Paperturn's Privacy Policy

 

Thanks for using Paperturn. This policy explains the what, how, and why of the information we collect when you visit our website, or when you use our Services. It also explains the specific ways we use and disclose that information. We value your trust and take your privacy extremely seriously!

 

1. DEFINITIONS WITHIN THIS POLICY

 Paperturn Service or Service (“Us”, “We”) 

That’s us! Our Service consists of our website (www.paperturn.com) and all of its associated features, functionalities and interfaces related to online flipbooks and digital publishing.

 

Content

Any flipbooks, PDFs, images, text, sound and other material that is posted to or accessed via the Paperturn Service.

 

Data Subject(s) (Also known as “You”, “Users” & “Viewers”)
In most circumstances that’s you, the User, a Paperturn client. You as an individual provide us with your personal data in order to use the services of Paperturn. Data subjects can also be “Viewers” - the people who read and interact with the flipbook Content you create.
 
Data Controller
In most circumstances, that’s us. We’re the individuals responsible for things like personal data collection in connection with creating an account, collecting consent, managing consent revocation, enabling right to access, etc. In certain circumstances, you as the User can also be a Data Controller when collecting and processing your Viewers’ Personal Data. We refer to these circumstances specifically in Section 7.
 
Data Processor
The Data Processor is a person or organization who processes your personal data as instructed by us for specific purposes - for example, our accountants, our marketing partners, our cloud service providers etc. In certain circumstances, we can be a Data Processor instead of a Data Controller. We refer to these circumstances specifically in Section 7. 

 
Personal Data (also referred to as “data”)
Any information relating to an identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
 
Usage Data
Information collected automatically through Paperturn (or third-party services employed by Paperturn), which can include: the IP addresses or domain names of the computers utilized by the Users who use Paperturn, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within Paperturn) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
 
Cookies
Cookies are small pieces of data that are downloaded to your computer or mobile device when you visit a website or application. For a full overview of cookies, please see our Cookie Policy. 
 
 

2. SCOPE

This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you, according to our Terms of Use. This Privacy Policy applies to all services offered by Paperturn ApS, represented digitally as www.paperturn.com (hereinafter “Paperturn”).

 

 3. TYPES OF DATA WE COLLECT 

a) Information you voluntarily provide to us: When you sign up for and use Paperturn, consult with our customer service or sales team, send us an email, fill out a lead form, send us a message in chat or communicate with us in any way, you are voluntarily giving us information that we collect. That information may include: your or your client’s name, physical address, email address, IP address, phone number, credit card information, as well as details including gender, occupation, location, purchase history, and other demographic information.

b) Information we collect automatically: When you use Paperturn, we may collect information about your visit to our site,  your usage of the Services, and your web browsing. That information may include: your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with Paperturn or other websites. We may collect this information through the use of cookies or other tracking technologies. See our Cookie Policy.

c) Information from your use of the Service: We receive information about how and when you use Paperturn. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve the services of Paperturn.

d) Cookies and tracking: Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information and data used for marketing and targeted advertising. You can see how we use cookies, which data we collect and change your preferences or opt out via our Cookie Policy.

 

e) Anonymous usage data: Paperturn collects anonymous usage data whenever a User or Viewer interacts with our Service, for example: number of views and downloads, type of device, type of browser, links clicked, geographic location and referral source.
 

4. WHAT WE USE YOUR DATA FOR

 We may use the Personal Information we collect through Paperturn or 3rd party sources for a range of reasons, including: 

 

• To provide our online flipbook service to you and your viewers.
• To bill and collect money owed to us by you.  This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. 
• To send you system alert messages. For example, we may inform you about temporary or permanent changes to our Services, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
• To communicate with you about your account and provide customer support.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support and improve Paperturn.
• For our data analytics projects. Our data analytics projects use data from Paperturn accounts and usage habits to provide and improve our services. We use this data so we can make more informed predictions, decisions, products and marketing offers for our users.
• For marketing & remarketing purposes. We may combine Personal Information with other information we collect or obtain about you (such as information we source from our third-party partners) to serve you specifically, such as to deliver a product or service according to your preferences or restrictions, or for advertising or targeting purposes in accordance with this privacy policy. When we combine Personal Information with other information in this way, we treat it as, and apply all of the safeguards in this privacy policy applicable to, Personal Information.
• Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.

