PAPERANG

APP PRIVACY NOTICE

THIS NOTICE SETS OUT THE BASIS ON WHICH ANY PERSONAL DATA WE COLLECT FROM YOU, OR THAT YOU PROVIDE TO US, WILL BE PROCESSED BY US. PLEASE READ THE FOLLOWING CAREFULLY TO UNDERSTAND OUR PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE WILL TREAT IT.

1. INTRODUCTION

This Privacy Notice (together with our Terms of Service and App Terms and Conditions applies to your use of:

(a) the Paperang mobile/desktop application software (App), once you have downloaded or streamed a copy of the App onto your mobile device/computer (Device); and

(b) any of the services accessible through the App (Services).

2. IMPORTANT INFORMATION, WHO WE ARE AND HOW TO CONTACT US

2.1 XIAMEN PAPERANG TECHNOLOGY CO., LTD of Room 3124, Xuanye Building, Pioneer Park, Xiamen Torch High-tech Zone is the controller and is responsible for your personal data (we, us, our).

2.2 If you have any questions about this privacy notice, please contact them using the details set out below:

Email address:

service @paperang.com

 

2.3 You have the right to make a complaint at any time to the relevant data protection authority in your jurisdiction. The UK regulator for data protection issues is the Information Commissioner's Office (ICO).

3. CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy notice under regular review. This version was last updated on the date set out at the bottom of this notice. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you when you next start the App. The new notice may be displayed on-screen and you may be required to read and acknowledge you have read the changes to continue your use of the App and the Services. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

4. THIRD PARTY LINKS

Our App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

5. THE DATA WE COLLECT ABOUT YOU

5.1 We may collect, use, store and transfer different kinds of personal data about you as follows:

Type of data	Data collected
1. IDENTITY DATA	Username or similar identifier
	Date of birth
	Gender
	Other information such as time zone, IP and sim card region information and username, phone number and email address of the third-party account where you log in with a social media account (e.g. Facebook or Twitter)
2. CONTACT DATA	Email address
	Telephone numbers
3. DEVICE DATA	Type of mobile/computer device
	Device's IMEI, IMSI, device model number, unique device identifier, device Bluetooth information, Android ID, MAC address
	Mobile network information such as IP address, telecom operator, date and time of access
	Your mobile/computer operating system and version
4. CONTENT DATA	Login information
	Information stored on your Device, photos, videos or other digital content
5. PROFILE DATA	Username
	Password
	Feedback
6. USAGE DATA	Traffic data and other communication data
7. LOCATION DATA	Current location disclosed by GPS technology

 

6. HOW IS YOUR PERSONAL DATA COLLECTED?

We will collect and process the following data about you:

(a) Information you give us: This is any personal information you consent to giving us about you by filling in forms on the App or by corresponding with us (for example, by email or chat). It includes information you provide when you download and register to use the App or subscribe to any of our Services. This also includes when you report a problem with an App and if you contact us, we will keep a record of that correspondence.

(b) Information we collect about you and your Device: Each time you visit our website or use our App we will automatically collect personal data including Device, Content and Usage Data. We collect this data using cookies and other similar technologies (see “COOKIES”, below).

(c) Location Data: We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.

7. COOKIES

7.1 We use cookies and/or other tracking technologies to distinguish you from other users of the App and the distribution platform (Appstore) to remember your preferences. This helps us to provide you with a good experience when you use the App or browse our website and also allows us to improve the App and website.

7.2 We use session cookies which allow our site to link your actions during a particular browser session and which expire each time you close your browser and do not remain on your Device afterwards. We also use persistent cookies which are stored on your Device in between browser sessions and allow your preferences or actions across the site to be remembered. These will remain on your Device until they expire, or you delete them from your cache.

7.3 The cookies we use fall into the following categories:

7.3.1 Strictly necessary cookies: These cookies are essential for you to be able to navigate the site and use its features. Without these cookies, the services you have asked for could not be provided.

7.3.2 Performance cookies: These cookies collect information about how you use our site, e.g. which pages you go to most often.

7.3.3 Functionality cookies: These cookies allow the site to remember the choices you make (such as your user name, language, last action and search preferences) and provide enhanced, more personal features.

7.4 If you do not wish for cookies to be installed on your Device, you can change the settings on your browser or Device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.

8. HOW WE USE YOUR PERSONAL DATA

8.1 We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

8.1.1 where you have consented before the processing;

8.1.2 where we need to perform a contract we are about to enter or have entered with you;

8.1.3 where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;

8.1.4 where we need to comply with a legal or regulatory obligation.

See section 15: “GLOSSARY – LEGAL BASIS” for further information on these legal bases.

8.2 We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.

9. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

Purpose/activity	Type of data	Lawful basis for processing
To install the App and register you as a new App user	· Identity · Contact · Device	· Performance of a contract with you
To manage our relationship with you including notifying you of changes to the App or any Services	· Identity · Contact · Profile	· Your consent · Performance of a contract with you · Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services) · Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)
To administer and protect our business and this App including troubleshooting, data analysis and system testing	· Identity · Contact · Device	· Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
To deliver content and advertisements to you To measure and analyse the effectiveness of the advertising we serve you To monitor trends so we can improve the App	· Identity · Contact · Device · Content · Profile · Usage · Location	· Consent · Necessary for our legitimate interests (to develop our products/Services and grow our business)

 

10. DISCLOSURES OF YOUR PERSONAL DATA

10.1 We may share your personal information within our group of companies (i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006).

10.2 We may share your personal information with our suppliers, business partners and service providers, where they are helping us to market and advertise our services as well as providing our services to you. We may disclose your personal information to other third parties in the following cases:

10.2.1 for the purposes of research, evaluation, and analysis;

10.2.2 in the event that we sell any business or assets, in which case we may disclose your personal information to the prospective buyer of such business or assets;

10.2.3 if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers and visitors to our websites will be one of the transferred assets;

10.2.4 if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation or request; or

10.2.5 to protect the rights, property or safety of us or our users, or others, and in order to enforce or apply our terms and conditions (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

11. INTERNATIONAL TRANSFERS

11.1 Some of our external third parties are based outside the UK and/or EEA so their processing of your personal data will involve a transfer of data outside the UK and/or EEA.

11.2 Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

11.2.1 we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data;

11.2.2 where we use certain service providers, we may use specific contracts approved by the UK/EU which give personal data the same protection it has in the UK/EU.

11.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and/or EEA.

12. DATA SECURITY

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

13. DATA RETENTION

13.1 We take steps to ensure that the personal information that you provide is retained for only as long as it is necessary for the purpose for which it was collected. After this period it will be deleted or in some cases anonymised. For example, where you have made a purchase with us, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you (for example if you have made a complaint) for as long as is necessary to protect us from a legal claim.

13.2 In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further information.

13.3 In the event that you do not use the App for a period of 90 days then we will treat the account as expired and your personal data may be deleted.

14. YOUR LEGAL RIGHTS

Under certain circumstances you have the following rights under data protection laws in relation to your personal data. You also have the right to ask us not to continue to process your personal data for marketing purposes. You can exercise any of these rights at any time by contacting us at service@paperang.com. You have the right to:

(a) request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

(b) request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

(c) request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;

(d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

(e) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

(f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;

(g) withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

15. GLOSSARY – LEGAL BASIS

Consent	means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
Legitimate Interest	means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract	means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation	means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

THIS NOTICE WAS LAST UPDATED IN MARCH 2023.