Privacy Notice
Documents

Last updated: December 11, 2023
Effective from: December 12, 2023

Intro

Readdle Limited (“Readdle” or “we”) welcomes you. We provide you with our application “Documents” (“App” or “Documents”), available on iOS and iPadOS, subject to the terms and conditions of our Terms of Service.

This Privacy Notice describes which of your personal data the App collects, how stores, processes, and uses it, and what happens when you use the App.

When you use our website by following the link (“Website”), your personal data is processed in accordance with the Privacy Notice for the Readdle Website.

We understand you care about your privacy, and we appreciate the trust you place in us. To justify that trust, we embed the latest data security standards, improve our awareness of privacy matters, and comply with the General Data Protection Regulation and other privacy laws.

If you have any questions or comments about this Privacy Notice, visit our Support page for more information about the App or contact us.

Table of contents

• About Us
• About You
• Personal Data
  • Sources of Data
  • Lawful Bases for Processing
• Personal Data in Documents
  • Technical Data
  • Free Users' Data
  • Paying Users' Data
  • Support Requesters' Data
  • Feedback Providers' Data
  • Data Received from Third Parties
• Data Sharing with Third Parties
• Security measures
• Data Subjects Rights
  • European Economic Area and United Kingdom Residents
  • United States Residents
  • Do Not Sell My Personal Information
  • Do-Not-Track Requests
  • Canada Residents
• Privacy Notice Updates

About Us

Our support team is happy to assist you in any matter. We kindly ask you to be polite and calm in your communication with us. Otherwise, we may not respond to offensive emails/messages.

About You

When you use Documents, you become our user ("User").

We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.

Personal Data

Sources of Data

We receive data about you when you download our App and interact with it, depending on your actions in the App. Please read carefully the details below.

You can change your personal data in the App by exercising your right to rectification or by the App functionality. Please note that the same lawful bases and storage terms apply to the changed data.

We may also, although we do not necessarily do so, receive data from third parties. It depends on your settings and the features you use.

Lawful Bases for Processing

To process your personal data, we rely on the following lawful bases:

• performance of the contract — for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract (mainly, the Terms of Service) with you;
• legal obligation — for the processing of data as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorized public body;
• legitimate interest — for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
• consent — for additional processing for specific purposes.

Personal Data in Documents

We collect your personal data according to this Privacy Notice when you use the App. Some of the data we collect automatically, such as the country the App is used in: we get this data based on the IP address or from the AppStore (we receive this information in a generalized form). 

Generally, all the data provided to us can either be linked to you or not (i.e., anonymized data).

Technical Data

When you use our App, we may collect some technical data. Pay attention to the fact that we collect your device’s name for security purposes.

Free Users' Data

Before using the App’s features, we may ask you for some information about yourself to help us choose how to improve the App.

We may ask you for your email to send you some useful information according to your answers.

We provide you with the possibility to link accounts from third-party services (Apple or Google) for integration and synchronization of data.

For greater security and anonymity when using the Internet, we have added a VPN. With VPN enabled, your IP address will be changed. A connection server can be random, or you can choose some specific one.

You may upload, create or edit different kinds of documents or content.

We provide you with the functionality for data transfer. With Wi-Fi, you can transfer files and photos from a computer to your iPhone or iPad and vice versa. Please note! All user data is transmitted exclusively over the local network and never gets to our or any other server.

While using a scanning or photo feature, we can request access to your camera to take a photo or scan of the document or signature and connect to a computer via a QR code. We also can request access to your microphone to enable sound annotations in PDF files.

While using Photo Actions on iOS, we can request access to your Photos to help you arrange your Photo library.

Air Gestures

The App offers an Air Gestures mode within its video player, allowing you to control the player solely through hand gestures, without requiring touch input. It is important to note that upon closing the App, the Air Gestures mode will deactivate automatically. You will need to manually re-enable this feature in the video player’s settings after reopening the App.

For this feature to function, we will request access to your device’s camera. The camera will be active while the Air Gestures mode is enabled within the video player. Upon exiting the video player, the Air Gestures mode will be temporarily paused.

The Air Gestures utilizes Apple's Vision framework technology to facilitate hand gesture recognition. This involves the processing of images from your device’s camera by Apple Inc. in accordance with Apple’s Terms and Conditions and Privacy Policy. The technology functions by detecting hand-raising gestures and analyzing the hand poses and the fingers coordinates within the captured images. Apple then provides the coordinates of your fingers to the App, which processes this data to execute specific commands, such as pausing a video, etc. 

Our App does not utilize your data for learning purposes. Additionally, we do not retain or back up any finger coordinates, hand gestures, or other images when the feature is on. The coordinates are processed solely within your device and are automatically deleted afterwards.

We also collect some analytics on how you use our App to assess the features and the App’s functionality.

Paying Users' Data

If you are a Paying User, we collect the same data as the Free Users’ Data and some additional data to process your payments.

We charge you for premium subscriptions and paid features through the App Store.

We also keep the history of payments, as this is a legal requirement, and we cannot delete this information until the filing of the annual accounts expires.

We also collect some information to provide you with the subscription features of the App.

Pay attention, that we use Convert API to convert your files. The Convert API does not read or collect file content, metadata, or other data from the uploaded files.

Support Requesters’ Data

When you address your request to support in the App, we collect some information to help you.

We may collect your detailed log files to help you with your problem. These log files may contain sensitive personal information and are connected to you.

Pay attention to our practice on the log files:

• detailed logging – when you address your support request, you can choose whether to add detailed log files or not;
• general logging – when you address your support request, we collect your log files by default.

Feedback Providers’ Data

When you submit your feedback about the App to us directly or via third-party platforms, we process personal data in your feedback, which may include data listed below:

Data Received from Third Parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the lawful bases for processing are determined by the respective privacy documents of these parties.

Data Sharing with Third Parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organizational and technical measures to ensure the security of personal data during data transfer to third parties.

To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.

Data Transfer Outside the European Economic Area

The personal data we collect is stored on the US servers, which participate in the Data Privacy Framework and European Economic Area (“EEA”) servers, which fall under the General Data Protection Regulation.

We may share personal data with the recipients in the USA and other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation. For example, we share some data with our contractors in Ukraine.

To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient. If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

You can read more detailed measures to protect your personal data here.

Security measures

We systematically perform Data Protection Impact Assessments to ensure that we use an appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of or access to personal data transmitted, stored, or otherwise processed.

To be more specific, to protect your personal data, we use HTTPS and encryption, divided group and individual access (where appropriate), an alarm system, corporate VPN, and written approved internal policies (like password policy and physical access policy).

Moreover, we systematically monitor our technologies’ state of the art and never forget about the backups. All our contractors are under contractual obligations compliant with the GDPR requirements.

You can contact us in case of any questions regarding security issues.

Here you can find information about the steps we mentioned above:

Data Subjects Rights

European Economic Area and United Kingdom Residents

You, as a data subject, have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.

United States Residents

Your rights vary depending on the state of your residency, as indicated below.

Do Not Sell My Personal Information

California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.

We neither sell your personal information to anyone nor use your data as a business model. Your privacy is our top priority and we are committed to protecting it.

However, we support the CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us via dpo@readdle.com.

Do-Not-Track Requests

California residents visiting our App may request that we do not automatically gather and track information pertaining to their online browsing movements across the Internet.

Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.

We currently do not have the ability to honor these requests. We may modify this Privacy Notice as our abilities change.

Canada Residents