PRIVACY POLICY
Last updated June 18, 2026
This Privacy Notice for 15942390 Canada Inc. ("we,"
"us," or "our"), describes how
and why we might access, collect, store, use, and/or share
("process") your personal information when you use
our services ("Services"), including when
you:
- Visit our website at trysubtotal.com or any website of ours that links to this Privacy Notice
- Use Subtotal Subscription Audit. Find and kill the subscriptions quietly draining your bank account. Upload a statement, and Subtotal scrubs all your personal and account details in your browser before anything is sent. You approve exactly what gets analyzed, then AI separates recurring subscriptions from your everyday spending and hands you a kill list — complete with one-click cancellation links and a savings tracker.
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy
Notice will help you understand your privacy rights and choices. We
are responsible for making decisions about how your personal
information is processed. If you do not agree with our policies and
practices, please do not use our Services. If you still have any
questions or concerns, please contact us at
ryanxu101@gmail.com.
SUMMARY OF KEY POINTS
This summary provides key points from our Privacy
Notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using
our table of contents below to find the section you are looking
for.
What personal information do we process? When you
visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services,
the choices you make, and the products and features you use. Learn
more about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive"
in certain jurisdictions, for example your racial or ethnic
origins, sexual orientation, and religious beliefs. We may process
sensitive personal information when necessary with your consent or
as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we collect any information from third parties?
We do not collect any information from third parties.
How do we process your information? We process
your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other
purposes with your consent. We process your information only when
we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal
information?
We may share information in specific situations and with specific
third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have
adequate organizational and technical processes and procedures in
place to protect your personal information. However, no electronic
transmission over the internet or information storage technology
can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third
parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Learn more
about how we keep your information safe.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information. Learn more
about your privacy rights.
How do you exercise your rights? The easiest way
to exercise your rights is by contacting us. We will consider and
act upon any request in accordance with applicable data protection
laws.
Want to learn more about what we do with any information we
collect? Review the Privacy Notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us
when you express an interest in obtaining information about us or
our products and Services, when you participate in activities on
the Services, or otherwise when you contact us.
Personal Information Provided by You. The
personal information that we collect depends on the context of your
interactions with us and the Services, the choices you make, and
the products and features you use. The personal information we
collect may include the following:
- names
- phone numbers
- email addresses
- contact preferences
Sensitive Information. When necessary, with your
consent or as otherwise permitted by applicable law, we process the
following categories of sensitive information:
- financial data
Payment Data. We may collect data necessary to
process your payment if you choose to make purchases, such as your
payment instrument number, and the security code associated with
your payment instrument. All payment data is handled and stored by
Stripe. You may find their privacy notice link(s) here:
https://stripe.com/en-ca/privacy.
All personal information that you provide to us must be true,
complete, and accurate, and you must notify us of any changes to
such personal information.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process the personal information for the following purposes listed below.
We process your personal information for a variety of
reasons, depending on how you interact with our Services,
including:
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
- Improve the subscription audit service. We may process information you approve for analysis to improve the accuracy and usefulness of the subscription audit.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section
applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require
us to explain the valid legal bases we rely on in order to process
your personal information. As such, we may rely on the following
legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Analyze how our Services are used so we can improve them to engage and retain users
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies
to you.
We may process your information if you have given us specific
permission (i.e., express consent) to use your personal information
for a specific purpose, or in situations where your permission can
be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under
applicable law to process your information without your consent,
including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
- We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments
We may need to share your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.
As part of our Services, we offer products, features, or tools
powered by artificial intelligence, machine learning, or similar
technologies (collectively, "AI Products"). These tools are
designed to enhance your experience and provide you with innovative
solutions. The terms in this Privacy Notice govern your use of the
AI Products within our Services.
Use of AI Technologies
We provide the AI Products through third-party service providers
("AI Service Providers"), including Anthropic. As outlined in this
Privacy Notice, your input, output, and personal information will be
shared with and processed by these AI Service Providers to enable
your use of our AI Products for purposes outlined in "WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL
INFORMATION?" You must not use the AI Products in any way that violates the
terms or policies of any AI Service Provider.
Our AI Products
Our AI Products are designed for the following functions:
- AI research
How We Process Your Data Using AI
All personal information processed using our AI Products is handled
in line with our Privacy Notice and our agreement with third
parties. This ensures high security and safeguards your personal
information throughout the process, giving you peace of mind about
your data's safety.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this Privacy Notice, unless a
longer retention period is required or permitted by law (such as
tax, accounting, or other legal requirements). No purpose in this
notice will require us keeping your personal information for longer
than indefinitely.
When we have no ongoing legitimate business need to process your
personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your
personal information has been stored in backup archives), then we
will securely store your personal information and isolate it from
any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and
organizational security measures designed to protect the security
of any personal information we process. However, despite our
safeguards and efforts to secure your information, no electronic
transmission over the Internet or information storage technology can
be guaranteed to be 100% secure, so we cannot promise or guarantee
that hackers, cybercriminals, or other unauthorized third parties
will not be able to defeat our security and improperly collect,
access, steal, or modify your information. Although we will do our
best to protect your personal information, transmission of personal
information to and from our Services is at your own risk. You should
only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.
We do not knowingly collect, solicit data from, or market to
children under 18 years of age or the equivalent age as specified
by law in your jurisdiction, nor do we knowingly sell such personal
information. By using the Services, you represent that you are at
least 18 or the equivalent age as specified by law in your
jurisdiction or that you are the parent or guardian of such a minor
and consent to such minor dependent's use of the Services. If we
learn that personal information from users less than 18 years of
age or the equivalent age as specified by law in your jurisdiction
has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records.
