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Last updated: July 21, 2026
Controller / Operator: Q-CONSULT MARKETING LTD
Registered address: 187, Office 1, Level 3, Triq Nazju Ellul, Gzira Malta
VAT: MT28140713
This Privacy Policy explains how Q-CONSULT MARKETING LTD ("Q Consult", "we", "us", "our") collects, receives, accesses, uses, stores, discloses, deletes and otherwise processes personal data in connection with SubSSwitch, including the website at subsswitch.app, the SubSSwitch mobile application, user account portal, integrations, communications and support services (together, the "Service").
We are the controller of personal data processed for the purposes described in this Privacy Policy, except where another party acts as an independent controller under its own terms and privacy notice, for example your bank, email provider or a third-party merchant that you choose to access through an affiliate recommendation.
This Privacy Policy is intended to satisfy transparency requirements under the General Data Protection Regulation (Regulation (EU) 2016/679), the Maltese Data Protection Act (Chapter 586 of the Laws of Malta), the Google API Services User Data Policy including Limited Use requirements, and applicable Maltese and EU data protection laws.
Controller: Q-CONSULT MARKETING LTD
Registered address: 187, Office 1, Level 3, Triq Nazju Ellul, Gzira Malta
VAT: MT28140713
Privacy contact: privacy@subsswitch.app
General support: support@subsswitch.app
We have not appointed a statutory Data Protection Officer unless and until an assessment determines that appointment is legally required. Privacy queries and data subject rights requests should be sent to privacy@subsswitch.app.
| Category | Examples | Source | Purpose |
|---|---|---|---|
| Account data | Name, email address, account ID, login method, account status, password hash where email/password login is used. | Provided by user or received from Google/Apple authentication. | Create and manage Account, authenticate user, provide support, secure Service. |
| Subscription data | Merchant name, billing amount, currency, billing cycle, renewal date, category, subscription status, notes. | Entered by user or detected from connected data sources. | Provide dashboards, reminders, insights and subscription history. |
| Bank transaction data | Merchant, amount, date, account identifier/token, category, transaction description, recurring patterns. | Plaid after user authorisation. | Detect recurring subscriptions and provide Service. |
| Uploaded bank statements | CSV, Excel, OFX, QFX, PDF or other supported statement files and extracted text/transaction lines. | Uploaded by user. | Extract subscription-related transactions; support detection and troubleshooting. |
| Email inbox data | Sender, subject, date, limited body excerpts, merchant identifier, amount, renewal/billing terms from subscription-related emails. | Gmail, Outlook/Microsoft 365 or iCloud Mail after separate user consent. | Detect subscription confirmations, receipts, renewal notices and cancellation notices. |
| Screenshot / import data | Screenshots or lists of subscriptions uploaded by the user; extracted merchant/amount/date fields. | Uploaded by user. | Import and structure subscription records. |
| AI processing inputs and outputs | Minimised email excerpts, transaction lines, screenshot content, extraction prompts, extracted subscription fields. | Generated through use of AI-assisted extraction. | Classify and extract subscription information. |
| Usage and device data | Pages/screens visited, feature usage, session duration, device/browser type, country-level location, error events. | Generated by use of Service. | Security, troubleshooting, analytics, product improvement and abuse prevention. |
| Communications data | Support emails, requests, complaints, preferences and related correspondence. | Provided by user or generated through support interactions. | Respond to requests, keep records, comply with obligations. |
| Security and log data | IP address, timestamps, authentication logs, access logs, system events, token activity, audit logs. | Generated by infrastructure and Service. | Security monitoring, fraud prevention, incident response and troubleshooting. |
| Email connection credentials | OAuth access and refresh tokens, provider account identifiers, and iCloud App-Specific Password/IMAP credentials | User and connected email provider | Authenticate the connection, maintain authorised inbox access and stop access when disconnected |
The following features are optional. Declining them does not prevent you from using manual subscription-management features, although it may limit automatic detection functionality.
