Privacy Notice
Scanner Mini

Last updated: February 19, 2025

Key Changes to the Terms of Service and Privacy Notice for Scanner Mini

At Readdle, we prioritize our users, and, as Scanner Mini evolves, we amend our Terms of Service and Privacy Notice accordingly.

In a nutshell, we updated the address of Readdle Limited.

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

Intro

Readdle Limited (“Readdle” or “we”) welcomes you. We provide you with our application “Scanner Mini” (“App” or “Scanner Mini”) available on iOS and iPadOS, subject to the terms and conditions of our 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 Readdle 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.

About Us

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

Controller	Readdle Limited Company number: 630281 Glandore Business Centres, 26-27 Fitzwilliam Place, Fitzwilliam Hall, Dublin 2, D02T292, 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 Scanner Mini, 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 under 16 or you are a legal representative of such a person, please contact us.

Personal Data

Sources of Data

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

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 Basis 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 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 Scanner Mini

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 enhance features while ensuring security and privacy to improve the overall user experience.

Data	Reasons for Processing	Lawful basis	Data Storage
IP Address	Providing you with the functionality of the App	Performance of the contract	We store the data during your use of the App and for 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)	Providing you with the functionality of the App	Performance of the contract
Device info (device ID, IP address, phone settings, name, local time, country and city, language, other characteristics)	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
Analytics ID
Interactions with the App, its screens and features (e.g. activation of the feature, activation of the trial)

Information About You

Before you access the App’s features, we may request some personal information to assist us in enhancing the App. Additionally, we might ask for your email address to send you useful information about the App.

Data	Reasons for Processing	Lawful Basis	Data Storage
Field of activity	Improvement of the App	Legitimate interest	We store the data until you delete your account
Files preferences
Necessary functions
Email	To send you tips about the usage of the App	Consent	We store the data until you withdraw your consent
Email	To inform you about major Company's events and special offers.	Legitimate interest	We store the data during the performance of the contract of until you object the processing

Payments Data

We collect some additional data to process your payments.

We charge you for subscriptions and paid features through the App Store.

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 agreement between Readdle and you

Content and App's Features

Scanner and files' management

You may upload, create or edit different kinds of documents or content. While using a scanning feature, we can request access to your camera or photos in order to scan the document.

Data	Reasons for Processing	Lawful Basis	Data Storage
Documents and their content	Providing you with the functionality of the App	Performance of the contract	We do not store the data
Image from your camera	Providing you with the functionality of the App	Performance of the contract	We do not store the data

Smart Eraser

The App offers the Smart Eraser feature to remove unwanted objects.

By default, this feature is turned off. The AI model operates directly on your device, ensuring that no data is collected or transmitted externally. It accesses and processes only the image or document’s page you explicitly choose. Once the erasure process is completed, the model stops running. It can be used again through the menu whenever needed.

The feature does not intentionally restrict the size, format, or content of the images it processes. However, there are unspecified technical limitations on the maximum allowable image size, which depend on the characteristics of a particular device and cannot always be predicted.

The output is always saved as a copy of the original file. Also, the output file format will be preserved only for jpeg, png, or heiс files. All other formats will be converted and saved as jpeg.

Occasionally, the AI model may make errors. The model is sensitive to how an object for erasing has been masked, and it tends to produce both good and bad results depending on the input.

We do not use the user’s data for learning purposes and do not retain or back up any images when the feature is on.

Data	Reasons for Processing	Lawful Basis	Data Storage
Image	Providing you with the functionality of the App	Performance of the contract	We do not store the data
File	Providing you with the functionality of the App	Performance of the contract	We do not store the data

Expense Report

If you subscribe to the Expense Report functionality, we collect some additional data to provide you with the purchased features.

Data	Reasons for Processing	Legal Basis	Data Storage
Receipts and their content	Providing you with the functionality of the App	Performance of the contract	We do not store the data

Fax

If you subscribe to the fax functionality, we collect some additional data to provide you with the purchased features.

Data	Reasons for Processing	Legal Basis	Data Storage
Fax number	Providing you with the functionality of the App	Performance of the contract	We do not store the data

Files' 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	Legal Basis	Data Storage
Files on the cloud of the third-party service	Providing you with the functionality of the App	Performance of the contract	We do not store the data

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.

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 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

Where we have your email, 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		Legitimate interest	We process data in this way until you unsubscribe

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 data listed below.

Feedback Provided to us Directly
Data	Reasons for Processing	Lawful Basis	Data Storage
Email.	To respond to your feedback or clarify it and ask for your consent, as may be applicable	Consent.	We store the data for 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 marketing activities.
Feedback, including text feedback, answers to the review forms, or the feedback provided orally in the meeting
Date of the feedback.
Assigned rating
Meeting records

Feedback Provided via a 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 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 legal basis for processing is determined by the respective privacy documents of these parties.

Third parties	Privacy document of the respective party
Dropbox	Privacy Policy
Google Drive	Privacy Policy
OneDrive	Privacy
Box	Privacy Notice
OneNote	Privacy Statement
Evernote	Privacy Policy
WebDAV	Privacy Policy
Veryfi	Privacy Policy

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 laws. Additionally, we have put in place organizational and technical measures to secure your personal data during its transfer to third parties.

To share your data, we rely on the following 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.
Messengers	We use messengers to communicate with you in ways that are convenient for you.
Contractors	We cooperate with contractors to operate, develop, and improve the features and functionality of the App, fulfill your support requests, etc. We sign data processing agreements with them and impose various security measures to ensure your data is safe.
Services Scanner Mini uses	We use third-party services to provide you with the functionality of the App.
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 App; 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 GDPR requirements.

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

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

Physical Measures
Limited Access to Premises
Organizational Measures
Policies and Instructions Password policy Monitoring and physical access policy Contractual obligations and corporate VPN Internal security policy Access control policy	Transfer Protection Data Transfer Agreements Standard Contractual Clauses Data Privacy Framework
Contractor and Staff Training	Agreements Non-disclosure Agreements Data Processing Agreements
Regular Access and Policy Review	Privacy Protection: Privacy by design and by default. 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 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 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 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, under the California Consumer Privacy Act (CCPA), 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 utmost priority, and we are dedicated 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 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. 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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