Policy

Privacy policy

A. This Policy

Summary: This Policy explains how we Process Personal Data. This Policy may be amended or updated from time to time, so please check it regularly for updates.

This Policy is issued by each of the Controller entities listed in Section (R) below (together, “ Paddle ”, “ we ”, “ us ” and “ our ”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, other users of our products or services, personnel of corporate customers and vendors, applicants for employment, and visitors to our premises (together, “ you ”). Defined terms used in this Policy are explained in Section (R) below.

This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Policy.

This Policy was last updated on 8 September 2021.

You may also have certain rights regarding the information we collect about you. Specifically, the rights of Data Subjects of the EEA are explained in M below. Similarly, California Residents may find information on their rights as a Consumer in Sections (R), (S) and (T) below.

B. Collection of Personal Data

Summary: We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you appoint us as your seller of record or if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you visit our Sites; when you register to use any of our Sites, products, or services; or when you interact with any third party content or advertising on a Site. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

We collect or obtain Personal Data about you from the following sources:

Data provided to us : We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
Data we obtain in person : We obtain Personal Data during meetings, at trade shows, during visits from sales or marketing representatives, or at events we attend.
Collaborations : We obtain Personal Data when you collaborate with us in research or in an advisory/consultancy capacity.
Relationship data : We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g. we provide a service to you, or to your employer).
Data you make public : We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g. we may collect information from your social media profile(s), if you make a public post about us).
Site data : We may collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details : We collect or obtain Personal Data when you use, or register to use, any of our Sites, products, or services.
Content and advertising information : If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we may receive Personal Data from the relevant third party provider of that content or advertising.
Third party information : We collect or obtain Personal Data from third parties who provide it to us (e.g. credit reference agencies; law enforcement authorities; etc.).

C. Creation of Personal Data

Summary: We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, products, or services, including where those data are collected from different devices.

D. Categories of Personal Data we Process

Summary: We Process: your personal details (e.g., your name); demographic data (e.g. your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g. our billing address); information about our Sites (e.g. the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

Personal details : given name(s); preferred name.
Demographic information : gender; date of birth / age; nationality; salutation; title; and language preferences.
Contact details : correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Expertise : records of your expertise; professional history; practising details and qualification details; information about your experience; participation in meetings; seminars; advisory boards and conferences; information about your professional relationship with other individuals or institutions; language abilities and other professional skills.
Consent records : records of any consents you have given, together with the date and time; means of consent and any related information (e.g. the subject matter of the consent).
Purchase details : records of purchases and prices; and consignee name, address, contact telephone number and email address;
Payment details : invoice records; payment records; billing address; payment method; cardholder or account holder name; card payment identifiers; payment amount; payment date; and records of cheques.
Data relating to your use of our Sites : device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; username; password; security login details; usage data; and aggregate statistical
information.
Employer details : where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising data : records of your interactions with our online advertising and content, records of advertising and content displayed on pages displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse
hover, mouse clicks, any forms you complete in whole or in part) and any
touchscreen interactions.
Views and opinions : any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

E. Sensitive Personal Data

Summary: We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law : We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
Detection and prevention of crime : We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
Establishment, exercise or defence of legal claims : We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal claims; or
Consent : We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely
voluntary – it is not used for Processing that is necessary or obligatory in
any way).

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

F. Purposes of Processing and legal bases for Processing

Summary: We Process Personal Data for the following purposes: providing our Sites, products, and services to you; compliance checks; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, products, and services; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Provision of Sites , products, and services: providing our Sites, products, or services; providing promotional items upon request; and communicating with you in relation to those Sites, products, or services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, products, or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way)

Compliance checks : fulfilling our regulatory compliance obligations; ‘Know Your Client’ checks; and confirming and verifying your identity; use of credit reference agencies; and screening against government and/or law enforcement agency sanctions lists and other legal restrictions.

The Processing is necessary for compliance with a legal obligation ; or
The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of fulfilling our regulatory and compliance obligations (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Operating our business : operating and managing our Sites, our products, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our products, or our services; and notifying you of changes to any of our Sites, our products, or our services.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our products, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Communications and marketing : communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.

The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Management of IT systems : management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.

The Processing is necessary for compliance with a legal obligation ; or
We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Health and safety : health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.

The Processing is necessary for compliance with a legal obligation ; or
We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
The Processing is necessary to protect the vital interests of any individual.

Financial management : sales; finance; corporate audit; and vendor management.

We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Surveys : engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.

We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Security : physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).

