Privacy Notice

Privacy Notice

Last updated on November 24, 2025

Key Changes to the Terms of Service and Privacy Notice for Documents
At Readdle, we care about our users, and, as Documents evolve, we amend our Terms of Service and Privacy Notice accordingly.

In a nutshell, we introduced the provisions related to:

  • Documents for Web: The biggest update is the launch of our new web application. You can now access some Documents features from any major web browser.
  • Cross-Platform Accounts: We are introducing a single, cross-platform Account that allows you to sign in and use the service seamlessly across your Mac, iPhone, iPad, and the web.
  • Synced Subscriptions: Your paid subscription is now linked to your Account, so your premium access automatically syncs across all your devices.
  • Direct Website Purchases: You can purchase a cross-platform subscription directly from our website and request a refund within 30 days of the purchase.
  • New Terms for Business Customers: We have added a new section with specific terms for companies and organisations using Documents for their internal business needs.

A Note on Our Web App Launch: For an initial period of 60 days following the publication of these updates, we are providing free access to the new Documents web application. During this period, your accounts and subscriptions will not be synced across platforms. However, your use of the web application will be governed by the updated Terms of Service, with the exception of provisions related to payments and subscription sync and management.
Please note that we reserve the right to change the duration and terms of this introductory offer at any time, at our sole discretion.

We encourage you to carefully review the full text of the Terms of Service and Privacy Notice. The changes become effective as of the publication date above.

Intro

Readdle Limited (“Readdle” or “we”) welcomes you. We provide you with the “Documents” mobile, desktop, and web application (“App” or “Documents”) and related website services (collectively, the “Service”) 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 processed, and what happens when you use the Service.

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, please visit our Support page for more information about the Service or contact us.

Table of Contents

Intro

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 Features Data

General

VPN

AI Features

Support Requests Data

Requests submitted via email or form

Requests submitted via support chat

Feedback 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

ControllerReaddle Limited Company number: 630281 Glandore Business Centres, 26-27 Fitzwilliam Place, Fitzwilliam Hall, Dublin 2, D02T292, Ireland
Data Protection OfficerPrivacity GmbH Neuer Wall 50, 20354 Hamburg, Germany
Emailrdsupport@readdle.com – for general inquiries
dpo@readdle.com – for privacy inquiries

Our support team is happy to assist you with any issue related to the use of the Service. 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 access the Service, 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 access the Service. Please review the details provided below carefully.

You have the option to modify your personal data, 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, interactions with the Service 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 Service, depending on how you interact with it, what features you use, and what subscription you have.

Technical Data

We collect identifiers, technical information, usage, and diagnostics data about the Users to optimize performance, debug issues, and improve our Service while ensuring security and privacy to improve the overall user experience.

DataReasons for ProcessingLawful BasisData Storage
User IDProviding you with the ServicePerformance of the contractWe store the data during your use of the Service and for six (6) years after you stop activities in the App or until your account deletion
Device info (device ID, IP address, device settings, name, local time, country and city, language, and other characteristics)
Crash and error logs
Device info (model, device ID, version of iOS, iPadOS, or macOS, time zone, country and/or city, language, connection type, сarrier, type of Central Processing Unit (CPU), free disk space, battery level, screen resolution, paired Apple Watch model (if any) and watchOS version)Providing you with the Beta OfferingsPerformance of the contractWe store the data during your use of the Betta Offering and for one (1) year after its termination
Interaction with the Service (invitation type, status of your invitation, App name and version, App uptime, number of installs, sessions, and crashes, symbolicated crash logs)
Device info (device ID, IP address, phone settings, name, local time, country and city, language, and other characteristics)Improvement of the ServiceLegitimate interestWe process the data until you object to the processing where we have your email and can identify you or until you delete your account
Analytics ID
Interactions with the Service, its screens and features (e.g. activation of the feature, activation of the trial, tapping a push notification)
Crash and error logs

Information about you

Before you access the Service, we may request some personal information to assist us in enhancing the Service. Additionally, we might ask for your email address to contact you regarding the Service.

You have the option to create an account with Documents to access web application and 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.

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.

For marketing activities, we utilize tools provided by social media platforms like Meta that allow us to create lookalike audiences. Meta only uses your hashed email to identify other Meta users with similar characteristics and interests and doesn't keep your actual email. Please note that we do not conduct any profiling or derive any specific characteristics about users. The data is analysed in general. This helps us show our ads to people who might be genuinely interested in our products or services. You can manage your ad preferences directly within your Meta account settings. Learn more by following this link.

