Last Updated: October 7, 2026
Subi Incorporated and its affiliates and subsidiaries (“Subi,” “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.
This Notice should be read together with our Terms of Use, which govern your use of the Services. The Services are intended only for individuals who are at least eighteen (18) years old.
Some users of the Services are licensed real estate professionals (“Agent Users”) who use the Services in their business, including to communicate with their own clients and contacts. Where an Agent User submits information about, or sends a message to, one of their own clients or contacts, we process that information as the Agent User’s service provider — on their behalf and under their instructions — and the Agent User, not Subi, decides how it is used. See Text Messages and Mobile Information below.
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:
Certain data we collect may be considered “Sensitive Personal Information” under applicable law, including financial account information, government identifiers, precise geolocation, biometric information, and contents of communications. Where applicable law requires your consent before we process sensitive data for a particular purpose, we will obtain that consent. We use such information only as reasonably necessary to provide the Services, ensure security, and comply with legal obligations. We may use Sensitive Personal Information to train and improve our artificial intelligence models as permitted by applicable law. This does not include Google user data. Google user data is excluded from developing, improving, or training generalized or non-personalized AI or machine-learning models and is processed only as described in the Google User Data section. If you are a resident of California, you may have the option to direct us to limit our use of your Sensitive Personal Information to those permitted purposes by emailing legal@oksubi.com.
We process audio only to convert speech to text and to provide the features you request. We do not create a voiceprint, voice template, or other biometric identifier capable of identifying you by the characteristics of your voice.
Written retention schedule and destruction guidelines. This paragraph is our publicly available written policy for the purposes of 740 ILCS 14/15(a) and comparable laws. Audio recordings are retained for 30 days and then permanently destroyed. Transcripts are retained for the life of your account and then permanently destroyed. We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information. Recording consent. Recording a call may require the consent of every participant. Where you use the Services to record a call, you are responsible for obtaining any consent required from the other participants.
If you connect a Google account, Subi requests permissions separately for the features you choose to enable. Basic sign-in uses your Google account identifier, name, email address, and profile image. Calendar synchronization may access your calendar list and events; contact import may access your Google contacts; connected-inbox features may read Gmail messages and attachments. Sending email requires separate permission and your review or authorization.
Subi uses information received from Google APIs only to provide or improve user-facing features visible in Subi, including calendar synchronization, contact import, email search and summarization, transaction-related productivity features, and sending messages you authorize. "Google user data" includes information received from Google APIs and information derived from it, including summaries, extracted information, and aggregated or anonymized data.
These restrictions apply throughout this Notice and take precedence over broader descriptions of data use, disclosure, AI training, advertising, or analytics elsewhere in it. Subi does not sell Google user data, use it for marketing or advertising, transfer it to advertising platforms, data brokers, or information resellers, or use it to determine creditworthiness or for lending.
Google Workspace API data is not used to develop, improve, or train generalized or non-personalized artificial intelligence or machine-learning models, including Subi's internal models or our service providers' models. AI processing of Google user data is limited to providing the user-facing features you request, such as summarizing an email or extracting transaction information.
Subi transfers Google user data only as necessary to provide or improve these user-facing features with your consent, for security purposes, to comply with applicable law, or as part of a merger, acquisition, or sale of assets after obtaining your explicit prior consent. Service providers acting on our behalf, including AI providers, are subject to these restrictions.
Humans do not read Google user data except with your affirmative permission to view specific data, when necessary for security purposes such as investigating a bug or abuse, when required by law, or when the data has been aggregated for permitted internal operations in accordance with applicable law.
You can revoke Subi's access through your Google Account permissions or disconnect your account in Subi. Revocation stops future collection from Google. You may request deletion of Google-derived data by contacting legal@oksubi.com. Retention is governed by the "How Long We Keep Your Personal Information" section, subject to the restrictions above.
Subi's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including its Limited Use requirements.
Every use described below is subject to the restrictions in the Google User Data section.
To the extent permitted by applicable law, we use Personal Information:
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Where we hold information in de-identified form, we will maintain and use it in de-identified form and will not attempt to reidentify it.
Every disclosure described in this section is subject to the restrictions on Mobile Information set out under Text Messages and Mobile Information below. Where this section and that section conflict, that section controls.
We may disclose your Personal Information with your consent or in the following circumstances:
We do not sell your Personal Information. Some state privacy laws define “sell” broadly to include disclosures for monetary or other valuable consideration; we do not make disclosures of that kind. We may “share” Personal Information, as that term is defined under applicable law, with advertising and analytics providers for purposes of cross-context behavioral advertising, which some state laws call “targeted advertising.” We never sell or share Mobile Information for any purpose; see Text Messages and Mobile Information below. You may opt out of this sharing by emailing legal@oksubi.com. We have no actual knowledge that we sell or share the Personal Information of consumers under sixteen (16) years of age.
No mobile information will be shared with third parties or affiliates for marketing or promotional purposes.
We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes.
We do not sell, rent, share, lease, trade, or otherwise transfer mobile phone numbers, SMS or text message opt-in information, or messaging consent (“Mobile Information”) to any third party or affiliate for that third party’s or affiliate’s marketing or promotional purposes. Text messaging originator opt-in data and consent are never shared with any third party for that purpose. This applies equally to Mobile Information about you and to Mobile Information about an Agent User’s clients and contacts processed through the Services.
