Last Updated: September 2026

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Kolhsys Pty Ltd ("Kolhsys", "we", "us", or "our") is committed to safeguarding the confidentiality and privacy of information entrusted to us, including personal information (or "personally identifiable information" / "PII"). 

This Privacy Policy applies to our website, consulting services, and mobile software applications (including "Subly - Subscription Tracker" and any other mobile applications operated by Kolhsys). By using our website, services, or mobile apps, you agree to the handling of your personal information as set out in this Asia Pacific Privacy Policy ("APP Privacy Policy").

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### 1. Information We Collect

We collect personal information necessary to provide our consulting services and software applications to you:

#### A. Mobile Application Data (e.g., Subly)
* **Account Information:** Email address and authentication details provided when you register an account (managed via secure authentication providers such as Supabase).
* **User-Generated App Data:** Subscription names, renewal dates, billing frequencies, currency choices, and user-entered cost amounts.
* **Technical & Device Information:** Anonymous crash reports, device operating system versions, and usage diagnostics required for app performance and stability.

#### B. Corporate & Consulting Data
* **Contact Information:** Name, email address, telephone number, physical address, and occupation provided when inquiring about or using our consulting services.

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### 2. How We Use Your Information

Kolhsys collects, holds, and uses personal information strictly for the purposes for which it was provided, including:
* Providing, operating, and maintaining our mobile applications and consulting services.
* Managing customer relationships, account authentication, and user support.
* Sending essential service notifications (e.g., password resets or app updates).
* Internal business operations, app diagnostics, and legal compliance.

We do **not** sell, rent, trade, or lease your personal information to third parties for marketing purposes.

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### 3. Third-Party Service Providers & Cross-Border Data

To deliver high-performance mobile software, we partner with trusted infrastructure and service providers:
* **Backend & Authentication Infrastructure:** Supabase (for database storage and secure user authentication).
* **App Build & Distribution Tools:** Expo, Apple App Store, and Google Play Store.

By submitting information to Kolhsys or using our mobile software, you consent to the cross-border transfer and storage of data on secure servers managed by our trusted cloud service infrastructure providers, consistent with applicable laws and security standards.

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### 4. Account and Data Deletion (Your Rights)

You have full control over your personal data:
* **In-App Account Deletion:** You can permanently delete your account and clear all associated app data at any time directly within the Subly app by navigating to **Settings → Account → Delete Account**.
* **Manual Data Request:** You may also request access to, correction of, or complete removal of your personal information by emailing us at  admin@kolhsys.com. Upon receiving your request, we will delete your account and associated personal data from our active databases within 30 days.

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### 5. Data Security

Kolhsys maintains reasonable physical, administrative, and technical safeguards to protect your personal information against unauthorized loss, misuse, access, disclosure, alteration, or destruction. All data transmitted between our mobile apps and backend services is encrypted in transit using industry-standard SSL/TLS protocols.

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### 6. Children's Privacy

Our mobile applications and services are not directed at children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us at  admin@kolhsys.com  so we can promptly remove it.

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### 7. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us:

**Kolhsys Pty Ltd**  
Email: admin@kolhsys.com  
Website: https://kolhsys.com