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and newsletter terms.

DATA POLICY AND NEWSLETTER TERMS

Last updated: June 7, 2026

This Data Policy explains how Subaka handles personal data through the website, newsletter, contact forms, pre launch access forms, member access pages, documentary archive, service requests, field recording archive, public communication and related digital services.

This page also explains the basic newsletter terms that apply when you subscribe to updates from Subaka.

Subaka is a practical safety, privacy, documentation, audio, living environment technology and digital media project connected to civilian field experience in Ukraine, lawful documentation work, sensitive archive material, practical support services, full spectrum audio recording, online publication and carefully managed member access.

Subaka handles personal data carefully because the work may involve sensitive situations, protected people, families, volunteers, frontline connected networks, field recordings, mission related material, public subscribers, paid members, private clients and people connected to the archive.

Who we are

Subaka is the controller for the personal data described in this Data Policy, unless clearly stated otherwise.

Website

https://www.subaka.com

Contact email

information@subaka.com

Public business mailing address

To be added after Dutch Chamber of Commerce registration.

Chamber of Commerce number

To be added after registration.

VAT number

To be added if applicable.

Do not send national identification numbers, passport numbers, BSN numbers, private medical files, classified information, operational military information, current frontline details, live location data, protected person details or highly sensitive personal data through public website forms.

Scope of this policy

This Data Policy applies to website visits, newsletter subscriptions, contact forms, pre launch access forms, service request forms, member access requests, paid member accounts after launch, public archive pages, members only documentary pages, full spectrum audio archive pages, embedded video and social media content, emails sent by Subaka, archive related communication, client intake communication and privacy related support requests.

This Data Policy does not replace the full Terms and Conditions for paid member access, service work, consulting work, field recording agreements or commissioned technical work. Separate terms may apply when paid access, services, consulting or field recording work opens.

Personal data Subaka may collect

Subaka may collect personal data when you use the website, subscribe to the newsletter, contact Subaka, request access, become a member, request a service, join a private intake or communicate about archive material.

This may include your email address, name if provided, message content, consent status for newsletter registration, date and time of subscription, IP address or technical registration data where needed for security or consent records, newsletter preferences, website usage data, member account data after launch, payment and invoice related data after launch, communication history and technical data such as browser type, device type and website logs.

For service requests, Subaka may also process practical information about your situation, requested support, safety needs, privacy concerns, home technology needs, archive questions, family coordination needs, documentation needs, audio project requests, living environment technology requests or other information that you choose to provide.

Subaka does not ask newsletter subscribers for national identification numbers, passport numbers, BSN numbers, Social Security numbers or similar identity numbers. If such information is sent through public forms without being requested, Subaka may delete it, restrict access to it or ask the sender to use a safer communication method.

Newsletter subscriptions

When you subscribe to the newsletter, Subaka uses your email address to send updates about the Subaka mission archive, public documentary stories, online launch information, YouTube and video updates, full spectrum audio projects, members only access information, paid membership availability, new chapters, publication updates, practical safety updates, privacy related announcements, archive related announcements and selected service updates.

You subscribe voluntarily. You can unsubscribe at any time by using the unsubscribe link in newsletter emails or by contacting Subaka directly.

Subscribing to the newsletter does not automatically create a paid membership, does not create a client relationship, does not give immediate access to protected archive material and does not guarantee access to members only content.

Newsletter subscribers may receive early launch information before the public members channel opens.

Legal basis for processing

Subaka processes personal data only when there is a lawful reason to do so.

For newsletters, Subaka relies on consent. For contact messages and service requests, Subaka processes data to respond to the request and to assess whether the matter is within scope. For paid member access, Subaka processes data to perform the membership agreement. For invoices, administration and tax records, Subaka processes data to comply with legal obligations.

For website security, fraud prevention, abuse prevention, service protection, archive protection and account protection, Subaka may rely on legitimate interests. For archive publication, documentary work, full spectrum audio publication and field recording material, Subaka assesses context, privacy, safety, consent, legitimate interests, legal obligations and the risk to people before publication.

Members only access after launch

When members only documentary access opens, paid members may need to create an account or complete a payment process.

For paid access, Subaka may process name, email address, account login data, subscription status, payment confirmation, invoice data, billing data, membership history and access logs for security and account management.

Subaka does not intentionally store full payment card details on its own website. Payment providers process payment data according to their own security and legal obligations.

Paid member access will be governed by the Terms and Conditions, Cancellation Policy and Data Policy available on the website at the time of purchase.

