to purchase agreements, addendums, contingencies,
    and escrow agreements, we may collect Personal Information contained within those documents,
    including financial information, such as account numbers and insurance information.
  • Voice and Audio Data – If you utilize the voice recognition capability of the Site’s virtual
    assistant service, we may collect Personal Information contained within your audio
    communication with the Site, as well as audio recordings of your voice.
Sensitive Personal Information

Certain data we collect may be considered “Sensitive Personal Information” under applicable law,
including financial account information, precise geolocation, and contents of communications. We use
such information only as reasonably necessary to provide the Services, ensure security, and comply with
legal obligations. We do not use Sensitive Personal Information for purposes other than those permitted
by applicable law.

How We Collect Personal Information
  • Directly From You – We collect Personal Information that you provide to us directly, for example,
    if you choose to contact us, request information from us, sign up to receive updates, upload or
    allow access to documents, or integrate or allow access to text messages, email, and calling
    capabilities, or otherwise utilize the Site.
  • From Third Parties – We may collect Personal Information from third parties, including but not
    limited to business partners, advertising networks, social networks, data analytics providers,
    mobile device providers, and Internet or mobile service providers. We may also collect Personal
    information from apps and third-party services you connect to the Site
  • Through Online Tracking Technologies – We use cookies and similar technologies to collect
    Personal Information automatically as you navigate the Site. For additional information regarding
    our use of these technologies, see the Cookies and Tracking Technologies section below.
How We Use Personal Information

To the extent permitted by applicable law, we use Personal Information:

  • To provide and personalize our Site and Services, such as providing and personalizing our
    Services, providing customer service, maintaining or servicing accounts, verifying customer
    information, creating and maintaining business records, verifying eligibility, and undertaking or
    providing similar services.
  • To optimize, improve, and maintain our Services, including understanding how users interact with
    our Services, gauging user interest in certain Services or the Site functionality, and
    troubleshooting problems.
  • For internal research and development, such as testing, verifying, and improving the quality of
    our Services or developing new ones, including but not limited to using Personal Information to
    train and improve an internal artificial intelligence model to provide our Services.
  • For marketing and advertising, including using your information to send you messages, notices,
    newsletters, surveys, promotions, or event invitations about our own or third parties’ goods and
    services that may be of interest to you. We also use Personal Information to conduct
    interest-based advertising as discussed in the Cookies and Other Tracking Technologies section
    below. You can also unsubscribe from any marketing emails or text messages that we may send
    you by following the instructions included in the email or text correspondence.
  • For communicating with you, such as responding to your questions and comments or notifying
    you of changes to the Site or Services.
  • For legal, security, or safety reasons, such as protecting our and our users’ safety, property, or
    rights; complying with legal requirements; enforcing our terms, conditions, and policies;
    detecting, preventing, and responding to security incidents; and protecting against malicious,
    deceptive, fraudulent, or illegal activity.
  • As part of a corporate transaction, such as in connection with the sale of part or all of our assets
    or business, the acquisition of part or all of another business or another business’ assets, or
    another corporate transaction, including bankruptcy.
  • To fulfill any other purpose for which you provide it, including purposes described when you
    provide the information or give your consent.
How We Disclose Personal Information

We may disclose aggregated information about our users, and information that does not identify any
individual, without restriction.


We may disclose your Personal Information with your consent or in the following circumstances:

