Положення про конфіденційність
Останнє оновлення: 12 серпня 2026 р.
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 added details on the data processing in connection with the introduction of Readdle Accounts.
Readdle Accounts are not yet available and will roll out after the publication date above. We will notify you when they are available, via in-app notifications or other means as described in the Electronic Communications and Notices section of the Terms of Service.
We encourage you to carefully review the full text of the Privacy Notice.
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
- Personal Data in Documents
- Data Sharing with Third Parties
- Data Transfer Outside the European Economic Area
- Security Measures
- Data Subjects Rights
- Privacy Notice Updates
About Us
| Controller |
Readdle Limited Company number: 630281 Glandore Business Centres, 26-27 Fitzwilliam Place, Fitzwilliam Hall, Dublin 2, D02T292, Ireland |
||
| Data Protection Officer |
Privacity GmbH Neuer Wall 50, 20354 Hamburg, Germany |
||
|
rdsupport@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.
To help us with our marketing efforts, we may use an advertising identifier (IDFA) from your device. We will only do this if you agree. If you change your mind, you can easily stop this at any time by going to your device's Settings > Privacy > Tracking and switching off “Allow Apps to Request to Track”.
To understand how users interact with our app and to evaluate the performance of our marketing efforts on the Meta platforms, we use the Meta SDK. For these purposes, we collect specific event data, including app launch, trial initiations, and purchase events. Please note that we process this data in de-identified reports regarding app usage and marketing effectiveness.
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”).
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
User ID Device info (device ID, IP address, device settings, name, local time, country and city, language, and other characteristics) Crash and error logs |
Providing you with the Service | Performance of the contract | We 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 (model, device ID, version of iOS, iPadOS, or macOS, time zone, country and/or city, language, connection type, carrier, type of Central Processing Unit (CPU), free disk space, battery level, screen resolution, paired Apple Watch model (if any) and watchOS version) 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) |
Providing you with the Beta Offerings | Performance of the contract | We store the data during your use of the Beta Offering and for one (1) year after its termination |
|
Device info (device ID, IP address, phone settings, name, local time, country and city, language, and other characteristics) 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 |
Improvement of the Service | Legitimate interest | We process the data until you object to the processing where we have your email and can identify you or until you delete your account |
| Device identifiers for advertising (IDFA) | Measurement of the effectiveness of marketing activities | Consent | We store the data until you withdraw your consent or delete your Readdle Account |
Account data
You have the option to create a single personal account that works across Documents and other select Readdle applications (“Readdle Account”). Readdle Account is optional for using only the Documents mobile and/or desktop applications. However, it is required to access the App on the web or across multiple devices, as well as to activate the bundled subscriptions.
You can either register a Readdle Account by providing your email address or sign in using your Apple or Google account via Single Sign-on (SSO). Please note that if you created a Documents account before the release of the Readdle Account, it will be automatically converted into a Readdle Account starting on that date.
Below we provide the list of data used to create and maintain Readdle Account. It will be synced across the applications that support the Readdle Account.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
User ID Name Email address Device ID |
Providing you with the functionality of the App | Performance of the contract |
We store this data until your Readdle Account is deleted. Please note that name and email address may be used subject to provisions of the Information about you section. |
If you create a Readdle Account, you can delete it at any time through the App. Please note that deleting your Readdle Account may result in the immediate cancellation and loss of access to your active paid subscription and the account itself across other Readdle applications that support the Readdle Account.
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.
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.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Field of activity Files preferences Necessary functions |
Improvement of the Service | Legitimate interest | We store the data until you object to the processing where we have your email and can identify you or until you delete your account |
| Providing you with the Beta Offerings | Performance of the contract | We 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 request | Legitimate interest |
We process the data in such a way until you object to such processing If you have Readdle Account, we will store the data until your Readdle Account is deleted |
|
| To inform you about major events and special offers of the company and its partners | Legitimate interest |
We process the data in such a way until you unsubscribe If you have Readdle Account, we will store the data until your Readdle Account is deleted |
|
| Marketing activities | Legitimate interest |
We process the data in such a way until you unsubscribe If you have Readdle Account, we will store the data until your Readdle Account is deleted |
|
| To send you tips, promotions and marketing communications | Consent | We store the data until you unsubscribe or delete your account | |
| Name | Providing you with the Beta Offerings | Consent | We store the data until you withdraw your consent or during your use of the Beta Offering and for one (1) year after its termination |
| Name | To contact you regarding custom pricing and subscription per your request | Legitimate interest | We process the data in such a way until you object to such processing |
| Photo | Providing you with the Service | Performance of the contract | We store the data until you delete your Readdle Account |
| Company | To contact you regarding custom pricing and subscription per your request | Legitimate interest | We process the data in such a way until you object to such processing |
Payments data
We collect some additional data to process your payments. It is linked to your Readdle Account and may be synced across the applications that support the Readdle Account.
