Privacy Policy

Effective October 1, 2025

Subduxion B.V. (hereinafter referred to as “Subduxion”), with its registered office at High Tech Campus 5, 5656 AE Eindhoven, the Netherlands, is the controller responsible for the processing of personal data as set out in this Privacy Policy.

Subduxion, including our subsidiaries (collectively, “we,” “us,” or “our”), attaches great importance to protecting your privacy and the security of your data. This Privacy Policy explains our approach to the personal data (“Personal Data”) that we collect from you or about you through your use of the Subduxion websites (https://www.subduxion.com) and those of our affiliates (together, the “Website”), as well as through your use of Subduxion’s products and services, including but not limited to application programming interfaces, related software, developer tools, data, and documentation (collectively, the “Services”).

Your use of our Website, registering an account, subscribing to our newsletter, and/or requesting a live or video demonstration constitutes your unambiguous consent (by providing your Personal Data or by opting in) to this Privacy Policy and therefore to the manner in which we collect, use, and process your Personal Data.

We recommend that you read this Privacy Policy carefully together with our Cookie Policy.

Personal Data We Process

In the context of providing our Services, Subduxion may collect and process the following categories of Personal Data:

  • First and last name;

  • Position within your organization;

  • Name of the legal entity by which you are employed;

  • Business address;

  • Business email address;

  • Business telephone number;

  • VAT identification number.

We may collect and process this Personal Data in the following ways:

  • Information you provide to us: We may collect Personal Data when you register an account to use our Services or otherwise communicate with us.

  • Communications data: When you correspond with our organization, we may collect data that allows us to identify you, including your name, communication channels, and the content of your communication.

  • Technical information collected automatically: When you visit, use, or interact with our Services, we may automatically collect certain technical information, including but not limited to:

    1. Log file data: Information your browser automatically transmits when visiting our Website, including your IP address, browser type and settings, the date and time of your request, and your interactions with the Website.

    2. Usage information: Automatically collected data regarding your interactions with our Services, such as content viewed or used, features you utilize, your actions, time zone, country, dates and times of access, user agent and version, device type, connection details, and IP address.

    3. Device information: Including the device name you use, operating system, and browser, depending on your device type and configuration.

The processing of this data is carried out in accordance with applicable data protection laws and this Privacy Policy.

Cookies and Your Choices

Within our Website, www.subduxion.com, and in providing our Services, we actively use cookies. Cookies are intended to optimize the functionality of our site and enhance your browsing experience. A cookie is a small text file that our Website sends to your browser and that is then stored on your device. These files play a crucial role in improving your user experience on our site.

We understand the importance of your privacy and your control over your own data. Therefore, we offer you the ability to set your cookie preferences as you wish. Through your browser settings, you can choose to accept all cookies, refuse them, or receive a notification each time a cookie is offered. This gives you the freedom to decide, on an individual basis, whether to accept cookies.

Please note that completely disabling cookies may affect the accessibility and functionality of our Website or certain parts of it. This may result in a limited user experience or certain sections of the Website not functioning optimally.

For detailed information on managing your cookie preferences and to gain more insight into how cookies work, we invite you to consult the “All About Cookies” website. In addition, you can adjust your cookie preferences directly via our Website. At the bottom of our Privacy Policy you will find the option to change your settings, so that you always have control over your cookie preferences on www.subduxion.com.

Purposes of Data Processing

We may use your Personal Data for the following purposes:

  • Providing our products and services: Your data is used to deliver our Services, including processing and completing your selection or purchase of our Services, and to improve the quality, safety, and security of our Website and Services.

  • Communication: Your data is necessary for responding to your messages, contacting you about your transactions, promoting our Services, providing relevant information, and requesting your insights or feedback.

  • Personalisation of your experience: We use your data to personalise and optimise your experience on our Website.

  • Internal research: Your data is used for internal research to develop, improve, or repair our products, services, or technology.

  • Security and fraud prevention: We use your data to (1) prevent, detect, and protect against security incidents, and (2) ensure the integrity or security of our systems.

  • Compliance with law: Your data may be used to comply with applicable laws and regulations or to respond to lawful government requests.

We aim not to retain your Personal Data longer than is reasonably necessary to achieve the purposes for which it was collected or as required by law.

Sharing and Disclosure of Personal Data

Subduxion acts at all times with the utmost care and diligence regarding your Personal Data. In the course of our business operations and in accordance with applicable data protection laws, it may be necessary to share your Personal Data with third parties. This only occurs within strictly defined parameters and subject to the required legal safeguards, including:

  • External service providers: To perform certain business functions and services - such as hosting, cloud computing and IT services, event management, email communications, and marketing activities - we may provide Personal Data to carefully selected service providers. These parties are contractually obligated to process the data in accordance with our instructions and applicable data protection laws.

  • Corporate transactions: In the event of corporate transactions such as mergers, acquisitions, or bankruptcies, Personal Data may be shared or transferred as part of due diligence and the transaction, subject to the necessary legal and contractual safeguards.

  • Legal obligations: Where required by law, or where we in good faith believe action is necessary, data may be disclosed to comply with legal proceedings, national security requirements, fraud prevention, or to protect the rights, property, and safety of Subduxion, its users, and the public.

  • Affiliated companies: Sharing Personal Data with our affiliates will occur only where consistent with this Privacy Policy and applicable law.