| Feature | User action required | Can be withdrawn? | Effect of withdrawal |
|---|---|---|---|
| Bank connection | User authorises connection via supported provider. | Yes. | Automatic bank-based subscription detection stops; previously extracted subscription records may remain unless deleted. |
| Bank statement upload | User uploads a file. | Yes, by deletion request or account deletion. | Uploaded file and extracted data are deleted according to retention/deletion rules; future statement-based detection stops. |
| Email inbox scanning | Separate affirmative opt-in for each connected email account before inbox access begins. | Yes, through Settings → Connected Accounts. | Future inbox scanning stops and the stored OAuth token, App-Specific Password or other email connection credential is deleted from active systems. Previously extracted subscription records remain until deleted by the user or in accordance with the retention rules. |
| AI-assisted extraction | Separate explicit opt-in is obtained before any email data, bank-statement-derived transaction data, screenshot or other personal data is transmitted to a third-party AI provider. | Where based on consent, yes. | Future transmission to the AI provider stops. Manual subscription management and any non-AI features remain available. |
| Analytics cookies | Cookie banner consent. | Yes. | Non-essential analytics are disabled. |
| Affiliate recommendations | Displayed in Service; click/action is voluntary. | Not applicable to display where necessary for Service, but users may choose not to click. | No third-party sign-up or merchant interaction occurs unless user acts. |
| Purpose | Data used | Legal basis under GDPR |
|---|---|---|
| Account creation, login and account management | Account data, authentication data, security logs. | Performance of contract; legitimate interests in account security; legal obligation where applicable. |
| Manual subscription management | Manual subscription data and related account data. | Performance of contract. |
| Bank-based subscription detection | Read-only bank transaction data received through Plaid, or supported provider. | User consent/authorisation for connection and performance of contract to provide the requested feature. |
| Bank statement extraction | Uploaded statement file and extracted transaction lines. | Performance of contract and user consent for optional upload/processing. |
| Email inbox scanning | Limited email data from connected account. | Consent under Article 6(1)(a) GDPR for connecting the email account and conducting ongoing inbox scanning requested by the user. |
| AI-assisted extraction | Minimised excerpts, transaction lines, screenshots and extracted fields. | Consent under Article 6(1)(a) GDPR for transmitting personal data to the disclosed third-party AI provider. Performance of contract may apply to the subsequent storage and display of the subscription information extracted at the user's request. |
| Affiliate recommendations | Manually entered subscription data, merchant/category, price and user preferences. Gmail-, Outlook-, iCloud Mail-, bank- and bank-statement-derived data are not used to personalise affiliate recommendations. | Legitimate interests in operating the free/freemium Service and offering relevant alternatives, subject to transparency and user control; performance of contract where recommendations are part of requested Service. |
| Service communications | Email address, account status, system events. | Performance of contract; legitimate interests; legal obligation for required notices. |
| Security, fraud prevention and abuse prevention | Security logs, IP address, access records, token activity, system events. | Legitimate interests in protecting users, systems and Service; legal obligation where applicable. |
| Analytics and product improvement | Usage data; anonymised or aggregated analytics where possible. | Consent for non-essential cookies/analytics; legitimate interests for strictly necessary service diagnostics and aggregated/anonymised analysis. |
| Compliance with laws and regulatory requests | Relevant account, transaction, log and communication data. | Legal obligation; establishment, exercise or defence of legal claims where applicable. |
If you connect a bank account, the connection is provided by Plaid Financial Ltd. Plaid Financial Ltd. may act as an independent controller or processor depending on the feature and its applicable terms. Its services are subject to its own terms and privacy notice.
We receive read-only transaction and account information necessary for subscription detection. We do not initiate payments, transfers or withdrawals. We use bank transaction data exclusively to identify and display recurring subscription charges, track subscription history and provide related features.
Bank transaction data may reveal sensitive inferences about spending habits, health, beliefs, lifestyle, family relationships, employment, financial position or other private matters. We therefore apply enhanced access controls, data minimization and retention limits.
If you upload a bank statement file, the file is encrypted at application layer using AES-256-GCM before storage. Files are stored in our own database hosted in the European Union, currently Railway, EU West / Amsterdam region, running on Google Cloud Platform europe-west4, subject to vendor configuration and updates.
Uploaded files are not stored in public URLs and should be accessible only through authenticated API endpoints after ownership checks. We process the uploaded statement file within SubSSwitch systems to extract subscription-related transaction data. The bank statement file itself is not sent to the third-party AI provider. Only extracted subscription-related transaction data, such as merchant, amount and date, may be transmitted to the AI provider after the required user permission has been obtained. Account balances, account numbers, personal identifiers and non-subscription transactions are not sent to the AI provider.
