Privacy Notice
PDF Expert App

Last updated: April 29, 2024

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.

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.

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.

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 may engage 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.

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

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

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.

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.

Under certain subscription plans, you may access additional AI Chat features.

The request within the AI Chat features is processed in three steps. First, we receive and pseudonymize your request. Second, we send it to the AI provider for processing. Third, we receive the output and provide the result back to you. Please note that we do not control or influence the data included in your requests or their results. 

We process your requests within the AI Chat features with the engagement of Azure OpenAI Service, by the Microsoft Corporation, as the main provider or OpenAI API, by OpenAI, L.L.C., as a backup. Specifically, we use OpenAI API when Azure OpenAI Service is unavailable or operates slowly. Additionally, we may use OpenAI API to run new versions of models until they are available in Azure OpenAI Service or for other commercially justifiable reasons. The switch between the providers is manual, and we retain full control over it. We will not provide notification about such switches. 

Please note that both Microsoft Corporation and OpenAI, L.L.C. commit not to use the data to train their models. They also retain the data sent within the request for abuse and misuse monitoring purposes for a maximum of 30 days, after which it is deleted, unless otherwise required by law.

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.

Feedback Providers' Data

We may reach out to request your feedback. Your insights are invaluable to us for enhancing the App and improving user experience.

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

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 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.

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:

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

United States Residents

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

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

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.