Privacy Notice

Key Changes to the Privacy Notice for Documents

At Readdle, we care about our users, and, as Documents evolves, we amend our Privacy Notice accordingly.

In a nutshell, we clarified details on data processing in connection with the beta offerings.

We encourage you to carefully review the full text of the 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

• 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
  • Support Requests Data
  • Feedback Data
  • Personal Data in Documents Beta Community
  • 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
  • Canada Residents
• Privacy Notice Updates

About Us

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.

From time to time, we may offer certain users the opportunity to use and evaluate features and functionality designated as experimental, pilot, in development, etc. (“Beta Offerings”).

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.

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.

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.

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.

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:

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 collect analytics on request categories to improve our services and responses. Additionally, we may analyze the approximate emotional sentiment of your request to identify how your inquiry sounds. Such analysis may help us prioritize the responses and manage the requests more efficiently. No data is used for training.

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

For 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

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.

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

Feedback Provided via a Third-party Platform

We may collect analytics on the categories of issues mentioned in the feedback to improve our services. Additionally, we may analyze the approximate emotional sentiment of your feedback to identify how your inquiry sounds. Such analysis may help us manage the feedback more efficiently. No data is used for training.

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.

Personal Data in Documents Beta Community

Introduction

We operate a users’ community, “Documents Beta Community” (the “Documents Beta Community” or “Community”). You may read more about it and the terms of participation in the Documents Beta Community Terms. Participation remains entirely voluntary at all times.

This Section sets out how we process personal data in connection with the Community and should be read alongside the remainder of this Privacy Notice, which covers our data processing practices.

Third-Party Platforms

The Community is hosted and managed on Slack. By joining the Community, you are required to access and use the Slack platform. Use of Slack is subject to Slack's own Privacy Policy and Terms of Service, which we encourage you to review.

Personal Data Processing

In relation to the Documents Beta Community, we additionally process the personal data described below, depending on how you interact with the Community.

Connection and Interaction Data

Storage of Connection and Interaction Data

Such data will be processed until withdrawal from the Community or for as long as your Slack account remains active. Email communication based on the legitimate interest can be stopped upon receipt of an opt-out request sent via email.

Communications and Development Feedback Data

You can communicate with other members of the Community through channels, threads, or direct messages within the Slack workspace. Please remain mindful of whether the information you share is public or private, and ensure you trust the sources provided by the moderators. We encourage active participation, including private messaging; however, please be aware that the Community does not take responsibility for such personal interactions.

Development Feedback is treated in an aggregated, non-attributable manner where possible. Please note that the general “Feedback Data” section applies regarding the potential use of the feedback in marketing activities. We may ask for your consent for this purpose.

Storage of Communications and Development Feedback Data

Such data will be processed for the duration of the 2-year retention period established for the Slack workspace.

Use of Files for the Improvement of our Products

Subject to your consent, we may use files or samples of files to develop and improve our App and our other products, including AI features and underlying AI technologies, as well as internal automations and workflows. This may include optimising existing features, developing new ones, and refining the AI capabilities used for our products and internal workflows.

To transfer the files or their samples, you may attach them to the dedicated Slack channel.

The files or their samples will undergo anonymisation prior to use. You have the right to withdraw your consent at any time before the anonymisation process is complete by inquiring it in the dedicated Slack channel or by contacting us at dpo@readdle.com, whichever is easier for you. Once the files have been anonymised, we cannot identify you anymore, and such data cannot be considered personal data, so withdrawal will no longer be technically feasible.

Please remain mindful when sharing any files or samples, ensuring you only provide those you wish for us to use for the mentioned purposes.

Personal Data Deletion in Community

We are committed to upholding your data subject rights. If you withdraw from the Community or your Slack account is terminated, we will take reasonable steps to delete or anonymise your personal data in a timely manner, in accordance with the data storage periods or your data subject request.

However, the technical architecture of the Slack platform implies limitations beyond our direct control. They should not impact your privacy, but we would like to be transparent.

Slack stores messages within a thread-and-channel structure that links each message to its context. A complete deletion of all data attributable to a specific user — including messages others have replied to, quoted, or referenced — may not be technically feasible without disrupting the integrity of wider conversation threads. In such cases, we will delete or anonymise your data to the greatest extent possible, which may include removing your display name and profile information from the Community workspace, even where individual messages cannot be fully expunged.

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.

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:

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.

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.

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.

Please note that 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

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.