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.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
| 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 autorenewal) | Confirming the payment for compliance with the applicable law | Legal obligation | We store the data during your use of the Service and six (6) years after the termination of the agreement between Readdle and you |
| 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 autorenewal) | Confirming the payment for providing you with the paid features of the App | Performance of the contract | 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.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
| Files | Providing you with the Service | Performance of the contract |
We 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) 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 |
Providing you with the Service | Performance of the contract | We do not store your data. |
| Files metadata (format, size, number of pages etc.) | Improvement of the Service | Legitimate interest | We 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.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Phone settings IP address |
Providing you with the Service | Performance of the contract | We store the data during your use of the App |
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:
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Audio stream of the audio file Audio stream extracted from the video file Text transcription of the audio stream Files Files summary Technical data |
Providing you with the Service | Performance of the contract | We do not store your data |
| Files attached to your feedback regarding their summary | To fulfill your support request and/or process your feedback | Consent | We store the data for six (6) months or until you withdraw your consent, whichever occurs first |
| File summary in case of “thumb down” feedback | To fulfill your support request and/or process your feedback | Legitimate interest | We store the data for six (6) months or until you object to the processing, whichever occurs first |
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
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Name Type of device Text of the request Attached files Logs |
To fulfill your support request | Performance of the contract | We store the data during communication and for six (6) years after the last communication on the ticket. |
| Emotional sentiment of a request | To improve the App | Legitimate interest | We store the data during communication and for six (6) years after the last communication on the ticket. |
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
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Messages and commands in the chat User ID and Chat ID Name and email Technical data |
To respond to your request | Performance of the contract |
If 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 three (3) years after closing the conversation. |
|
Interaction with the Support Chat User ID and Chat ID Technical data |
Improvement of the Service | Legitimate interest | Stored during communication and up to three (3) 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.
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Data used for improvement of the Service |
To ask for your feedback or suggest participation in the users’ surveys | Legitimate interest | We process data in this way until you unsubscribe |
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
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
Name or username Attachments and/or photos Other information about you, such as social handles, occupation etc. |
Communication regarding your feedback and consent Improvement of the Service |
Legitimate interest | We store the data for six (6) years from feedback or the last communication on feedback, or until you object against processing |
|
Name or username Attachments and/or photos Other information about you, such as social handles, occupation etc. |
Use in marketing activities | Consent | We store the data for six (6) years from feedback or the last communication on feedback, or until you withdraw the consent |
|
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 Service Use in marketing activities |
Legitimate interest | We store the data for six (6) years from feedback or the last communication on feedback, or until you object against processing |
| Meeting records | Improvement of the Service and/or use in marketing activities | Consent | We store the data for six (6) years from feedback or the last communication on feedback, or until you withdraw the consent |
Feedback Provided via a Third-party Platform
| Data | Reasons for Processing | Lawful Basis | Data Storage |
|---|---|---|---|
|
First and last name or username Text of the feedback |
To use your feedback in our product development and/or marketing activities | Legitimate interest | We store the data for two (2) years from feedback or the last communication on feedback |
| Screenshots and comments you share when providing feedback within the Beta Offerings | To use your feedback in our product development | Legitimate interest | We store the data during your use of the Beta Offering and for one (1) year after its termination |
| Emotional sentiment of a request | To use your feedback in our product development | Legitimate interest | We store the data for two (2) years from feedback or the last communication on feedback |
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
| Data | Reasons for Processing | Lawful Basis |
|---|---|---|
|
To process your application and ensure that you are identified within the Community To share the tips, promotions, and send mailings within the Community affairs |
Performance of the contract | |
| To share the tips, promotions, and send mailings within the Community affairs | Legitimate interest | |
| Slack profile data, completed by you, including profile picture, other profile information | To facilitate communication and identify you within the Community | Performance of the contract |
| Slack usage and interaction metadata | To administer the Community | Performance of the contract |
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.