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

DataReasons for ProcessingLawful BasisData Storage
Field of activity Files preferences Necessary functionsImprovement of the ServiceLegitimate interestWe store the data until you object to the processing where we have your email and can identify you or until you delete your account
EmailProviding you with the ServicePerformance of the contractWe store the data until you delete your account
Providing you with the Beta OfferingsPerformance of the contractWe store the data during your use of the Beta Offering and for one (1) year after its termination
To contact you regarding custom pricing and subscription per your requestLegitimate interestWe process the data in such a way until you object to such processing
To inform you about major events and special offers of the company and its partnersLegitimate interestWe process the data in such a way until you unsubscribe or delete your account
Marketing activitiesLegitimate interestWe process the data in such a way until you unsubscribe or delete your account
To send you tips, promotions and marketing communicationsConsentWe store the data until you unsubscribe or delete your account
NameProviding you with the ServicePerformance of the contractWe store the data until you delete your account
Providing you with the Beta OfferingsConsentWe store the data until you withdraw your consent or during your use of the Beta Offering and for one (1) year after its termination
To contact you regarding custom pricing and subscription per your requestLegitimate interestWe process the data in such a way until you object to such processing
PhotoProviding you with the ServicePerformance of the contractWe store the data until you delete your account
CompanyTo contact you regarding custom pricing and subscription per your requestLegitimate interestWe process the data in such a way until you object to such processing

Payments data

We collect some additional data to process your payments.

We charge you for premium subscriptions and paid features through the App Store or other payment systems.

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.

DataReasons for ProcessingLawful Basis
Subscription and payment information: email charging platform name information about the payment subscription start and expiration dates chosen payment plan subscription status trial status status of the subscription autorenewalConfirming the payment for compliance with the applicable lawLegal obligation
Confirming the payment for providing you with the paid features of the AppPerformance of the contract
Data Storage
We store the data during your use of the Service and six (6) years after the termination of the agreement between Readdle and you

Content and Features Data

General

Our App provides you with a broad range of features. You may upload, organise, create, or edit different kinds of documents or content. You may also transfer files between devices or sync with different cloud storages. Further, the App allows you to protect certain files with a password or sign documents.

Depending on the feature you use, we can request access to your camera (to take a photo, scan a document or signature, and connect to a computer via a QR code, etc.), photo gallery, files or your microphone to enable sound annotations in PDF files.

DataReasons for ProcessingLawful BasisData Storage
FilesProviding you with the ServicePerformance of the contractWe do not usually store your data. However, the files are temporarily stored for up to eight (8) hours for the file conversion functionality.
Image from your device’s camera (if the permission is granted)We do not store your data.
Hand pose and gestures, fingers’ coordinates in the space
Audio stream from your microphone (if the permission is granted)
Password for PDFs
Files metadata (format, size, number of pages etc.)
Signature
Files metadata (format, size, number of pages etc.)Improvement of the ServiceLegitimate interestWe store the data until you object to the processing where we have your email and can identify you or until you delete your account

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.

DataReasons for ProcessingLawful BasisData Storage
Phone settingsProviding you with the ServicePerformance of the contractWe store the data during your use of the App
IP address

AI Features

To offer certain features, we may use AI models that operate locally on your device and/or provided by third-party AI providers such as Azure OpenAI Service by Microsoft Corporation, OpenAI by OpenAI LLC, Claude by Anthropic, and Vertex AI by Google. For seamless service delivery, we may manually switch between these AI providers. Please note that data processing rules and interaction protocols will remain consistent even if we switch between the AI providers.

AI features are turned off by default. You may activate them for a specific file working with it. For example, you may use Audio or Video Transcribe only for a specific audio or video file.

We do not use your data to train any AI model. AI providers may only retain your inputs for up to thirty (30) days as part of their abuse and misuse monitoring. After this period, they delete the inputs automatically unless a longer retention period is required by law.

Occasionally, the AI models can make mistakes. Please note that we do not control the file content or influence the data included in the outputs.

Depending on the specific feature and your request, we may process the data listed below:

DataReasons for ProcessingLawful BasisData Storage
Audio stream of the audio file Audio stream extracted from the video file Text transcription of the audio stream FilesProviding you with the ServicePerformance of the contractWe do not store your data

Support Requests Data

When you address your request for support, we collect some information to help you.

We may also 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.

To enhance your experience, we may offer the option of using AI-powered assistance from a trusted provider. In this case, you can get quick, automated responses to your inquiries. No data will be used for training. Still, you can always choose to continue the chat without AI if you prefer so.