5. OUR LEGAL BASIS FOR COLLECTING THIS DATA

 We legally collect and process your data under the following premises:

• When you give us explicit consent.
• In order for us to exercise our contract (provide Paperturn’s service to you).
• To comply with our legal obligations in Denmark and the EU.
• For the establishment, exercise or defence of legal claims, where necessary.

 6. RETENTION OF DATA

 For Users, we keep your Personal Data as described in the previous sections of this Privacy Policy as long as you have an active account with us. Once your account is deleted, we take steps to remove all of your personal data from our systems and 3rd party providers within 90 days (the “Buffer Period”). After the buffer period, all data is permanently and irrevocably deleted from our system, except for the data which is mandatory in order for us to comply with our legal, regulatory and taxation obligations. For Viewers, your personal data is permanently deleted from our system when the User deletes their account or the flipbook associated with your data input.

 

7. WHEN PAPERTURN’S USERS COLLECT PERSONAL DATA FROM THEIR VIEWERS

With some of Paperturn’s features (lead form / shopping cart), a Paperturn User is able to collect Data from their Viewers and download that collected Data in CSV format. In these instances, the Paperturn User becomes the Data Controller and Paperturn becomes the Data Processor. This is because the User exercises overall control of the purpose and means of the processing of the Data (they decide what to process from their Viewers and why), while Paperturn only facilitates the data collection from a technical perspective and acts on behalf of the User’s instructions.

 

As such, Users are responsible for having the appropriate permission and consent relevant to collect and process Data about their Viewers, as well as ensuring that their manner of processing the Data is consistent with this Privacy Policy.

 

If you are a Viewer who has voluntarily submitted Personal Data to one of our Users via these features, and wish to exercise any of your data rights (See Section 11 below), please contact the User directly. Should you contact us, we may remove or update your information within a reasonable time, after providing notice to the User of your request. 

 

We will only retain the Data we process on behalf of our User for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.

Types of personal data Paperturn Users may collect from their Viewers: 

 The Personal Data collected depends entirely on the fields the User is requesting for the Viewer to fill out; however, examples may include: the Viewer’s email address, full name, company, address, phone number etc. It is important to note that as a Viewer, you are not required to fill out any information, but rather, that submission of your information is voluntary and at your own discretion.

 

As a User, you should know that your usage of the Viewer’s collected Personal Information is limited to:

 

• facilitating the use of your services;

• sending informational or promotional messages;

• providing customer support;

• providing, supporting, and improving the services you offer.

 

Additionally, usage and storage of collected Personal Information is limited to the terms set out in this Privacy Policy. Any breach of such terms may result in Paperturn suspending your rights to use these data collection features, termination of your account or in some cases, legal action.

 

8. OUR THIRD PARTY PROVIDERS

 When we share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this privacy policy and applicable privacy laws.

 

Paperturn’s current list of Sub-Processors used to process Personal Data can be viewed here. 

9. PROTECTION OF DATA

 We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration.  The security measures include: firewalls, data encryption, dedicated servers, physical access controls to our data centers & offices, information access authorization controls, protection against script injection and A+ server SSL ratings.

 

While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.  We are not responsible for protecting any Personal Data that we share with a third-party - Please review their individual privacy policies for more information on their data protection efforts.

 

10. NOTICE OF BREACH OF SECURITY 

Every care is taken to protect your Personal Data from accidental or deliberate incidents that compromise security. In the unfortunate and unlikely event that a security breach causes an unauthorized intrusion into our system that materially affects you, we will notify both you and the relevant supervisory authority about the breach within 72 hours of becoming aware of it.  We will also inform you of the steps we’ve taken to remediate the breach at our earliest possible opportunity. 

 

11. USER RIGHTS  

As a data subject, you are entitled to eight (8) user rights under the GDPR. Information about how to manage your rights can be found in Section 12 below. In most cases we do not charge fees to comply with your requests; however, we will charge a reasonable fee for our administration costs if we deem your request to be manifestly unfounded or excessive. We will always inform you prior to completing your request if we will charge a fee. We also reserve the right to refuse to comply with manifestly unfounded or excessive requests. 

THE RIGHT TO BE INFORMED 
You have the right to be provided with information about our data processing activities. 

 

THE RIGHT OF ACCESS 

You have the right to know which personal data we collect from you. 

 

THE RIGHT TO ERASURE

You have the right to request the deletion of your personal data. 