This section controls over every other provision of this Notice. To the extent any other section of this Notice — including Personal Information We Collect, How We Use Personal Information, How We Disclose Personal Information (including the Affiliates and Subsidiaries, Business Partners, and Ad Tech Companies and Other Providers subsections), Sale and Sharing of Personal Information, or Cookies and Other Tracking Technologies — describes or permits any sale, sharing, or disclosure of Personal Information for marketing, promotional, advertising, or analytics purposes, that description does not apply to Mobile Information and grants no right to disclose Mobile Information.
The only parties that receive Mobile Information are the service providers that transmit messages on our behalf — our messaging platform provider and telecommunications carriers — and they receive it solely to deliver the messages you have asked to receive. They may not use it for their own marketing or promotional purposes and may not disclose it to anyone else for those purposes. We may also disclose Mobile Information where required by law or legal process.
Messaging consent is not transferable. Consent to receive messages from Subi applies only to Subi, and consent to receive messages from an Agent User applies only to that Agent User. We do not transfer, assign, or make consent available to any other business; we do not acquire messaging consent from lead generators, list brokers, or any other source; and we do not use an Agent User’s clients or contacts to send our own marketing messages.
Text messages sent through the Services fall into two categories, described below.
Messages we send to you
How we obtain your consent. We send our own text messages only to individuals who have opted in, by checking a consent box on a form on our Site or in our app, by providing a mobile number and agreeing to receive messages during account registration, or by texting us first. The consent disclosure is presented at the point of opt-in and links to this Notice. Consent to receive text messages is not a condition of purchasing any goods or services.
Message types and frequency. We may send account and service notifications, appointment and transaction updates, conversational messages, group or broadcast messages sent to recipients who have opted in, and — if you have separately consented to marketing messages — promotional messages. Message frequency varies. Message and data rates may apply.
How to stop. Reply STOP to any message to opt out, or HELP for assistance. You may also email legal@oksubi.com. We will honor a request to stop receiving messages, made through any reasonable means, within ten (10) business days, and we will treat it as applying to all non-exempt messages. Opting out of text messages does not affect email or other communications, which you may manage separately.
Messages an Agent User sends to their own clients and contacts
Where we make this feature available, an Agent User may use the Services to send text messages to that Agent User’s own clients and contacts. In that case:
If you received a text message from a real estate professional who uses Subi. That message was sent by the professional who contacted you, not by Subi. Reply STOP to stop receiving messages from that sender, or HELP for assistance; we apply an opt-out across the Services, so the sender cannot continue messaging you through Subi. Because the professional — not Subi — decides how your information is used, requests to access, correct, or delete your information should be directed to them. You may also contact us at legal@oksubi.com and we will forward your request to them and assist them in responding.
We and our service providers may use cookies and similar technologies to collect usage data 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. These technologies are not used to disclose Mobile Information.
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:
Site Analytics and Session Replay – We may use analytics and session replay services, that use cookies and other technologies that collect 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:
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.
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.
Applying those criteria to the categories above: Contact, Commercial, and Transaction Information is retained for the life of your account and for a further period after closure sufficient to resolve disputes, satisfy tax and audit obligations, and enforce our agreements. Financial Information is retained as required for payment processing, tax, and audit purposes. Usage Information is retained for the period needed for analytics and security purposes. Voice and Audio Data is retained as described under Voice and Audio Data above. Mobile Information, including records of your opt-in and any opt-out, is retained for as long as you remain opted in and for a further period afterward sufficient to demonstrate compliance with applicable messaging laws and to honor your opt-out. Where an Agent User sends messages to their own clients and contacts through the Services, we retain that contact and opt-out information for the Agent User for as long as their Account is active and as needed to honor opt-outs, and we delete or return it on the Agent User’s instruction, subject to any retention required by law. We may retain de-identified or aggregated information indefinitely.
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 respond within the period required by applicable law. We will not discriminate against you for exercising any of your privacy rights under applicable law. Appeals. If we decline to act on your request, you may appeal by emailing legal@oksubi.com with the subject line “Privacy Request Appeal.” We will respond in writing within the period required by the law of your state, explaining the action we have taken and the reasons for it. If we deny your appeal, you may submit a complaint to your state Attorney General, and we will provide you with the relevant contact information in our response.
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.
California. California residents may request, once per calendar year, information about our disclosures of Personal Information to third parties for their direct marketing purposes under Cal. Civ. Code § 1798.83. Send requests to legal@oksubi.com. We do not disclose Mobile Information to third parties for their direct marketing purposes.
Nevada. Nevada residents may submit a verified request directing us not to make any sale of covered information as defined under Nevada law. Send requests to legal@oksubi.com with the subject line “Nevada Opt-Out Request,” or to the mailing address below.
Illinois, Texas, and Washington. See Voice and Audio Data above for our biometric data policy, including our written retention schedule and destruction guidelines.
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 your 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.
The Services are offered in the United States, and 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.
We maintain a written information security program with administrative, technical, and physical safeguards designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. These include encryption of Personal Information in transit and at rest, access controls, and vendor security diligence. If a security incident affects your Personal Information, we will notify you and the relevant authorities as required by applicable law. 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.
The Services are not directed to, and are not intended for, anyone under eighteen (18) years of age. We do not knowingly collect or solicit Personal Information from anyone under eighteen (18). If we learn that we have collected Personal Information from a person under eighteen (18), we will promptly take steps to delete that information. If you believe we might have any information from or about a person under eighteen (18), please contact us at legal@oksubi.com. We have no actual knowledge of selling or sharing the Personal Information of minors under 16 years of age.
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.
If you have any questions about our practices handling your Personal Information, or this Notice, please contact us at legal@oksubi.com.