We may also collect analytics on request categories to improve our services and responses.

To process and analyse your requests more efficiently, we may engage trusted AI providers. Before proceeding with these providers, we always take necessary technical and organizational precautions, including pseudonymisation, data minimization, conducting data protection impact assessments, and establishing data processing agreements. No data is used for training.

Requests submitted via email or form

DataReasons for ProcessingLawful BasisData Storage
EmailTo fulfill your support requestPerformance of the contractWe store the data during communication and for six (6) years after the last communication on the ticket.
Name
Type of device
Text of the request
Attached files
Logs
Privacy requests
If you contact us through our DPO mailbox, we will process your request with the help of Spark Mail.

Requests submitted via support chat

DataReasons for ProcessingLawful BasisData Storage
Messages and commands in the chat User ID and Chat ID Name and email Technical dataTo respond to your requestPerformance of the contractIf you submit your request to our support team, the data is stored during communication and for six (6) years after the last communication on the ticket If you use Support Chat but do not submit your request to our support team, the data is stored during communication and up to two (2) years after closing the conversation.
Interaction with the Support Chat User ID and Chat ID Technical dataImprovement of the ServiceLegitimate interestStored during communication and up to two (2) years after closing the conversation.

Feedback Data

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

DataReasons for ProcessingLawful BasisData Storage
EmailTo ask for your feedback or suggest participation in the users’ surveysLegitimate interestWe process data in this way until you unsubscribe
Data used for improvement of the Service

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

Feedback Provided to us Directly
DataReasons for ProcessingLawful BasisData Storage
Email Name or username Attachments and/or photos Other information about you, such as social handles, occupation etc.Communication regarding your feedback and consentLegitimate interestWe store the data for six (6) years from feedback or the last communication on feedback, or until you withdraw the consent
Improvement of the Service
Use in marketing activitiesConsent
Feedback, including text feedback, answers to the review forms, or feedback provided orally in the meeting Other information related to your feedback such as rating, the date of the feedback, etc.Improvement of the ServiceLegitimate interest
Use in marketing activities
Meeting recordsImprovement of the Service and/or use in marketing activitiesConsent
Feedback Provided via a Third-party Platform
DataReasons for ProcessingLawful BasisData Storage
First and last name or usernameTo use your feedback in our product development and/or marketing activitiesLegitimate interestWe store the data for two (2) years from feedback or the last communication on feedback
Text of the feedback
Screenshots and comments you share when providing feedback within the Beta OfferingsTo use your feedback in our product developmentLegitimate interestWe store the data during your use of the Beta Offering and for one (1) year after its termination

We may collect analytics on the categories of issues mentioned in the feedback to improve our services.

To process and analyse your requests more efficiently, we may engage trusted AI providers. Before proceeding with these providers, we always take necessary technical and organizational precautions, including pseudonymisation, data minimization, conducting data protection impact assessments, and establishing data processing agreements. No data is used for training.

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.

Third PartyPrivacy Documents
Hotspot ShieldPrivacy Notice
Convert APITerms and Privacy
AmplitudePrivacy Notice
TypeformPrivacy Policy
DropboxPrivacy Policy
Google DrivePrivacy Policy
OneDrivePrivacy
BoxPrivacy Notice
SparkPrivacy Policy
ApplePrivacy Policy

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.

Third PartyDescription
Analytics toolsWe use analytics tools to understand and promote our business.
ContractorsWe cooperate with contractors to operate, develop, and improve the features and functionality of the Service, fulfill your support requests, etc. We sign data processing agreements with them and impose various security measures to ensure your data is safe.
Services Documents usesWe use third-party services to provide you with the functionality of the Service.
Services our team usesWe use CRM systems, messengers, and other services in our organization to provide you with our services. To manage and fulfill privacy requests, we use: Spark for processing requests and communication with the user; Jira for internal tracking and timely involvement of responsible ones in the scope of the request.
State authorities, courts, law enforcement agencies, etcWe may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies: to comply with a government request, court order, or applicable law; to prevent unlawful use of the Service; to protect against claims of third parties; to help prevent or investigate fraud.
To get a detailed list of the third-party recipients of your personal data, contact us

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.