The Processing is necessary for compliance with a legal obligation ; or
We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Investigations : detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.

The Processing is necessary for compliance with a legal obligation ; or
We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

Legal compliance : compliance with our legal and regulatory obligations under applicable law.

The Processing is necessary for compliance with a legal obligation .
Improving our Sites, products, and services: identifying issues with our Sites, our products, or our services; planning improvements to our Sites, our products, or our services; and creating new Sites, products, or services.
We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our products, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

Fraud prevention : Detecting, preventing and investigating fraud.

Establishment, exercise and defence of legal claims : management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defence of legal rights and claims, including formal legal proceedings.

The Processing is necessary for compliance with a legal obligation ;
We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
The Processing is necessary for the establishment, exercise or defence of legal claims.

Recruitment and job applications : recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.

The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).

G. Disclosure of Personal Data to Third Parties

Summary: We disclose Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business or successor in title to our obligations under a contract; and any third party providers of advertising, plugins or content used on our Sites.

you and, where appropriate, your appointed representatives;
legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
accountants, auditors, consultants, lawyers and other outside professional advisors to Paddle, subject to binding contractual obligations of confidentiality;
third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
any relevant party, regulatory body, governmental authority, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims;
any relevant party, regulatory body, governmental authority, law enforcement agency or court, for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
any alternative payment provider or reseller appointed by the Supplier or other third party acquirer(s) or successor(s) in title, including but not limited to in the event that we sell or transfer all or any relevant portion of our business or assets (including in
the event of a reorganisation, dissolution or liquidation); and
any relevant third party provider, where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.
Suppliers to the extent necessary to provide a product requested by you.
any relevant third party outsourced service providers, where our Sites use third parties to perform certain functions otherwise performed by Paddle, subject to binding contractual obligations of confidentiality.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

H. International Transfer of Personal Data

Summary: We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA to a recipient outside the EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses.

Because of the international nature of our business, we transfer Personal Data within the Paddle group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Policy, including the UK, the Republic of Ireland and the US. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where no exemption or derogation applies, and we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. Please
review the contact details provided in Section (Q) below if you wish to request a copy of our Standard Contractual Clauses.

Please note that when you transfer any Personal Data directly to any Paddle entity established outside the EEA, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we
receive those data, in accordance with the provisions of this Policy.

I. Data Security

Summary: We implement appropriate technical and organisational security measures to protect your Personal Data. Please ensure that any Personal Data that you send to us are sent securely.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

J. Data Accuracy

Summary: We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date and are erased or rectified if we become aware of inaccuracies.

We take every reasonable step to ensure that:

your Personal Data that we Process are accurate and, where necessary, kept up-to-date; and
any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

K. Data Minimisation

Summary: We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.

L. Data Retention

Summary: We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Policy. The criteria for determining the duration for which we will retain your Personal Data are as follows:

We will retain Personal Data in a form that permits identification only for as long as:

we maintain an ongoing relationship with you (e.g., where you are lawfully included in our mailing list and have not unsubscribed); or
your Personal Data are necessary in connection with the lawful purposes set out in this Policy, for which we have a valid legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those Personal Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data)

Plus:

The duration of:

any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

And:

In addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods noted above, each to the extent applicable, have concluded, we will
either:

permanently delete or destroy the relevant Personal Data; or
anonymise the relevant Personal Data.

M. Your Legal Rights

Summary: Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. In some cases it will be necessary to provide evidence of your identity before we can give effect to these rights.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, products, or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
the right to request rectification of any inaccuracies in your Relevant Personal Data;
the right to request, on legitimate grounds:
erasure of your Relevant Personal Data; or
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the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

N. Cookies and Similar Technologies

Summary: We Process Personal Data by using Cookies and similar technologies. For more information, please see our Cookie Policy.

When you visit a Site we will typically place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We Process Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

O. Terms of Use

Summary: All Suppliers are subject to Terms of Use that govern all use of our Site.

All use of our Site is subject to each Supplier’s Terms of Use. We recommend that you review your applicable Terms of Use to ensure that you are aware of your obligations and where applicable, regularly in order to review any changes we might make from time to time.

P. Terms of Sale

Summary: Our Buyer Terms and Conditions govern the sale of all Products by Paddle.

All sales of Products are subject to our Buyer Terms and Conditions. We recommend that you review these regularly, in order to review any changes we might make from time to time.

Q. Direct Marketing

Summary: We Process Personal Data to contact you with information regarding Sites, products, or services that may be of interest to you. You may unsubscribe for free at any time.

