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Privacy Notice
PDF Expert App

Last updated: September 16, 2024



Key Changes to the Terms of Service and Privacy Notice for PDF Expert App

At Readdle, we prioritize our users, and, as PDF Expert evolves, we amend our Privacy Notice accordingly.

In a nutshell, we:

  • revised the structure of the Privacy Notice;
  • updated the list of personal data we process; and
  • clarified our processing practices.

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

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

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”), 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 such a User or you are a legal representative of such a User, please contact us.

Personal Data

Sources of Data

We collect data about you when you download our App and interact with it, depending on your actions within the App. Please carefully review the details provided below.

You have the option to modify your personal data within the App, 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 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, 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 PDF Expert

We collect your personal data according to this Privacy Notice when you use the App, 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 App while ensuring security and privacy to improve the overall user experience.

Data Reasons for Processing Lawful Basis Data storage
User ID Providing you with the functionality of the App Performance of the contract We store the data during your use of the App and for six (6) years after you stop activities in the App
Device info (device ID, IP address, phone settings, name, local time, country and city, language, other characteristics)
Analytics ID Improvement of the App Legitimate interest We store the data until you object to the processing where we have your email and can identify you
Device info (device ID, IP address, phone settings, name, local time, country and city, language, other characteristics)
Interactions with the App, its screens, and features (e.g., activation of the feature, activation of the) trial

Information about you

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 Data storage
Email To maintain your account Performance of the contract We store the data during your use of the App and six (6) years after the termination of the contract between Readdle and you
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
To communicate with you about the product (recommendations, tips, news) and share the company's news and offers Legitimate interest We store the data during the performance of the contract or until you object the processing
Name Confirming the payment for compliance with the applicable law Legal obligation We store the data during your use of the App and six (6) years after the termination of the contract between Readdle and you
Confirming the payment for providing you with the paid features of the App Performance of the contract
Field of activity Improvement of the App Legitimate interest We store the data until you delete your account
Necessary functions
Macbook permission

Payments' Data

We collect some additional data to process your payments.

We charge you for 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, please 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 Data storage
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 We store the data during your use of the App and six (6) years after the termination of the contract between Readdle and you
Confirming the payment for providing you with the paid features of the App Performance of the contract

Content and App’s Features

We collect personal data to provide you with the functionality of PDF Expert depending on your subscription, create an account for you, and personalize the App for your needs.

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

Files Management

Data Reasons for Processing Lawful Basis Data storage
Settings and information Providing you with the functionality of the App Performance of the contract We store the data during your use of the App and for six (6) years after the termination of the agreement between Readdle and you
Files We do not store your files

Files Conversion

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

Data Reasons for Processing Lawful Basis Data storage
Files Providing you with the functionality of the App Performance of the contract We store your data for up to three (3) hours after uploading to the server

Account synchronization

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 Data storage
Files on the cloud of the third-party services Providing you with the functionality of the App Performance of the contract We do not store your files

AI Chat features

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 thirty (30) days, after which it is deleted, unless otherwise required by law.

Data Reasons for Processing Lawful Basis Data storage
Text file Providing you with the AI Chat features Performance of a contract We do not store this data. After completion of your request, the data is deleted
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 We store this data until you delete your account or object to the processing
Size if the response
Technical data
Errors

Support Requests' 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 Data storage
Email 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.
Name
Type of device
Text of the request
Attached files.
Logs.
Privacy requests
If you contact us through our DPO mailbox, we will process your request with the help of Spark Mail.

Feedback Data

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

Data Reasons for Processing Lawful Basis Data storage
Email To ask for your feedback or suggest participation in the users’ surveys Legitimate interest We process data in this way until you unsubscribe
Data used for improvement of the App

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 the data listed below. 

Feedback Provided to us Directly
Data Reasons for Processing Lawful Basis Data storage
Email To respond to your feedback and ask for your consent Consent We store the data for six (6) years from the feedback or the last communication on feedback, or until you withdraw the consent
First and last name or username To use your feedback in our product development and/or marketing activities, depending on your consent
Feedback, including text feedback, answers to the review forms, or feedback provided orally in the meeting
Date of the feedback
Assigned rating
Meeting records
Feedback Provided via Third-party Platform
Data Reasons for Processing Lawful Basis Data storage
First and last name or username 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
Text of the feedback.
Any other information contained in or related to your feedback such as the date of the feedback, rating you assigned etc.

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 Data Processing Addendum
Enterprise Privacy
Azure OpenAI Data, privacy and security

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 privacy laws. Additionally, we maintain organizational and technical measures to secure your personal data during its transfer to third parties. 

To share your data, we rely on the 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 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 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), utilize an alarm system, 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. Additionally, all our contractors are bound by contractual obligations that comply with the GDPR and other privacy legislation 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

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.

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 (1) 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 (1) 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 thirty (30) to sixty (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

Under the California Consumer Privacy Act (CCPA), California residents 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 top priority, and we are fully committed 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 how your personal data is processed.
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 could file a complaint to the regulatory body.
To exercise your rights, contact us.
We will answer your request within thirty (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

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 in our App to reflect these modifications.

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

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