A. How We Share Information
(i) Our service providers
: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
For example, if it is necessary to provide Register Users something they have requested (like enable a feature such as Social Profiles), then we may share Register Users' Personal Information with a service provider for that purpose. Other examples include analyzing data, hosting data, engaging technical support for our Services, processing payments, and delivering content.
(ii) Advertising partners
: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party
where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors)
in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.
(v) Any other person with your consent
B. Legal Basis for Processing Personal Information (EEA Persons Only)
If you are from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.
However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests
and not overridden by your data-protection interests or fundamental rights and freedoms. Typically, our legitimate interests include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Services and our Websites; and for our marketing activities.
If you are a Register User, we may need the Personal Information to perform a contract
with you. In some limited cases, we may also have a legal obligation
to collect Personal Information from you.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.
Where required by law, we will collect Personal Information only where we have your consent
to do so.
If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.
C. Your Choices and Opt-Outs
Register Users and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and Register Users cannot opt out of these messages unless you cancel your Paperchain account.
D. Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page here
. If you have any questions about the security of your Personal Information, you may contact us at firstname.lastname@example.org.
Paperchain accounts require a username and password to log in. Register Users must keep their username and password secure, and never disclose it to a third party. Because the information in a Register User's Paperchain account is so sensitive, account passwords are hashed, which means we cannot see a Register User's password. We cannot resend forgotten passwords either. We will only provide Register Users with instructions on how to reset them.
E. International Transfers
(i) We operate in the United States
Our servers and offices are located in the United States and the European Union, so your information may be transferred to, stored, or processed in the United States or the European Union. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering our Register Users a data processing agreement.
(ii) Register Users located in Australia
If you are a Register User 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:
F. Retention of Data
- 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 located in the United States and European Union. 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 offshore 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 retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
- Whether we have a legal or contractual need to retain the data.
- Whether the data is necessary to provide our Services.
- Whether our Register Users have the ability to access and delete the data within their Paperchain accounts.
- Whether our Register Users would reasonably expect that we would retain the data until they remove it or until their Paperchain accounts are closed or terminated.
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
G. California Privacy
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties' direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or email us at email@example.com.
H. Changes to this Policy
I. Questions & Concerns
If you have any questions or comments, or if 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 postal mail or email at:
For EEA Residents:
For the purposes of EU data protection legislation, Paperchain Inc d/b/a Paperchain is the controller of your Personal Information. Our Data Protection Officer can be contacted at firstname.lastname@example.org.
For Non-EEA Residents:
Attn. Privacy Officer
85 Delancey St Suite 54
New York NY 10002 USA