| Data | Reasons for Processing | Lawful Basis |
|---|---|---|
| Any contributions to the Community, including Development Feedback, messages, files, or other materials | To ensure the functionality of the Community and improve the App | Performance of the contract |
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.
| Data | Reasons for Processing | Lawful Basis |
|---|---|---|
| Files or their samples | To anonymise for further development and improvement of our other products | Consent |
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.
| Third Party | Privacy Documents |
|---|---|
| Hotspot Shield | Privacy Notice |
| Convert API | Terms and Privacy |
| Amplitude | Privacy Notice |
| Typeform | Privacy Policy |
| Dropbox | Privacy Policy |
| Google Drive | Privacy Policy |
| OneDrive | Privacy |
| Box | Privacy Notice |
| Spark | Privacy Policy |
| Apple | Privacy 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 Party | Description |
|---|---|
| Analytics tools | We use analytics tools to understand and promote our business. |
| Contractors |
We 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 uses | We use third-party services to provide you with the functionality of the Service. |
| Services our team uses |
We use CRM systems, messengers, and other services in our organization to provide you with our services. To manage and fulfill privacy requests, we use: (1) Spark for processing requests and communication with the user; (2) Jira for internal tracking and timely involvement of responsible ones in the scope of the request. |
| State authorities, courts, law enforcement agencies, etc |
We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies: (1) to comply with a government request, court order, or applicable law; (2) to prevent unlawful use of the Service; (3) to protect against claims of third parties; (4) 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 1. Password policy 2. Monitoring and physical access policy 3. Contractual obligations and corporate VPN 4. Internal security policy 5. Access control policy |
Transfer Protection 1. Data Transfer Agreements 2. Standard Contractual Clauses 3. Data Privacy Framework |
|
Agreements 1. Non-disclosure Agreements 2. Data Processing Agreements |
Privacy Protection 1. Privacy by design and by default 2. Internal procedures for GDPR compliance |
| Contractor and Staff Training | Regular Access and Policy Review |
| Code Review | |
| Technical Measures | |
|
Backup 1. Regular backup of the entire system 2. Redundant operation of the critical services in multiple data centers controlled by a high-availability system |
Encryption Technologies 1. Encryption in transit and at rest 2. Backup encryption |
| Multi-factor Authentication | Quality Assurance |
| Static Code Analysis | Dependency and Supply Chain Vulnerability Check |
| Vulnerability Management |
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.
| Right | Description |
|---|---|
| Right to access | You can request an explanation of the processing of your personal data. |
| Right to rectification | You can change the data if it is inaccurate or incomplete. |
| Right to erasure | You 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 processing | You may partially or completely prohibit us from processing your personal data. |
| Right to data portability | You can request all the data that you provided to us, as well as request to transfer data to another controller. |
| Right to object | You may object to the processing of your personal data. |
| Right to withdraw consent | You can withdraw your consent at any time. |
| Right to file a complaint | If 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.
| Right | Description | Area |
|---|---|---|
| Right to access | You can request an explanation of the processing of your personal data. | California, Colorado, Connecticut, Indiana, Iowa, Montana, Tennessee, Texas, Utah, Virginia. |
| Right to correct | You can change the data if it is inaccurate or incomplete. | California, Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, Virginia. |
| Right to delete | You 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 portability | You 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 sales | The 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 purposes | The 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 data | The right to opt out of the processing of sensitive data. | California. |
| Right to opt in for sensitive data processing | The right to opt in before the processing of sensitive data. | Colorado, Connecticut, Indiana, Montana, Tennessee, Texas, Virginia. |
| Right against automated decision-making | A 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 action | The 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.
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
| Right | Description |
|---|---|
| Right to access | You can request an explanation of the processing of your personal data. |
| Right to rectification | You can change the data if it is inaccurate or incomplete. |
| Right to delete | You 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 portability | You can request all the data you provided to us and request to transfer data to another controller. |
| Right to object opt-out | You may object to the processing of your personal data. |
| Right to withdraw consent | You can withdraw your consent at any time. |
| Right not to be subject to automated decision-making | You 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 complaint | If 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.