We Process Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding Sites, products, or services that may be of interest to you. We also Process Personal Data for the purposes of displaying content tailored to your use of our Sites, products, or services. If we provide Sites, products, or services to you, we may send or display information to you regarding our Sites, products, or services, upcoming promotions and other information that may be of interest to you, including by using the contact details that you have provided to us, or any other appropriate means, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may change your preferences, or unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional electronic communication and updating your communication preferences. Please note that it may take up to a month to process your unsubscribe request during which time you may continue to receive communications from us. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, products, or services you have requested (for example, we may send you emails about your Paddle projects or our ongoing business relationship).

R. California Consumer Privacy Act Disclosures

Summary: Under the California Consumer Privacy Act (“CCPA”), we must disclose our practices regarding the collection, use, and disclosure of the Personal Information of California Residents (“Consumers”). Consumers are also afforded additional rights with regard to the Personal Information we collect about them that include the rights of access, deletion, and to be free from discrimination. This section of our Privacy Policy includes the disclosures required by the CCPA.

Collection of Personal Information:

We have collected and will collect the following general categories of Personal Information about Consumers:

Personal identifiers, such as names, aliases, postal addresses, unique personal identifiers, online identifiers, internet protocol addresses, email addresses, account names, social security numbers, driver’s license numbers, and passport numbers;\Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e) including names, addresses, telephone numbers, credit and debit card identifiers;
Protected classifications, including sex, age, and national origin;
Commercial information, including products or Services you have purchased, and your purchasing history;
Internet or other electronic network activity information;
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment related information;
Education information; and
Inferences drawn from your personal information for use in creating a consumer profile (e.g. behaviour).

Use of Personal Information

We may use the categories of Personal Information described above for the following business or commercial purposes:

Advancing our commercial or economic business interests through our services and products to our customers
Maintaining and servicing customer accounts;
Auditing customer activity on our Site or with our services;
Processing or fulfilling orders and transactions;
Processing, managing, and accounting for transactions;
Providing customer support;
Verifying customer information;
Providing advertising or marketing services;
For short term, transient uses (such as behavioural advertising);
To understand and enhance your experience on our Site or with our products by utilizing analytic services;
Linking or combining it with information received from third parties to help understand your needs and provide you with an enhanced service;
Performing internal research for technological development;
Ensuring and improving the quality and safety of our services and products;
Debugging to address impairments to operational functionality;
Detecting security incidents;
Complying with applicable law and law enforcement requirements;
Protecting against malicious, deceptive, fraudulent or illegal activity and prosecuting those responsible for such activities; and
Defending against or bringing legal action, claims and other liabilities.

Categories of Sources of Personal Information

We collect or obtain Personal Information about you from the following sources:

Data provided to us: We obtain Personal Information when it is provided to us (e.g., where you create an account, where you contact us via email or telephone, or by any other means, or when you submit a job application).
Data we obtain in person: We obtain Personal Information during meetings, at trade shows, during visit from sales or marketing representatives, or at events we attend.
Collaborations: We obtain Personal Information when you collaborate with us in research or in an advisory/consultancy capacity.
Relationship data: We collect or obtain Personal Information in the ordinary course of our relationship with you (e.g., when you purchase any Services from us).
Data you make public: We collect or obtain Personal Information that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
App data: We collect or obtain Personal Information when you download or use any of our Apps.
Site data: We collect or obtain Personal Information when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details: We collect or obtain Personal Information when you use, or register to use, any of our Sites, Apps or services.
Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Information from the relevant third party provider of that content or advertising.
Third party information: We collect or obtain Personal Information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

Disclosures of Personal Information

We do not Sell any personal information to third parties. In particular, we do not Sell the personal information of minors under 16 years of age. In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of recipients.

The following is the categories of recipients and the categories of personal Information that we collect:

Legal and regulatory authorities , upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;

Personal Identifiers;
Categories of personal information enumerated in Cal. Civ. Code § 1798.80(e)
Protected Classification (if provided)
Commercial Information
Internet or other electronic network activity information
Inferences for use in creating a consumer profile

Accountants, auditors, consultants, lawyers and other outside professional advisors to Paddle, subject to binding contractual obligations of confidentiality;

Personal identifiers;
Protected classifications (if provided);
Commercial information;
Geolocation data;
Professional or employment related information;
Inferences drawn from your personal information for use in creating a consumer profile.