  • Other users: Certain actions you take as a user - such as participating in open forums or comment sections - may be visible to other users of the Service.

Email Marketing

As part of our communications strategy, we may use your Personal Data to deliver newsletters and other marketing or promotional materials. Consent is the legal basis for this processing where required. You may withdraw your consent at any time by using the unsubscribe link included in each email or by contacting us directly.

Advertising Services

A portion of our revenue may be derived from displaying advertisements. Such activities are conducted in compliance with applicable privacy laws and, where required, on the basis of your consent or another valid legal basis (e.g., legitimate interests). For details on cookies and similar technologies used for advertising and measurement, please refer to our Cookie Policy.

Advertising Tools


Third-Party Services

We disclose Personal Data to carefully vetted third parties solely for specific, legitimate purposes, limited to what is necessary to operate our business and deliver high-quality services. Each provider is bound by appropriate contractual and security obligations.

Sub-processors

When Subduxion acts as a processor on behalf of its customers, we may engage the following Sub-processors to support delivery of the Services. Each Sub-processor is subject to a written agreement imposing data-protection obligations no less protective than those in our DPA.

Service Providers

When Subduxion acts as a controller (e.g., for our marketing site, CRM, recruiting, and scheduling), we use the following processors/service providers:


Note: A vendor may appear in both lists if it supports both our customer-facing Services (as a Sub-processor) and our own operations (as a Service Provider), depending on how it is used.

We encourage you to review these providers’ privacy policies to understand how they process and protect your Personal Data. When selecting service providers and sub-processors, we ensure they maintain a rigorous privacy program consistent with the EU General Data Protection Regulation (GDPR) and our own high standards.

Updating Your Information

If you want to update or correct your Personal Data, or if you have questions or comments not covered by this Privacy Policy, please contact us at privacy@subduxion.com.

GDPR - EU Data Subjects

Use of Personal Data and Legal Bases

We generally act as a data controller for the Personal Data of EU data subjects provided to us. We process such data for legitimate business purposes in order to provide our Website and Services to you. Where we are required by law or under a contract with you to collect Personal Data and you fail to provide it when requested, we may be unable to provide (part of) the Services.

We assess and balance any potential impact on you and your rights before processing your Personal Data based on our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by your interests or fundamental rights and freedoms, unless we have your consent or are otherwise required or permitted by law.

In certain situations, we act as a data processor for third-party partners. In those cases, we process your Personal Data for the purposes set out in this Policy in accordance with those partners’ data-processing terms.

Where we rely on your consent to collect, use, or disclose your Personal Data, you may withdraw your consent at any time by contacting us using the details below. We will use your Personal Data only for the purposes for which it was collected, unless we reasonably consider that we need to use it for another purpose that is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

If you are located in the EU and have concerns about our privacy practices as a controller, you have the right to lodge a complaint with your local supervisory authority. We would appreciate the chance to address your concerns before you contact the authority, so please reach out to us first using the details below.

Your Rights

Subject to Articles 12–23 GDPR, you have the following rights regarding your Personal Data:


  • Right of access - request access to and a copy of your Personal Data.

  • Right to rectification - request correction of outdated, inaccurate, or incomplete data.

  • Right to restriction - request that we restrict processing in certain circumstances.

  • Right to withdraw consent - withdraw consent at any time, without affecting the lawfulness of processing based on consent before withdrawal.

  • Right to data portability - where technically feasible, request that we transmit your Personal Data to you or to a third party.

  • Right to object - object to processing based on our legitimate interests in certain circumstances.

  • Right to erasure - request deletion of your Personal Data where a legal basis applies.

  • Right to lodge a complaint - with your supervisory authority.

You can exercise these rights at any time by emailing privacy@subduxion.com.

International Data Transfers

We use EU Standard Contractual Clauses (SCCs) (and, where applicable, the UK addendum) to meet adequacy and security requirements for customers in the European Union and the United Kingdom when Personal Data is transferred from these jurisdictions to countries that do not provide an adequacy decision. For more information, contact us as described in the Contact Us section below.

Children

Our Services are not directed to children under the age of 13. Subduxion does not knowingly collect Personal Data from children under 13. If you believe a child under 13 has provided Personal Data to Subduxion through the Services, please email privacy@subduxion.com and we will endeavour to delete such information from our systems.

Security

We implement commercially reasonable physical, technical, and administrative safeguards designed to reduce the risk of loss, misuse, unauthorised access, and disclosure of data as per our Information Security Policy. However, no security measure is perfectly secure, and we cannot guarantee the absolute security of your Personal Data.

No Internet or email transmission is ever fully secure or error-free. Email sent to or from us may not be secure; please take special care in deciding what information you send to us via the Services or email. We are not responsible for circumvention of any privacy settings or security measures contained on the Services or on third-party websites.

International Users

By using the Services, you understand and acknowledge that your Personal Data may be transferred from your location to our facilities and servers in the European Economic Area.

Changes to This Privacy Policy

We may update this Policy periodically as we introduce new products and services, and as our business, technologies, and applicable laws evolve. You can determine when this Policy was last revised by referring to the “Last updated” date below. Changes take effect when the revised Policy is posted.

Contact

If you have questions or comments about our privacy practices, please contact Subduxion's Data Privacy Officer using the details below:


We aim to respond as promptly as possible. For direct communication or specific requests regarding your Personal Data, you may also use the contact form on our Website.