Documentary archive and protected material

The Subaka archive may include photos, videos, messages, notes, memories, field recordings, full spectrum audio, written records, mission related documentation and selected material connected to civilian field experience in Ukraine.

Not all archive material is public. Some material may be delayed, edited, anonymized, restricted, blurred, withheld or placed behind member access to protect safety, privacy and dignity.

Subaka aims to avoid unnecessary exposure of protected people, children, vulnerable persons, private addresses, sensitive locations, operational details, medical information, highly personal information, identifiable victim information, current frontline information and people who could be put at risk by publication.

The archive is not published for spectacle. It is published carefully, with attention to safety, context, privacy, dignity, documentary value and legal boundaries.

Full spectrum audio and field recording material

Subaka may collect, organize, process and preserve full spectrum audio recordings, including spatial recordings, environmental sound, low frequency movement, blast pressure, room response, infrastructure sound and other acoustic material from high pressure environments.

Where legally permitted and properly authorized, this may include field recordings from active war zones or high risk environments, including material recorded with trusted Ukrainian brigade contacts, civilian partners, journalists, volunteers or approved organizations.

These recordings are sensitive. They may contain location risk, operational risk, personal data, voices, identifiable background information, metadata, timestamps, environmental clues or information that could endanger soldiers, civilians, volunteers, families or protected people.

Before publication or sharing, field recording material must be reviewed for privacy, consent, safety, metadata, location risk, operational risk and legal permission. When material is recorded with brigade assistance or partner involvement, ownership, storage, access, review rights, public release rules and security boundaries should be agreed in advance.

Subaka does not use field recordings for real time battlefield intelligence, target detection, weapon targeting, fire correction, surveillance, tactical planning, enemy location analysis, troop movement tracking, drone detection for battlefield use, artillery correction, route planning or combat support.

Contact forms and messages

If you contact Subaka through a form or email, Subaka uses the information you provide to respond to your message, assess the request, prepare a reply, protect the service and keep appropriate records.

Please do not send sensitive mission information, private addresses, identification numbers, medical details, current operational details, live location data or protected person information through public forms.

If you send sensitive information anyway, Subaka may delete it, restrict it, refuse to process it or ask you to use a safer communication method.

Client intake and service requests

If you request a paid service, practical support, privacy support, home technology support, documentation support, audio support, living environment technology support, emergency planning support, cannabis route preparation support or other Subaka service, Subaka may process the information needed to understand the request, define scope, assess risk, provide pricing, prepare an agreement, deliver the work and keep legally required records.

Subaka may refuse requests that are unsafe, illegal, unclear, misleading, medically inappropriate, reputationally risky or outside scope.

Subaka does not request more information than needed for the purpose of the work. Sensitive information is handled carefully and only shared where needed, where lawful and where appropriate for the agreed purpose.

Cookies, analytics and embedded content

The website may use cookies or similar technologies for basic functionality, security, analytics, video embeds, member access, payment flow, website performance and abuse prevention.

Functional cookies may be needed for the website to work properly. Some analytics, tracking or marketing cookies may require consent, depending on how they are used. Where cookie settings are available, users can manage their choices through the website cookie settings. Users can also manage cookies through their browser settings.

Embedded content from platforms such as YouTube, video platforms, social media platforms, payment providers or external media tools may collect technical data when you interact with that content. These external platforms may apply their own privacy policies.

Processors and service providers

Subaka may use trusted service providers to operate the website, newsletter, hosting, payments, analytics, embedded video, member access, domain services, email services, security, cloud storage, technical support and archive management.

These providers may process personal data only where needed to provide their services. Where required, processing agreements or contractual safeguards are used.

Possible service provider categories include website hosting providers, email marketing providers, payment providers, website builders, domain and email providers, analytics providers if enabled, video platform providers, cloud storage providers, archive tools, security services and technical support services.

International transfers

Some service providers may process data outside the Netherlands or outside the European Economic Area.

Where this happens, Subaka aims to use legally recognized safeguards, such as adequacy decisions, standard contractual clauses or other lawful transfer mechanisms.

Retention periods

Subaka keeps personal data only as long as needed for the purpose for which it was collected, unless a longer period is required by law or justified by legal, safety, documentary, archive or mission related reasons.

Newsletter subscription data is kept until you unsubscribe or until the list is cleaned. Contact messages may be kept for up to 24 months, unless longer retention is needed for legal, safety, archive, dispute, service or documentation reasons.