If you become aware of any data we may have collected from children
under age 18 or the equivalent age as specified by law in your
jurisdiction, please contact us at
ryanxu101@gmail.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you
have certain rights under applicable data protection laws. These
may include the right (i) to request access and obtain a copy of
your personal information, (ii) to request rectification or
erasure; (iii) to restrict the processing of your personal
information; (iv) if applicable, to data portability; and (v) not
to be subject to automated decision-making. In certain
circumstances, you may also have the right to object to the
processing of your personal information. You can make such a
request by contacting us by using the contact details provided in
the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with
applicable data protection laws.
If you are located in the EEA or UK and you believe we are
unlawfully processing your personal information, you also have the
right to complain to your
Member State data protection authority
or
UK data protection authority.
If you are located in Switzerland, you may contact the
Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying
on your consent to process your personal information, which may be
express and/or implied consent depending on the applicable law, you
have the right to withdraw your consent at any time. You can
withdraw your consent at any time by contacting us by using the
contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of
the processing before its withdrawal nor, when applicable law
allows, will it affect the processing of your personal information
conducted in reliance on lawful processing grounds other than
consent.
Opting out of marketing and promotional
communications: You can unsubscribe from our marketing
and promotional communications at any time by clicking on the
unsubscribe link in the emails that we send, replying "STOP" or
"UNSUBSCRIBE" to the SMS messages that we send, or by contacting us
using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists.
However, we may still communicate with you — for example, to send
you service-related messages that are necessary for the
administration and use of your account, to respond to service
requests, or for other non-marketing purposes.
No mobile information will be shared with third parties or
affiliates for marketing or promotional purposes. Information
sharing to subcontractors in support services, such as customer
service, is permitted. All other use case categories exclude text
messaging originator opt-in data and consent; this information will
not be shared with third parties.
If you have questions or comments about your privacy rights, you
may email us at
ryanxu101@gmail.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web
browser DNT signals. Because there currently is not an industry or
legal standard for recognizing or honoring DNT signals, we do not
respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.Categories of Personal Information We Collect
The table below shows the categories of personal information we have collected in the past twelve (12) months. The table includes illustrative examples of each category and does not reflect the personal information we collect from you. For a comprehensive inventory of all personal information we process, please refer to the section "WHAT INFORMATION DO WE COLLECT?"| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location | NO |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics | NO |
| L. Sensitive personal Information | Financial information including account access details | YES |
We only collect sensitive personal information, as defined by
applicable privacy laws or the purposes allowed by law or with your
consent. Sensitive personal information may be used, or disclosed to
a service provider or contractor, for additional, specified
purposes. You may have the right to limit the use or disclosure of
your sensitive personal information. We do not collect or process
sensitive personal information for the purpose of inferring
characteristics about you.
We may also collect other personal information outside of these
categories through instances where you interact with us in person,
online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed
to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category D - As long as the user has an account with us
- Category L - As long as the user has an account with us
Sources of Personal Information
Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"How We Use and Share Personal Information
Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"
Will your information be shared with anyone
else?
We may disclose your personal information with our service
providers pursuant to a written contract between us and each
service provider. Learn more about how we disclose personal
information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
We may use your personal information for our own business purposes,
such as for undertaking internal research for technological
development and demonstration. This is not considered to be
"selling" of your personal information.
We have not disclosed, sold, or shared any personal information to
third parties for a business or commercial purpose in the preceding
twelve (12) months. We will not sell or share personal information
in the future belonging to website visitors, users, and other
consumers.
Your Rights
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
How to Exercise Your Rights
To exercise these rights, you can contact us by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an
authorized agent to make a request on your behalf. We may deny a
request from an authorized agent that does not submit proof that
they have been validly authorized to act on your behalf in
accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need
to collect additional information to verify your identity before
processing your request and the agent will need to provide a written
and signed permission from you to submit such request on your
behalf.
Appeals
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at ryanxu101@gmail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: You may have additional rights based on the country you reside in.Australia and New Zealand
We collect and process your personal information under the
obligations and conditions set by Australia's Privacy Act 1988 and
New Zealand's Privacy Act 2020 (Privacy Act).
This Privacy Notice satisfies the notice requirements defined in
both Privacy Acts, in particular: what personal information we
collect from you, from which sources, for which purposes, and other
recipients of your personal information.
If you do not wish to provide the personal information necessary to
fulfill their applicable purpose, it may affect our ability to
provide our services, in particular:
- offer you the products or services that you want
- respond to or help with your requests
At any time, you have the right to request access to or correction
of your personal information. You can make such a request by
contacting us by using the contact details provided in the section
"HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM
YOU?"
If you believe we are unlawfully processing your personal
information, you have the right to submit a complaint about a breach
of the Australian Privacy Principles to the
Office of the Australian Information Commissioner
and a breach of New Zealand's Privacy Principles to the
Office of New Zealand Privacy Commissioner.
Republic of South Africa
At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"
If you are unsatisfied with the manner in which we address any
complaint with regard to our processing of personal information, you
can contact the office of the regulator, the details of which
are:
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated
version will be indicated by an updated "Revised" date at the top of
this Privacy Notice. If we make material changes to this Privacy
Notice, we may notify you either by prominently posting a notice of
such changes or by directly sending you a notification. We encourage
you to review this Privacy Notice frequently to be informed of how
we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact us by post at:
15942390 Canada Inc.
Canada
You can also email us at
ryanxu101@gmail.com.