Uploaded bank statement files are deleted 90 days after upload unless deleted earlier through account deletion or a valid erasure request. Extracted subscription transactions are retained according to the retention table below.
Inbox scanning is optional and separate from account login. It requires an active user choice and, where applicable, provider OAuth authorisation or app-specific password configuration.
We filter inbox data for subscription-related patterns such as merchant senders, receipt markers, renewal keywords and transactional email indicators. We do not store full email content, attachments or full headers in the production database. We store only extracted subscription metadata required to display and manage subscriptions.
Because inboxes may contain third-party data and potentially sensitive information, access is restricted to automated extraction and strict operational controls. Routine human reading of inbox data is prohibited.
Our use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including Limited Use requirements.
We may transmit limited subscription-related data to Anthropic PBC or another disclosed AI processor for extraction and classification, after obtaining the user's separate explicit permission. AI processing is used to identify, classify and organise subscription-related information.
AI providers must be contractually prohibited from using API-submitted personal data to train their general models. The current policy is no AI model training from Gmail, Outlook, iCloud, bank or statement data.
AI processing may take place in the United States or other third countries. Transfers are governed as described in the International Transfers section.
We collect, access and retain only the data reasonably necessary for the feature selected by the user. Raw Source Data should be processed transiently and reduced as soon as technically feasible to Extracted Subscription Data.
Where technically feasible, analytics and operational reports should use anonymised or aggregated data that no longer identifies users. If data can still be attributed to a user by using additional information, it is pseudonymised rather than anonymised and remains personal data subject to GDPR.
Subscription dashboards remain linked to the Account because the user needs to view and manage their own subscription records. Analytics, product metrics, affiliate reporting and management dashboards should be anonymised or aggregated unless identifiable data is strictly necessary and authorised.
We disclose personal data only where necessary for the Service, where legally required, or where the user chooses to interact with a third-party service. Current sub-processors and relevant third-party providers include:
| Provider | Role | Likely location / transfer note |
|---|---|---|
| Railway Corporation | Hosting infrastructure; EU West / Amsterdam region running on Google Cloud Platform europe-west4. | EU hosting; operational support may involve US-based personnel/sub-processors. |
| Plaid Financial Ltd. | Open banking/account information connection. | UK/EU/US depending on account and provider terms; safeguards required. |
| Anthropic PBC | AI-based extraction/classification. | United States; SCCs/DPF and supplementary measures required. |
| Google LLC | Sign in with Google, Gmail OAuth access, Firebase Analytics if consented, cloud subprocessing through Railway. | EU/US/global; DPA/SCCs/DPF as applicable. |
| Microsoft Corporation | Outlook/Microsoft 365 integration. | EU/US/global; DPA/SCCs/DPF as applicable. |
| Apple Inc. | Sign in with Apple and iCloud Mail integration where enabled. | EU/US/global; DPA/SCCs/DPF as applicable. |
| Resend, Inc. | Transactional email delivery. | United States; DPA/SCCs/DPF as applicable. |
| Merchants / affiliate partners | Only where user clicks or signs up through a recommendation. | Independent controllers under their own terms and privacy notices. |
We do not sell or rent personal data. We do not disclose personal data to third-party advertisers for their own advertising purposes.
Our primary production infrastructure is intended to be hosted in the European Union. Some providers or their support teams may be based in the United States or other third countries. Where personal data is transferred outside the European Economic Area, we rely on appropriate safeguards such as EU Standard Contractual Clauses, Data Processing Agreements, the EU-US Data Privacy Framework where applicable, transfer risk assessments and supplementary technical measures including encryption, access controls and data minimisation.
We do not disclose email-derived, bank-derived or bank-statement-derived data to affiliate partners.