Member account data is kept as long as the account is active and for a reasonable period after closure. Payment and invoice records are kept according to Dutch legal and tax retention obligations.

Archive related material, documentary records, field recordings, mission records and related metadata may be kept longer when they have documentary, historical, legal, safety, evidence, public interest or mission related value. Sensitive archive material is reviewed carefully before public release.

Security

Subaka takes reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.

These measures may include access restrictions, account security, limited publication, secure service providers, data minimization, careful review before publication, restricted access to sensitive archive material, metadata review, role based access where possible and separate handling of sensitive field material.

No website, email system or online service can be guaranteed to be completely secure. Do not send highly sensitive information through public forms.

Your rights

Depending on the situation and applicable law, you may have the right to request access to your personal data, request correction of inaccurate data, request deletion of your data, object to processing, restrict processing, withdraw consent, request data portability and complain to the Dutch Data Protection Authority.

If you want to exercise your rights, contact Subaka by email at information@subaka.com.

Subaka may need to verify your identity before handling a request. Some requests may be limited where data must be kept for legal obligations, safety reasons, archive reasons, legal claims, documentary integrity or protection of other people’s rights.

Withdrawal of consent

You can withdraw newsletter consent at any time.

You can use the unsubscribe link in any newsletter email or contact Subaka directly. Withdrawal of consent does not affect processing that took place before the withdrawal.

Children

The website and newsletter are not intended for children under 16.

Subaka does not knowingly collect personal data from children through the newsletter. If a parent or guardian believes a child has provided personal data, they can contact Subaka and the request will be reviewed.

Archive material may involve children or vulnerable people only where there is a clear legal and ethical basis, and where publication has been reviewed carefully for safety, dignity and privacy. Subaka may blur, anonymize, restrict, delay or withhold such material.

Newsletter terms

By subscribing to the newsletter, you agree that Subaka may send you email updates about the mission archive, public stories, launch information, member access, full spectrum audio projects, documentary updates, privacy related announcements, safety related updates and related Subaka project updates.

You can unsubscribe at any time.

The newsletter is free unless clearly stated otherwise. Newsletter subscription does not guarantee access to paid members only content. Paid access will require a separate purchase or membership agreement after launch.

No sale of personal data

Subaka does not sell newsletter subscriber data, does not sell member data, does not publish private subscriber information and does not use subscriber data for unrelated third party marketing.

Subaka does not sell sensitive archive data, client intake data, protected person data, field recording metadata or private communication data.

Legal and safety limits

Subaka may restrict, refuse, delete or report information where required or permitted by law, where a request is unsafe, where information appears to involve illegal activity, where publication would endanger people, where operational information could put soldiers or civilians at risk, or where personal data has been sent without a proper basis.

Subaka does not provide emergency rescue, medical treatment, diagnosis, prescriptions, dosing advice, therapy, legal advice, legal representation, police work, official investigations, armed security, combat support, weapons support, tactical planning, intelligence operations, hacking, spyware, unauthorized access, account takeover, stalking, doxxing, intimidation, illegal tracking, surveillance, false documents, fake identities, fake evidence or fake stories.

Subaka also does not sell, supply, broker, import, export, cultivate, process, extract, store, transport, distribute, prescribe, dose or deliver cannabis, hash, THC products, CBD products, seeds, clones, plants, extracts or controlled substances.

Cannabis related data

Subaka may provide practical, legal and non medical support around regulated cannabis route awareness, documentation and preparation for conversations with doctors, pharmacists, insurers, legal professionals or regulators.

If you provide cannabis related information, Subaka may process it only for the purpose of documentation, preparation, communication, privacy support, legal boundary awareness, compliance awareness or patient route preparation.

Subaka does not provide medical cannabis advice, dosing schedules, product sourcing, supplier introductions, buyer introductions, import or export support, cannabis transactions or medical claims.

Do not send unnecessary medical information, controlled substance information, illegal transaction requests or product sourcing requests through public forms.

Changes to this Data Policy

Subaka may update this Data Policy when the website, newsletter, member access, service structure, archive, field recording work, legal requirements or service providers change.

The latest version will be published on this page.

Contact

For privacy questions, newsletter questions, data requests, archive related privacy concerns, field recording privacy concerns, member access questions or business communication, contact Subaka at:

information@subaka.com

Website:

https://www.subaka.com

Subaka

Practical safety, privacy and living environment technology