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), conduct monitoring security audits, 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. In case of the data deletion, the data are deleted from the backups within fourteen (14) days. Additionally, all our contractors are bound by contractual obligations that comply with 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:

Physical Measures
Limited Access to Premises
Organizational Measures
Policies and Instructions Password policy Monitoring and physical access policy Contractual obligations and corporate VPN Internal security policy Access control policyTransfer Protection Data Transfer Agreements Standard Contractual Clauses Data Privacy Framework
Contractor and Staff TrainingAgreements Non-disclosure Agreements Data Processing Agreements
Regular Access and Policy ReviewPrivacy Protection Privacy by design and by default Internal procedures for GDPR compliance
Code Review
Technical Measures
Encryption Technologies Encryption in transit and at rest Backup encryptionBackup Regular backup of the entire system Redundant operation of the critical services in multiple data centers controlled by a high-availability system
Multi-factor Authentication
Static Code AnalysisQuality Assurance
Vulnerability ManagementDependency and Supply Chain Vulnerability Check

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.

RightDescription
Right to accessYou can request an explanation of the processing of your personal data.
Right to rectificationYou can change the data if it is inaccurate or incomplete.
Right to erasureYou can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.
Right to restrict the processingYou may partially or completely prohibit us from processing your personal data.
Right to data portabilityYou can request all the data that you provided to us, as well as request to transfer data to another controller.
Right to objectYou may object to the processing of your personal data.
Right to withdraw consentYou can withdraw your consent at any time.
Right to file a complaintIf your request was not satisfied, you can file a complaint to the regulatory body.
To exercise your rights, contact us
For EEA residents: we will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.
For UK residents: we will answer your request within one month. If your request is not satisfied, you can submit a complaint at the Information Commissioner’s Office via number 0303-123-1113 or go online at www.ico.org.uk/concerns.

United States Residents

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

RightDescriptionArea
Right to accessYou can request an explanation of the processing of your personal data.California; Colorado; Connecticut; Indiana; Iowa;Montana; Tennessee; Texas; Utah; Virginia.
Right to correctYou can change the data if it is inaccurate or incomplete.California; Colorado; Connecticut; Indiana;Montana; Tennessee; Texas; Virginia.
Right to deleteYou can send us a request to delete your personal data from our systems.California; Colorado; Connecticut; Indiana; Iowa;Montana; Tennessee; Texas; Utah; Virginia.
Right to portabilityYou can request all the data you provided to us and request to transfer data to another controller.California; Colorado; Connecticut; Indiana; Iowa;Montana; Tennessee; Texas; Utah; Virginia.
Right to opt out of salesThe right to opt out of the sale of personal data to third parties.California; Colorado; Connecticut; Indiana; Iowa;Montana; Tennessee; Texas; Utah; Virginia.
Right to opt out of certain purposesThe right to opt out of processing for profiling/targeted advertising purposes.Colorado; Connecticut; Indiana; Montana;Tennessee; Texas; Utah; Virginia.
Right to opt out of the processing of sensitive dataThe right to opt out of the processing of sensitive data.California.
Right to opt in for sensitive data processingThe right to opt in before the processing of sensitive data.Colorado; Connecticut; Indiana; Montana;Tennessee; Texas; Virginia.
Right against automated decision-makingA prohibition against a business making decisions about a consumer based solely on an automated process without human input.California; Colorado; Connecticut; Indiana; Iowa;Montana; Tennessee; Texas; Virginia.
Private right of actionThe right to seek civil damages from a controller for violations of a statute.California.
To exercise your rights, contact us
We will answer your request within 30 to 60 days, depending on the state and legislative requirements. If your complaint is not satisfied, you can submit a complaint with the Federal Trade Commission.
Note: Some states do not have their own privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us.

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

RightDescription
Right to accessYou can request an explanation of the processing of your personal data.
Right to rectificationYou can change the data if it is inaccurate or incomplete.
Right to deleteYou can send us a request to delete your personal data from our systems. We will remove all data except what we are obliged to store in compliance with the law requirements.
Right to data portabilityYou can request all the data you provided to us and request to transfer data to another controller.
Right to object opt-outYou may object to the processing of your personal data.
Right to withdraw consentYou can withdraw your consent at any time.
Right not to be subject to automated decision-makingYou can object to being subject to automated-based processing to know if there are consequences concerning them due to such processing.
Right to lodge a complaintIf your request is not satisfied, you can file a complaint to the regulatory body.
To exercise your rights, contact us
We will answer your request within 30 days. If your complaint is not satisfied, you can submit a complaint to the Office of the Privacy Commissioner of Canada.

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 to reflect these modifications.

If we make substantial changes to the Privacy Notice or the Service 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 Service after these changes take effect, it will be considered that you have acknowledged and accepted the revised Privacy Notice.