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Privacy Notice
PDF Expert App

Last updated: January 19, 2024



Key Changes to the Privacy Notice for PDF Expert App

At Readdle, we care about our users, and therefore, we have improved our Privacy Notice governing your use of PDF Expert App.

In a nutshell, we:

  • revised the structure of the Privacy Notice;
  • added information on the engaged Data Protection Officer;
  • clarified Free Users’ Data processing;
  • detailed data processing regarding the AI Chat feature;
  • detailed processing of the support requests.

We encourage you to carefully review the full text of the Pricacy Notice for the PDF Expert App. The abovementioned updates become effective as of the publishing date.


Intro

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

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

We collect your personal data when you use the App according to this Privacy Notice. When you use our website by following the link (“Website”), your personal data is processed in accordance with the Privacy Notice for PDF Expert Website.

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

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

Table of Contents

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

About Us

We are the controller of your personal data processed through PDF Expert. This means that we determine the purposes and means of personal data processing.

Controller Readdle Limited
Company number: 630281
Glandore Business Centre, Grand Canal House, 1 Grand Canal Street Upper,
Dublin 4, D04 Y7R5, Ireland
Data Protection Officer Privacity GmbH
Neuer Wall 50, 20354 Hamburg, Germany
Email rdsupport@readdle.com – for general inquiries
dpo@readdle.com – for privacy inquiries

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

About You

When you download PDF Expert, you become our user (“User”).

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

Data Subject Description
Free User User who uses the App for free
Paying User User who subscribes to PDF Expert Premium subscription, uses it via trial, or purchases paid features
Support Requester User who contacts customer support via the App
Feedback Provider User who provides feedback about the App to us directly or via a third-party platform
Please note! We do not knowingly process the personal data of Users under the age of 16. If you are such a User or you are a legal representative of such a User, please, contact us.

Personal Data

Sources of Data

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

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

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

Lawful Bases for Processing

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

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

Technical Data

We collect usage data about the Users to optimize performance and improve our App while ensuring security and privacy to improve the overall user experience.

Data Reasons for Processing Lawful Basis
Activation of a tool or feature Improvement of the App Legitimate interest
Interactions with payment, sign in, welcome screens
File open or close events
Installer events
Braze Pixel: creation date, account type, onboarding occupation, platform, language, purchase list Analytics Legitimate interest
Braze Pixel: marketing metrics Analytics Consent
Data Storage
We store the data until you delete your account or object to the processing / withdraw your consent

Free Users' Data

We collect Free Users’ personal data to provide you with the free functionality of PDF Expert, create an account for you, and personalize the App for your needs.

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

We also can request access to your camera to take a photo or scan of the document or signature.

Data Reasons for Processing Lawful Basis
Email To maintain your account Performance of the contract
Settings information To personalize the App for your needs Performance of the contract
Files Providing you with the functionality of the App Performance of the contract
Data Storage
Files We do not store your files
Other data We store the data during your use of the App and for 6 years after the termination of the agreement between Readdle and you

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

Data Reasons for Processing Lawful Basis
Files on the cloud of the third-party service Providing you with the functionality of the App Performance of the contract
Data Storage
We do not store your files

We may use your email to send you some useful information.

Data Reasons for Processing Lawful Basis
Email To communicate with you about the product (recommendations, tips, news) and share the company's news and offers Legitimate interest
Data Storage
We store the data during the performance of the contract or until you object the processing

If you use the App for iOS or iPadOS, we may ask you for some information about yourself to help us choose how to improve the App.

Data Reasons for Processing Lawful Basis
Field of activity Improvement of the App Legitimate interest
Necessary functions
Macbook possession
Data Storage
We store the data until you delete your account

Paying Users' Data

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

We charge you for premium subscriptions and paid features either through the Website or App Store. We describe how we process data concerning payments and activation of redeem codes on the Website in our Privacy Notice for PDF Expert Website. If you want to know how we process your data concerning payments in the App, continue reading this section.

To track and issue invoices on time, we process your receipt. The receipt is stored on your device. We receive only a hash (electronic value) to verify the transaction.

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

Data Reasons for Processing Lawful Basis
Subscription and payment information:
  • 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
Confirming the payment for providing you with the paid features of the App Performance of the contract
Data Storage
We store the data during your use of the App and 6 years after the termination of the contract between Readdle and you

Under certain subscription plans, you may access additional AI Chat features (please refer to our Terms of Service for further details).

