Thanks for using Paperton or visiting one of our websites or services provided by us. This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use any of our Services. It also explains the specific ways we use and disclose that information, and to who.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “Paperton,” we are referring to Paperton AB, a registered Swedish AB. We provide online integrations and platforms that you use to read publications, articles and news, and in certain cases upload, convert, create and manage content and other information related to your Readers (the “Services”). When we say “Member,” we are referring to the person or entity that is registered with us and is permitted to provide our Services. When we say “you,” we are referring either to a Member or to some other person who visits any of our Websites or Services. A “Reader” is a person who can verify their permission to access content hosted on Paperton via any of our Services (e.g. apps, website integrations or directly on a paperton.com or papertonlive.com hosted site) via third-party subscription hosting solutions or services. In other words, a Reader can be anyone who reads content hosted on Paperton or about whom you have given us information concerning so they can access content hosted on Paperton. “Personal Information” means any information that identifies or can be used to identify you or a Reader, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A “Subscriber List” is a list of Readers and all associated information related to those Readers (e.g., email addresses, customer numbers, address information, etc).
We may store data in multiple locations across Europe (our "Storage Servers"). These locations are limited specifically to:
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please use our contact form to send us a message. You may also contact us by email at:
(c) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. 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 our Services for both you and for all of our users.
(e) Web beacons: We use web beacons on our Websites, in our emails and in our apps. When we provide functionality to Members, we may track behavior such as who opened a webpage, email and/or which functionality was used or which buttons were pressed. This allows us to measure and improve the impact of our features for specific segments of Members. To do this, we implement methods (such as single pixel gifs), also called web beacons, in the Services we provide. Web beacons allow us to collect information about the current date and time, your IP address, your browser or email client type, and other similar details. We use the data from those Web Beacons to create reports about how functionality performs and what actions your Readers take and provide these reports automatically to Members in an anonymous, amalgamated and non-identifiable form.
(f) Information from other sources: From time to time we may obtain information about your Readers from third party sources, such as external subscription providers, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: email address, partial location information, first and last name. We use this information, alone or in combination with other information (including Personal Information) we collect, to grant access to content and to develop and provide you with more relevant products features, and services. For example, we use this information to display your identity in My Account, a tool that helps you know who you are logged in as, which subscriptions you currently have active and when they expire.
(g) Information from the use of our Mobile Apps: When you use our mobile apps, we may collect certain information in addition to information described elsewhere in this Policy. For example, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications. If you have opted in to these notifications and no longer want to receive them, you may turn them off through “My Account”. We may ask for access to location-based information from your mobile device, if you want to turn them off you can do so using your operating system. We may use mobile analytics software (such as Fabric.io) to better understand how people use our application. We may collect information about how often you use the application and other performance data.
If you do not access your account or use the Services from the same app, device or account within a period of 12 months, your data may automatically be marked as inactive, invalidated and subsequently removed from our servers.
We may use and disclose Personal Information only for the following purposes:
(b) To send you informational content in accordance with your preferences. You can stop receiving emails by following the unsubscribe instructions included in every email or in My Account available in our Services.
(c) To bill and collect money owed to us by our Members. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need different payment details. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 14 below.
(e) To communicate with you about your account and provide customer support.
(f) To enforce compliance with our Terms of Service and applicable law. This may include developing tools and algorithms that help us prevent violations.
(g) To protect the rights and safety of our Members and third parties, as well as our own.
(h) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
(i) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
(j) To prosecute and defend a court, arbitration, or similar legal proceeding.
(k) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
(l) To provide, support, and improve the Services we offer. This includes our use of the data that our Members provide us in order to enable our Members to use the Services to communicate with their Readers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your Readers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to 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 policy.
As part of our Services, Members may import into our system Personal Information they have collected from their Readers or other individuals. We have no direct relationship with Members' Readers or any person other than you, and for that reason, Members are responsible for making sure they have the appropriate permission for us to collect and process information about those individuals. Consistent with the uses of Personal Information covered in Section 6, we may transfer Personal Information of you or your Readers to companies that help us promote, provide, or support our Services or the services of our Members (“Service Providers”). All Service Providers enter into a contract with us that protects Personal Information and restricts their use of any Personal Information consistent with this policy. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about Readers. We may share this information, including Reader email addresses, with third parties in line with the approved uses in Section 6.
If you are a Reader and no longer want to be contacted by one of our Members, please unsubscribe directly from that Member’s mail, app or website or contact the Member directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We will retain Personal Information we process on behalf of our Members for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
(a) Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us here. If we are unable to remove your information, we will tell you why.
(b) Social media platforms and widgets. Our Websites include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
(a) Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable a feature), then we may share your and/or your Readers’ Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors, hosting services and content delivery services.
A Subscriber List can be created in a number of ways, including by importing contacts, such as through csv or excel file. Subscriber Lists are stored on a secure Paperton server. If someone on your Subscriber List complains or contacts us, we might then contact that person. Only authorized employees have access to view Subscriber Lists. You may export (download) your Subscriber Lists from Paperton at any time.
We will use and disclose the information in your Subscriber Lists only for the reasons discussed in Sections 6-9. We will not use and disclose the information in your Subscriber Lists to:
bill or collect money owed to us;
send you system alert messages;
communicate with you about your account; or
send you informational and promotional content.
If we detect abusive or illegal behavior related to your Subscriber List, we may share your Subscriber List or portions of it with affected ISPs or anti-spam organizations.
If a security breach causes an unauthorized intrusion into our system that materially affects you or your Readers, then Paperton will notify you as soon as possible and later report the action we took in response.
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our credit card processing vendor uses security measures to protect your information both during the transaction and after it is complete. If you have any questions about the security of your Personal Information, you may contact us at email@example.com.
Paperton accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because your information on Paperton is so sensitive, account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.
Our Storage Servers are located across Sweden, Ireland and Germany, and our office is located in Stockholm, Sweden, so your information may be transferred to, stored, or processed in Sweden, Ireland or Germany. We take many steps to protect your privacy, including offering a data processing addendum to Members when appropriate. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in Europe and those third parties with whom we share it as described in this policy.
If you are a Member who lives in Australia, this Section applies to you. We are subject to the operation of the Privacy Act 1988 (“Australian Privacy Act”). Here are the specific points you should be aware of:
Where we say we assume an obligation about Personal Information, we are also requiring our subcontractors to undertake a similar obligation, where relevant.
We will not use or disclose Personal Information for the purpose of our direct marketing to you unless: you have consented to receive direct marketing; you would reasonably expect us to use your personal details for the marketing; or we believe you may be interested in the material but it is impractical for us to obtain your consent. You may opt out of any marketing materials we send to you through an unsubscribe mechanism or by contacting us directly. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as “direct marketing” under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account.
Our servers are primarily located in Europe. In addition, we or our subcontractors, may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of off-shore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas.
If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request.
If you are unsatisfied with our response to a privacy matter then you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
We will give an individual, either you or a Reader, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us here. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a Reader, from our servers at your or their request. There is no charge for an individual to access or update their Personal Information.
“Do Not Track” is a standard that is currently under development. Because it is not yet finalized, Paperton adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.
Updated: May 16, 2018