Privacy Notice
for Documents

Last updated: February 19, 2025

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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 outlines the types of personal data the App collects, details how it is stored, processed, and used, and explains the implications of your interactions with 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 recognize the importance you place on your privacy and value the trust you have in us. To honor that trust, we implement the latest data security standards, enhance our understanding of privacy issues, and ensure compliance with the General Data Protection Regulation and other applicable privacy laws.

If you have any questions or comments about this Privacy Notice, please visit our Support pagefor 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
  • Information about You
  • Payments Data
  • Content and Apps' Features
    • Files' Management
    • Files' Synchronization
    • Transfer of Filles
    • VPN
    • Air Gestures
    • Audio/Video Transcribe
    • Smart Eraser
  • Support Requests Data
  • Feedback Data
  • Data Received from Third Parties
• Data Sharing with Third Parties
• Data Transfer Outside the European Economic Area
• 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 with any issue related to the use of the App. We kindly request that you maintain politeness and calmness in your communications with us, as we may not respond to offensive emails or messages.

About You

When you use Documents, you become our user (" User"), and we collect and process some of your personal data.

Please note that we do not knowingly process the personal data of Users under the age of 16. If you are under 16 or you are a legal representative of such a person, please contact us.

Personal Data

Sources of Data

We collect data about you when you download our App and interact with it based on your activities within the App. Please review the details provided below carefully.

You have the option to modify your personal data within the App, either by exercising your right to rectification or through the App's functionalities. Please be aware that the same lawful bases and storage durations apply to the updated 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 one of 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 and security, 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, depending on how you interact with it, what features you use, and what subscription you have.

Technical Data

When you use the App, we collect certain technical data.

Information about you

Before you access the App’s features, we may request some personal information to assist us in enhancing the App. Additionally, we might ask for your email address to send you useful information about the App.

We also process your email address to prevent abuse of licenses obtained through the Apple Volume Purchase Program (VPP), as part of our commitment to ensuring the integrity of our services. This processing helps us monitor and mitigate potential fraudulent activities associated with the use of the App.

You have the option to create an account with Documents to access additional functionalities for registered users. You can either register an account by providing your email address or sign in using your Apple or Google account via Single Sign-on (SSO). If you choose to create an account, it can be deleted at any time through the App, provided there is no active subscription associated with it.

From time to time, we may also offer certain Beta Offerings according to our Terms of Service.

Payments Data

We collect some additional data to process your payments.

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

We maintain a history of payments because it is a legal requirement. We store this information as mandated by law and cannot delete it until the legally required retention period expires.

Content and App's Features

Files' management

You may upload, organise, create or edit different kinds of documents or content. You may also protect some files with a password or sign the documents.

While using a scanning or photo feature, we can also 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.

Files' synchronization

We offer you the option to link accounts from third-party services (such as Apple or Google) for integration and synchronization of your files.

Transfer of files

We offer data transfer functionality. Using Wi-Fi, you can seamlessly transfer files and photos between your computer and your iPhone or iPad—and vice versa. Please be aware that all user data is transmitted exclusively over the local network and is never uploaded to our or any other server.

VPN

To enhance your security and anonymity while using the Internet, we have integrated a VPN feature. When the VPN is enabled, your IP address will be altered. You have the option to connect to a random server or select a specific one of your choice.

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. Please 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 framework technology to facilitate hand gesture recognition. The technology functions by detecting hand-raising gestures and analyzing the hand pose 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. These coordinates are processed exclusively on your device and are automatically deleted once the processing is complete.

Audio/Video Transcribe

The App offers Audio/Video Transcribe feature to transcribe speech into the written text.

By default, this feature is turned off and can be enabled via the file's context menu. Upon its first use, the app downloads the AI model required for this functionality from Apple's servers. The transcription algorithm operates directly on your device, ensuring that no data is collected or transmitted externally. After the transcription process is completed, the model stops running. Additionally, any service data generated by the model during transcription is immediately erased once the App saves the text file with the transcription results (this includes the extracted audio file if you transcribe a video). The model is subsequently stored on your device and can be used again for transcribing audio or video files through the file's context menu whenever needed.