THE RIGHT TO RESTRICT PROCESSING 

You have the right to restrict processing of personal data under certain circumstances. Should you exercise this right, we may not be able to provide a portion or entirety of our services to you.

THE RIGHT TO OBJECT

You have the right to object to the processing of your personal data. 

THE RIGHT TO RECTIFICATION

You have the right to rectify any inaccurate or incomplete personal data. 

   

THE RIGHT TO DATA PORTABILITY

Under certain circumstances, you have the right to copy, transfer or move your personal data. 

 

THE RIGHT TO AVOID AUTOMATED DECISION-MAKING

You have the right to be provided with safeguards against automated decision-making. As a responsible service, we do not use any automated decision-making or profiling.

 

12. HOW TO MANAGE YOUR DATA WITH PAPERTURN

How to exercise your data subject rights under the GDPR

Should you wish to exercise any of your data subject rights under the GDPR, click here. It is important to note that, in some situations, restricting or withdrawing your consent for us to process your data may result in reduced account functioning or inability for us to offer you our Service.

 

How to update your personal information

You can change or correct your personal / account information with Paperturn at any time by logging in to your Paperturn account & updating your information (*Please note, certain changes may affect the functioning of your account).

 

How to delete your data from Paperturn 

If you’d like to delete all of your data from Paperturn, you should simply delete your account. Please note, this action is irreversible and means you will have to delete your existing account and everything that is stored in your account (flipbooks). Once you delete your Paperturn account, we will take steps to remove your personal data from our systems and from 3rd party processors, within the timeframes stated in Section 6 (“Data Retention”).

 

How to opt out of email communications from Paperturn

As a Paperturn client, you receive two types of email communication from us - system emails and marketing emails. You can adjust or opt out of receiving marketing emails at any time by clicking on the unsubscribe button at the bottom of the marketing email you receive. Regarding our system emails, you are unable to opt out as they are required legal, payment or system notices in accordance with your use of Paperturn’s Service.

 

How to opt out of 3rd party processing

You can easily change your preferences or opt out of 3rd party processing when using our Service. You can do this via the cookie dialog box on our website, or by visiting our Cookie Policy and changing your consent.

 

13. REPRESENTATION FOR DATA SUBJECTS IN THE UK (UK GDPR)

We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please click here. 

 

 

14. PAPERTURN AND THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA,” as amended by the California Privacy Rights Act or “CPRA”.

Although the CCPA does not officially apply to Paperturn, as we do not fulfil one or more of the conditions outlined in the law, we are still committed to compliance, as outlined below.

California law requires that we detail the categories of personal information that we collect and disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in earlier sections of this Privacy Policy. We collect this information for the business and commercial purposes described in this Privacy Policy and we do not sell the personal information we collect, under any circumstances. 

We may also share personal information (in the form of identifiers and internet activity information) with third party advertisers for purposes of targeting advertisements on non-Paperturn websites, applications, and services. In addition, we may allow third parties to collect personal information from our sites or services if those third parties are authorised service providers who have agreed to our contractual limitations as to their retention, use, and disclosure of such personal information, or if you use our sites or services to interact with third parties or direct us to disclose your personal information to third parties.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use, disclose, or may sell this information), to delete their personal information, to opt out of any “sales”, to know and opt out of sharing of personal information for delivering advertisements on non-Paperturn websites, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA, which closely mirror rights under the GDPR, by filling out this form. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorised agent to exercise these rights on their behalf. Authorised agents must submit proof of authorization.

 

15. QUESTIONS & CONCERNS 

If you have any questions or comments, if you have a concern about the way in which we have handled any privacy matter or wish to exercise your privacy rights, please contact our Data Protection Officer (DPO) at dpo@paperturn.com. You can also send us a request via registered mail to:
 
Paperturn
Attn. Data Protection Officer
Klokkestøbervej 16
5230 Odense M, DENMARK

16. DATA PROCESSING ADDENDUM (DPA)

We provide all of our customers with the opportunity to sign a Data Processing Addendum (DPA) with us. Executing a DPA does not change any of our practices concerning the protection of your privacy and your data. Everyone using our service gets the same high standards of privacy and security. If you require an executed DPA with us, please sign here.

 

17. CHANGES TO THIS POLICY

We may change this Privacy Policy at any time and from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the Website signifies your continuing consent to be bound by this Privacy Policy. 
 
 
LAST UPDATED: 22.2.2023