Users may request further information about applicable transfer safeguards by contacting privacy@subsswitch.app, subject to confidentiality and security limits.
| Data category | Retention period / criterion |
|---|---|
| Account data | For the life of the Account and deleted upon account closure, subject to legal, security, backup and dispute-retention limits. |
| Manual subscription data | For the life of the Account unless deleted earlier by the user or through account deletion. |
| Extracted subscription and bank transaction data | Up to 12 months for subscription history unless the user deletes it or closes the Account earlier, subject to backup rotation and legal/security retention. |
| Uploaded bank statement files | Deleted 90 days after upload by automated job unless deleted earlier through account deletion or valid erasure request. |
| Email message content | Not stored in the production database; processed transiently for extraction. Extracted subscription metadata may be retained according to subscription-data retention. |
| AI prompts and outputs | AI inputs and outputs transmitted to Anthropic may be retained by Anthropic for up to 30 days in accordance with the applicable provider terms and data processing arrangements. Personal data transmitted by SubSSwitch to Anthropic is not used to train Anthropic's general AI models. Extracted subscription data retained by SubSSwitch is subject to the applicable retention periods described in this section. |
| Screenshots uploaded for import | Processed for extraction and not retained unless required for the feature and disclosed in the relevant user flow. |
| Application and access logs | Up to 6 months for security, troubleshooting and audit purposes unless longer retention is required for security incident investigation, legal claims or legal obligations. |
| Support communications | As long as necessary to respond and maintain records, generally up to 24 months unless legal reasons require longer retention. |
| Backups | Encrypted backups and point-in-time recovery snapshots may persist for the hosting provider's standard backup window before being overwritten in the normal rotation. Deleted data may remain in backups temporarily but is not restored to production except for continuity/security reasons. |
| Anonymised/aggregated analytics | May be retained indefinitely where individuals are no longer identifiable. |
| Email connection credentials | Retained only while the relevant email account remains connected. Deleted from active systems when the user disconnects the account or deletes their SubSSwitch account. |
You may delete your Account through Settings → Delete Account where available or by contacting support@subsswitch.app. You may exercise data protection rights by contacting privacy@subsswitch.app.
When your Account is deleted, we delete active production account data and associated records, revoke supported third-party connections where programmatically possible, delete stored tokens and credentials, and delete uploaded files stored in our database. Deletion is subject to backup rotation, legal obligations, security-retention requirements and any lawful retention required for dispute handling or compliance.
Disconnecting a connected service stops future access to data from that service. It does not automatically delete subscription information previously extracted and stored by SubSSwitch. You may delete that data separately or request deletion in accordance with this Privacy Policy.
Subject to applicable legal conditions and exemptions, you have the following rights:
Requests should be sent to privacy@subsswitch.app. We will normally respond within one month of receipt. Where a request is complex or numerous requests are made, the period may be extended in accordance with GDPR. We may request information to verify your identity before acting on a request.
The Service uses automated processing to detect recurring payments, classify merchants, estimate renewal dates and display recommendations. This processing is intended to assist the user and does not itself cancel subscriptions, initiate payments, bind the user to third-party services, determine eligibility for credit, insurance, employment, housing or public benefits, or produce legal effects concerning the user.
Users remain responsible for reviewing and confirming detected information and deciding whether to cancel, switch or subscribe to third-party services.
We use essential cookies and similar technologies for authentication, security, session management and Service operation. Essential cookies do not require consent where strictly necessary.
We use analytics cookies or similar analytics technologies, including Google Firebase Analytics where enabled, only after user consent through the cookie banner or consent mechanism. Analytics is disabled until accepted, and users may decline or withdraw consent at any time. We do not use advertising cookies unless this Privacy Policy and the cookie notice are first updated and valid consent is obtained where required.
The Service is intended for users aged 18 and above. We do not knowingly collect or process personal data of persons under 18. If we become aware that such data has been collected, we will delete it unless another lawful basis requires retention.
We maintain an incident response process. Where a personal data breach occurs, we will assess the risk to affected individuals and notify the competent supervisory authority and/or affected users where required by GDPR and applicable law.
We may update this Privacy Policy from time to time. Material changes will be communicated by email or in-app notice at least 30 days before taking effect where practicable, unless earlier implementation is required for legal, security, provider or urgent operational reasons. The "Last updated" date above indicates the current version.
Q-CONSULT MARKETING LTD
187, Office 1, Level 3, Triq Nazju Ellul, Gzira Malta
Privacy matters: privacy@subsswitch.app. General support: support@subsswitch.app.
Maltese supervisory authority: Office of the Information and Data Protection Commissioner (IDPC), Malta, idpc.org.mt