  • Employees and Other Personnel – We may share Personal Information with our employees and
    personnel (such as contractors) who have a need to know the information for our business
    purposes.
  • Affiliates and Subsidiaries – We may share Personal Information within our family of companies
    for their and our business and marketing purposes, including providing you with information
    about the Services we think may be of interest to you.
  • Service Providers – We disclose your Personal Information with the service providers that we use
    to support our business, including but not limited to, artificial intelligence providers, website
    hosting providers, and other technology providers.
  • Business Partners – We may disclose Personal Information with trusted business partners. For
    example, we may disclose your Personal Information with a company whose products or services
    we think may be of interest to you or who we co-sponsor a promotion or service with.
  • Ad Tech Companies and Other Providers – We may share or make available limited Personal
    Information (such as a mobile device identifiers) with ad tech companies and other online service
    providers.
  • Legal Obligation or Safety Reasons – We may disclose Personal Information to a third party
    when we have a good faith belief that such disclosure of Personal Information is reasonably
    necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or
    enforceable governmental request, (b) enforce or investigate a potential violation of any
    agreement you have with us, (c) detect, prevent, or otherwise respond to fraud, security or
    technical concerns, (d) support auditing and compliance functions, or (e) protect the rights,
    property, or safety of Subi, its employees and clients, or the public against harm.
  • Merger or Change of Control – We may disclose Personal Information to third parties as
    necessary if we are involved in a merger, acquisition, or any other transaction involving a change
    of control in our business, including but not limited to, a bankruptcy or similar proceeding. Where
    legally required, we will give you notice prior to such disclosure.
  • Other – We may disclose Personal Information to third parties when explicitly requested by or
    consented to by you, or for the purposes for which you disclosed the Personal Information to us
    as indicated at the time and point of the disclosure (or as was obvious at the time and point of
    disclosure).
Sale and Sharing of Personal Information

We do not sell Personal Information in exchange for monetary compensation. However, we may “share”
Personal Information, as defined under applicable law, with advertising and analytics providers for
purposes of cross-context behavioral advertising.

Cookies and Other Tracking Technologies

We and our service providers may use cookies and similar technologies to collect usage about how you
use the Site. The technologies we use for this automatic data collection may include cookies and web
beacons that permit us to verify system and server integrity and generate statistics around the popularity
of certain content and Services. We process the information collected through such technologies, which
may include or be combined with Personal Information, to help operate certain features of the Site, to
enhance your experience through personalization, and to help us better understand the features of the Site
that you and other users are most interested in.


Site Delivery and Appearance – We may use third-party providers to enable certain customer interaction
opportunities, content delivery (like audio or video), or other service capabilities. Examples include, but
are not limited to, the following functionality:

  • Virtual Assistant Support: We use an interactive chat feature enabled by a large language model
    that may be provided by a third-party (like Google’s Gemini or a similar artificial intelligence
    service provider) to enable a virtual assistant service via the Site. When you engage in the chat,
    you are interacting with virtual assistant powered by artificial intelligence, not a human
    representative. Any Personal Information collected via the virtual assistant service may be
    automatically shared with the third-party service providers that support this tool and handled
    according to their privacy policy as appropriate. For example, Personal Information shared with
    Google’s Gemini in the course of this virtual assistant service will be subject to Google’s Privacy
    Policy.

Site Analytics and Session Replay – We may use analytics and session replay services, that use cookies
and other technologies that collect your Personal Information, to assist us with analyzing usage of the Site
to optimize, maintain, and secure the Site and inform subsequent business decisions (including, e.g.,
advertising). Where practicable, we configure these tools to avoid capturing sensitive information entered
into form fields.

Cookie Choices – To manage your preferences with respect to these technologies, you can:

  • Customize your device settings to refuse all or some cookies, or to alert you when apps set or
    access cookies. If you disable certain cookies, please note that some parts of the Site may not
    function properly. These settings may be lost and require reconfiguration if you delete your
    cookies.
  • Block the collection and use of your information by online platforms and ad tech companies for
    the purpose of serving interest-based advertising by visiting the opt out pages of the
    self-regulatory programs of which those companies are members: National Advertising Initiative
    and Digital Advertising Alliance. Please note that even if you opt out of interest-based
    advertising, you may still see “contextual” ads which are based on the context of what you are
    looking at on the websites and pages you visit.

Review and execute any provider-specific instructions to customize your preferences or opt-out of certain
processing, including interest-based advertising, by third-party service providers.