We do not utilize the user’s data for learning purposes and do not retain or back up any transcription data when the Audio/Video Transcribe feature is on.

Occasionally, the AI model may make errors in transcription, particularly with languages other than English or when the audio clarity is poor. Additionally, the model does not have restrictions on transcribing content that includes obscenities or various speech styles.

Smart Eraser

The App offers the Smart Eraser feature to remove unwanted objects from the images.

By default, this feature is turned off. Upon its first use, the App downloads the AI model required for this functionality. The algorithm operates directly on your device, ensuring that no data is collected or transmitted externally. It accesses and processes only the image you explicitly choose. Once the erasure process is completed, the model stops running. It is subsequently stored on your device and can be used again through the menu whenever needed.

The feature does not intentionally restrict the size, format, or content of the images it processes. However, there are unspecified technical limitations on the maximum allowable image size, which depend on the characteristics of a particular device and cannot always be predicted.

The output is always saved as a copy of the original file. Also, the output file format will be preserved only for jpeg, png, or heiс files. All other formats will be converted and saved as jpeg.

Occasionally, the AI model may make errors. The model is sensitive to how an object for erasing has been masked, and it tends to produce both good and bad results depending on the input.

We do not use the user’s data for learning purposes and do not retain or back up any images when the feature is on.

Support Requests Data

When you address your request for 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, such as emails, text prompts, file names, etc.

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 Data

Where we have your email, we may reach out to request your feedback. Your insights are invaluable to us for enhancing the App and improving user experience.

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 may share your personal data with third parties without causing you any harm and in strict compliance with applicable laws. Additionally, we have put in place organizational and technical measures to secure your personal data during its transfer to third parties.

To share your data, we rely on the following lawful bases, such as consent, compliance with the law, and performance of a contract, depending on the specific circumstances.

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 routinely conduct Data Protection Impact Assessments to guarantee the implementation of adequate technical and organizational measures. These measures aim to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.

To enhance the protection of your personal data, we employ HTTPS and encryption, establish segmented group and individual access (as necessary), utilize an alarm system, implement a corporate VPN, and adhere to formally approved internal policies, including those for password management and physical access.

Furthermore, we consistently monitor the state of the art of our technologies and diligently maintain backups. Additionally, all our contractors are bound by contractual obligations that comply with GDPR requirements.

You can contact usin 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

As a data subject, you have the right to access, manage, and control your data either directly or by submitting a request to us. This section outlines these rights and explains how you can exercise them based on your place of residence.

United States Residents

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

Do Not Sell My Personal Information

California residents, under the California Consumer Privacy Act (CCPA), possess the right to opt out of the "sale" of their personal information by entities governed by the CCPA.

We do not sell your personal information to anyone, nor do we use your data as a business model. Ensuring your privacy is our utmost priority, and we are dedicated to safeguarding it.

We adhere to the CCPA by providing California residents the option to opt out of any potential future sale of their personal information. If you wish to register your preference that we do not sell your data in the future, please contact us at dpo@readdle.com.

Do-Not-Track Requests

California residents using our App have the option to request that we do not automatically collect and track information related to their online browsing activities across the Internet.

These requests can usually be made via web browser settings that manage signals or other mechanisms, enabling consumers to express their preferences concerning the collection of personal data about their online activities over time and across third-party websites or online services.

We currently do not have the ability to honor these requests. However, we may update this Privacy Notice as our capabilities evolve.

Canada Residents

Privacy Notice Updates

The Privacy Notice and the relationships falling under its effect are regulated by the General Data Protection Regulation. Please note that laws and requirements for processing personal data can evolve. In the event of changes, we will release an updated version of the Privacy Notice in our App to reflect these modifications.

If we make substantial changes to the Privacy Notice or the App that affect your data privacy rights, we will notify you by email or display information in the App and ask you to read it. You will be notified in advance, and if you continue to use the App after these changes take effect, it will be considered that you have consented to and accepted the revised Privacy Notice.