We process your requests within these features through the GPT service provided by OpenAI. We divide this process into 3 steps. First, we receive and pseudonymize your request. Second, we send it to OpenAI for processing. Third, we receive the output from OpenAI and provide the result back to you.

Please note that OpenAI commits not to use the data to train its models as per Open AI’s Business Terms. You may also wish to check OpenAI Privacy Commitments and Data Processing Addendum for more details, including on data retention periods. Please note that we neither control nor influence the data included in your requests and/or their results delivered by OpenAI.

Data Reasons for Processing Lawful Basis
Text file Providing you with the AI Chat features Performance of a contract
Type and text of request
Email address
User ID
Technical data
Result of the requests
Errors
Type and text of the request Analytics and improvement of the feature Legitimate interest
Size if the response
Technical data
Errors
Data Storage
Data used only for providing you with the AI Chat features We do not store this data. After completion of your request, the data is deleted.
Data used for analytics and improvement of the feature We store this data until you delete your account or object to the processing.

Support Requesters' Data

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

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

Pay attention to our practice on the log files:

  • iOS or iPadOS – when you address your support request, you can choose whether to add detailed log files or not;
  • MacOS – when you address your support request, we collect your log files by default.
Data Reasons for Processing Lawful Basis
Text of the request. To fulfill your support request. Performance of the contract.
Attached files.
Logs.
Privacy requests
If you contact us through our DPO mailbox, we will process your request with the help of Spark Mail.
Data Storage
We store the data during communication and for 6 years after the last communication on the ticket.

Feedback Providers' Data

When you submit your feedback about the App to us directly or via third-party platforms, we process personal data in your feedback, which may include your first and last name, username, the text of the feedback, and/or any other information such as the feedback submission date, the rating which you assigned to the App, etc., contained in or related to the feedback.

Feedback Provided to us Directly
Data Reasons for Processing Lawful Basis
Email To respond to your feedback and ask for your consent Consent
First and last name or username To use your feedback in our marketing activities
Text of the feedback To use your feedback in our marketing activities
Data Storage
We store the data for 6 years from feedback or the last communication on feedback
Feedback Provided via Third-party Platform
Data Reasons for Processing Lawful Basis
First and last name or username To use your feedback in our marketing activities Legitimate interest
Text of the feedback. To use your feedback in our marketing activities
Data Storage
We store the data for 2 years from feedback or the last communication on feedback

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
Google Privacy Policy
iCloud Privacy - Apple
OpenAI Privacy Policy

Data Sharing with Third Parties

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

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

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 Website, fulfill your support requests, etc.

We sign data processing agreements with them and impose various security measures to ensure your data is safe.
Services PDF Expert uses We use third-party services to provide you with the functionality of the App.

For example, we use Open AI functionality to process your requests within AI Chat features. You can find Open AI’s privacy document following the link.
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:
  • Spark for processing requests and communication with the user;
  • Jira for internal tracking and timely involvement of responsible ones in scope of 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:
  • to comply with a government request, court order, or applicable law;
  • to prevent unlawful use of the Website;
  • 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 Sharing Outside the European Economic Area

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

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

To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient. 

If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.

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

Security Measures

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

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

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

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

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

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
Contractor and Staff Training Agreements
  1. Non-disclosure Agreements
  2. Data Processing Agreements
Regular Access and Policy Review Privacy Protection:
  1. Privacy by design and by default.
  2. Internal procedures for GDPR compliance
Code Review
Technical Measures
Encryption Technologies:
  • Encryption in transit
  • Backup encryption
  • State-of-the-art methods of cryptographic keys
Backup
  • Regular backup of the entire system
  • Redundant operation of the critical services in multiple data centers controlled by a high-availability system
Two-factor Authentication Stress-tests
Static Analysis Quality Assurance
Regular Patch Management Dependency and Supply Chain Vulnerability Check

Data Subjects Rights

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

European Economic Area and United Kingdom 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 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 you provided to us and 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 could 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 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! 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 have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.

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

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

Do-Not-Track Requests

California residents visiting the Website may request that we do not automatically gather and track information about their online browsing movements across the Internet.

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

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

Canada Residents

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 of 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 could 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. Existing laws and requirements for processing personal data are subject to change. Should this be the case, we will publish a new version of the Privacy Notice addressing such changes on our Website.

If we make substantial changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by email or display information on the Website and ask you to read it. We will notify you in advance, and, if you continue using the Website after the changes come into effect, it shall be deemed that you have agreed to and accepted the updated Privacy Notice.

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