How Long We Keep Your Personal Information

We retain your information for as long as it is needed: (i) to conduct business with you; (ii) fulfill the
purposes outlined in this policy; and (iii) to comply with our legal obligations, resolve disputes, and
enforce any agreements.
Criteria we will use to determine how long to retain your Personal Information includes the nature and
length of our business relationship with you; our legal rights, obligations, and retention requirements; and
if we have an ongoing business purpose for retaining your Personal Information, such as communicating
with you about ongoing or prospective Services you requested.


Your Privacy Rights

Depending on your state of residence, you may have the following rights: Right to access Personal
Information; Right to delete Personal Information; Right to correct inaccuracies; Right to opt out of the
sale or sharing of Personal Information; Right to opt out of targeted advertising and certain profiling; and
Right to limit use of Sensitive Personal Information.


To exercise your rights, please contact us at legal@oksubi.com. We will take reasonable steps to verify
your identity before fulfilling your request, which may include verifying information associated with your
account or requesting additional information where necessary. You may also designate an authorized
agent to act on your behalf where permitted by law.


We will not discriminate against you for exercising any of your privacy rights under applicable law.

Please note that certain features of the Services require the use of specific Personal Information. If you
choose to exercise certain privacy rights (such as deletion or restriction of processing), and the requested
action limits our ability to process Personal Information that is reasonably necessary to provide the
Services, some or all features of the Services may no longer function properly or may become
unavailable. In such cases, we will inform you if we are unable to fulfill your request without affecting
core functionality.

Links to Third-Party Websites

We are not responsible for the practices employed by any websites or services linked to or from the Site,
including the information or content contained within them. We encourage you to investigate and ask
questions before disclosing Personal Information to third parties, since any Personal Information
disclosed will be handled in accordance with the applicable third party’s privacy policy.

In some cases, we offer links to social media platforms that enable you to easily connect with us or share
information on social media. Any content you post via these social media pages is subject to the Terms of
Use and Privacy Policies for those platforms.

We may also integrate with other websites to provide enhanced services, technological capabilities, or
resources for you. These plug-in services and capabilities are governed by the terms, conditions, and
policies of the underlying companies. Some of the integrations we currently offer include the ability to
view our business and/or provider profiles on social media platforms. This hyperlinked content (including
any embedded customer reviews) is governed according to the privacy policies for each platform. We may
also give you the option to login to the Site’s platforms via third-party services. If you choose to leverage
this option to link your accounts, we will receive information associated with your account (such as your
name and profile information) from that third-party service. This information varies and is controlled by
that service or as authorized by you via your privacy settings at that service. We recommend reviewing
the service’s privacy policy beforehand and managing your privacy settings on an ongoing basis.

International Use and Cross-Border Data Transfers

If you are using the Site from outside of the United States, please note that our Site is hosted in the United
States. Where permitted by applicable law, we may transfer the personal data we collect about you to the
United States and other jurisdictions that may not be deemed to provide the same level of data protection
as your home country, as necessary for the purposes set out in this Notice.

How We Protect Personal Information

We have implemented commercially reasonable measures designed to secure your Personal Information
from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the
transmission of information via the internet is not completely secure. Despite these efforts to store
Personal Information in a secure environment, we cannot guarantee the security of Personal Information
during its transmission or its storage on our systems.

Children’s Privacy

We do not knowingly collect or solicit any Personal Information from children, as defined under
applicable law, without verified written parental consent, and we have no actual knowledge of selling
such Personal Information of minors under 16 years of age. If we learn that we have collected Personal
Information from a child, we will promptly take steps to delete that information. If you believe we might
have any information from or about a child, please contact us at legal@oksubi.com.

Changes to this Notice

Please note that we may modify or update this Notice from time to time, so please review it periodically.
If we make material changes to how we treat Personal Information, we will notify you according to
applicable law. Unless otherwise indicated, any changes to this Notice will apply immediately upon
notification to the Site. You are responsible for periodically visiting the Site and this Notice to check for
any changes.

Contact Us

If you have any questions about our practices handling your Personal Information, or this Notice, please
contact us at legal@oksubi.com