Third-party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted in Section (G);

Personal identifiers;
Protected classifications;
Commercial information;
Internet or other electronic network activity information;
Geolocation data;
Professional or employment related information;
Education information;
Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant party, regulatory body, governmental authority, law enforcement agency or court , to the extent necessary for the establishment, exercise or defence of legal claims;

Personal identifiers;
Protected classifications;
Commercial information;
Internet or other electronic network activity information;
Geolocation data;
Professional or employment related information;
Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant party, regulatory body, governmental authority, law enforcement agency or court , for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;

Personal identifiers;
Protected classifications;
Commercial information;
Internet or other electronic network activity information;
Geolocation data;
Professional or employment related information;
Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant third party acquirer(s) or successor(s) in title , in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation);

Personal identifiers;
Protected classifications;
Commercial information;
Internet or other electronic network activity information;
Geolocation data;
Professional or employment related information;
Inferences drawn from your personal information for use in creating a consumer profile.

Any relevant third party provider , where our Sites use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Information may be shared with the relevant third party provider.

Personal identifiers;
Protected classifications;
Commercial information;
Internet or other electronic network activity information;
Geolocation data;
Professional or employment related information;
Inferences drawn from your personal information for use in creating a consumer profile.

S. Consumer Rights under the California Consumer Privacy Act

Summary: Subject to the California Consumer Privacy Act (CCPA), you may have a number of rights, including: the right to know about your Personal Information, right to request the deletion of your Personal Information and the right to non-discrimination when they exercise their rights under the CCPA.

If you are a Consumer, the CCPA grants you the following rights regarding your Personal Information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may include your name, email address, phone number, or postal address. We will deliver a response to you within 45 days of receiving your verifiable consumer request. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information. Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:

The categories of Personal Information we collected about you.
The purposes for which the categories of Personal Information collected about you will be used.
The categories of sources for the Personal Information we collected about you.
The categories of third parties with whom we share Personal Information.
Our business or commercial purpose for collecting Personal Information.
The specific pieces of Personal Information we collected about you.
The categories of Personal Information we have disclosed for a business purpose.

Right to Request Deletion of Personal Information . Consumers have the right to request that we delete any Personal Information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the Personal Information in order to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with legal obligations.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable consumer requests to know or to delete may be submitted through one of the following methods:

Contact us on our website at paddle.com
By email at: privacy@paddle.com

Right to Non-Discrimination . Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

Deny you goods or services.
Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level of quality of goods or services.
Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Notice of Financial Incentive . We do not offer financial incentives or price or service difference to incentivise consumers to provide personal information.

Authorised Agent . Under the CCPA, you may appoint an authorised agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorised agent to provide us with a signed permission demonstrating they are authorised to submit a request on your behalf. We note, should your authorised agent fail to submit proof that they have been authorised to act on your behalf, we will deny their request.

T. California's "Shine the Light" Law

Summary: California residents are entitled to request a notice describing what categories of personal customer information We share with third parties.

Under California’s “Shine the Light” law, California residents are entitled to ask us for a notice describing what categories of personal customer information We share with third parties or corporate affiliates for those third parties or corporate affiliates’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and affiliates with which it was shared, along with their names and addresses. If you are a California resident, and would like a copy of this notice, please submit a written request to privacy@paddle.com.

U. Details of Controllers

Summary: There are several Paddle entities that act as Controllers for the purposes of this Privacy Policy.

For the purposes of this Policy, the relevant Controllers are:

Paddle.com Market Limited of Judd House, 18-29 Mora Street, London, EC1V 8BT,
UK

Paddle Payments Limited of Core B, Block 71, the Plaza, Park West, Dublin 12, Ireland

Paddle.com Inc. of 3811 Ditmars Blvd, 1071, Astoria, NY 11105-1803, USA

If you have any questions about this Policy, please contact us at privacy@paddle.com

V. Definitions

“Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
“California Resident” or “Consumer” means (1) every individual who is in the State of California for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the State of California who is outside the state for a temporary or transitory purpose.
“Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
“Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Policy, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
“Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
“EEA” means the European Economic Area.
“GDPR” means the General Data Protection Regulation (EU) 2016/679.
“Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, 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 individual.
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household:
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“Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
“Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
“Product” means the Supplier’s software product(s) and/or digital content and any subsequent updates and upgrades thereto agreed to be resold or distributed by Paddle.
“Relevant Personal Data” means Personal Data in respect of which we are the Controller.
“Sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration. A business does not sell personal information when:
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“Site” means any website operated, or maintained, by us or on our behalf.
“Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
“Supplier” means a party which has appointed Paddle to be its seller of record and reseller of its Products