Effective date: May 2024
Plekmin Trade, S.L. (hereinafter, “the Company”, “We”, “Us” and the like) is firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy and Cookie Policy (hereinafter, “this Policy”), the User (hereinafter “the User”, “you”, “your”) of Faxer (hereinafter, “the/our App”) will find all the relevant information to better understand what We do with his/her personal data. If you do not agree with this Policy, please discontinue using our App.
We may update this Privacy Policy according to new legislative or jurisprudential requirements and/or business needs, among other reasons. The new version of this Privacy Policy will be applicable from the moment of their publication on the app. Therefore, the User is recommended to review this Privacy Policy regularly. This Privacy Policy will always be available on the app so that the data subjects can consult them at all times.
What does this Policy apply to?
This Policy applies to the personal data that We collect and process from you as a User of our app and the services offered within it.
Please bear in mind that this app is for adults in accordance with the laws and regulations of his/her birth or residence country.
What does personal data mean and which data do We collect and process?
For the purposes of this Policy, "personal data" means all data that identifies you or that could be used to identify you, such as:
Your Apple/Google user ID when you download the App.
Fax Numbers of third individuals/companies who are the recipients of the fax.
E-mail address if you contact us.
Your digital signature or signatures, by using the option to sign the document with a scribble-style signature.
The App may collect information about how you interact with the App, to enhance your user experience.
Personal data on the documents or images sent as a fax. Please bear in mind if your documents or images contain personal data of third individuals: (i) adults, you confirm that you have informed them about the purposes for which their personal data will be processed and you guarantee Us that you have obtained their prior and expres consent to communicate their personal data to Us; and / or (ii) minors, you are his/her parent and /or legal guardian.
Information about the location (GPS) of your device (that is, your IP address) by using RevenueCat. For further information, please consult RevenueCat's privacy policy;
Advertisements while using the app when applicable by means of AdMob from Firebase (Google Inc). For Further Information, please consult Google's partner privacy policy.
In all cases, We only process personal data which is strictly necessary for the fulfillment of the purposes below. That is, if you provide Us with more information than the one expressly required, you consent to its processing for Us for the informed purpose(s).
In view of the foregoing, the Comapny shall not be liabale if:
The User is not an adult in accordance with the laws and regulations of their birth or residence country. In this sense, it is the sole responsibility of the parents and/or legal guardians to exercise adequate control over their minor children’s/wards’ online activity and to prevent their access to apps whose content is not suitable or recommended for minors. Therefore, the communication of a minor's personal data without the prior authorization of their parents/legal guardians is the exclusive responsibility of the latter. If We become aware that We have collected personal data about a User under the aforementioned age, We will delete that data as soon as it is possible from a technical standpoint.
The Company has received an adult’s personal data and/or private information to provide the services offered in the app by a third party who has not requested the adult’s consent to communicate his/her personal data to us. In such cases, the Company reserves the right to inform the interested person of how his/her personal data and/or private information has been collected and, where appropriate, We will ask the individual who provided the personal data to the Company to confirm that he/she requested the consent of the data subject and/or to amend this circumstance, as well as, if appropriate, to suspend the services and/or the User account.
For circumstances that are beyond our reasonable control, such as being provided with erroneous, incomplete, and/or fraudulent information from you as a User. You will be solely responsible for the inaccuracy or lack of veracity of the information provided. In this regard, the Company will not be held responsible for any impossibility or error to sending a fax and/or for sending it to an unwanted recipient.
Who is the personal data controller?
Plekmin Trade, S.L. (hereinafter, “the Company”, “We”, “Us” ) is the controller of the User’s personal data mentioned above.
What do We use your personal data for?
Please be informed that you only are required to provide personal data and information strictly necessary to fulfill the purposes explained below. In this sense, if you provide Us with more information than that expressly required, you consent to its processing for the purpose(s) for which it was granted.
Having said that, We use your personal data for the following purposes:
To personalize your experience and improve our Service and/or App functionalities.
For sending the documents and/or images upload to the App as a fax;
To show you a list of faxes sent by you;
To collect the fees of the subscription plans to the services offered through the App;
To manage your information queries regarding our app and/or the Service offered through it;
To comply with our legal obligations, legal requirements, laws, and regulations and/or to respond to judicial, police or the corresponding authorities’ requirements;
To protect, investigate, and deter fraudulent, unauthorized, or illegal activity on/through our app;
When applicable, to improve our app’s functionalities and Service offered by analyzing disaggregated data not associated with a particular user’s personal information.
When applicable, to show you advertisements related to our app while you are browsing your social media or third party websites.
What is the legal basis for processing your personal data?
We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason(s) why We collect and process your personal data. In almost all cases the legal basis will be:
The provision of the Service offered through the app for which is necesary to process certain personal data of the sender and recipinet of the fax.
The consent that you provided Apple to install cookies or similar technologies on your device(s) for the purpose of tracking your activity in these platforms, for example, what applications you have installed and shared with third party partners as well as the information about your browser or device for advertising purposes.
To comply with our legal obligations and/or to attend administrative, judicial, police, or the corresponding authorities’ official requirements.
Our legitimate interests in (i) offering an enhanced user experience when you access and use the app and operate it efficiently, (ii) monitoring fraudulent activity in order to preserve the security and integrity of our app; (iii) providing advertisements to users according to their interests; (iv) defending and addressing our rights in the event that a claim regarding our app and/or Services may arise.
Regarding cookies and /or similar technologies used by Apple to collect and store the information on your device that is later shared with the partners of the services by these platforms, we recommend that you consult the Privacy and Cookie Policies fo these platforms for information on how to revoke the consent that you have given for the installation of similar technologies.
How long do We keep your personal data for?
For Users not subscribed to the Service: We will keep your personal data only for six (6) months.
For Users/Customers subscribed to the Service: We will keep your personal data only for as long as you are subscripted to the Service and, beyond that , your personal data will be retained, an securely blocked, for the necesary retention period to meet our legal obligations and/or for our legitimate reasons (i.e to address claims in connection with the services offered though the app; to finish the investigation of detected fraudulent or illicit activity.) Once the necesary retention period has ended, your personal data will be securely deleted from our information systems.
Who do We share the User’s personal data with?
We may communicate your personal data to the following third parties, including but not limited to:
(i) our main service providers, and Apple, where appropriate;
(ii) outsourced service providers for the Service provision, such as Documo Inc (Documo's Privacy Policy)
(iii) other providers such as RevenueCat, Google Inc, Amplitude, Firebase, among others;
(iv) administrative, police or judicial authorities as long as the data is required in accordance with the applicable law and regulations;
(v) law firms to respond to claims regarding our app or services offered through it;
The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore, your personal data will beobject of international transfers. In any event, if a personal data international transfer is deemed appropriate, We inform you that We will only transfer personal data to recipients located in countries that ensure an adequate level of data protection according to the Decisions of adequzcy of the european Comission or, failing that, offer the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure that your personal data is properly protected and that your individual rights and freedoms are guaranteed. In this regard, please be informed that the third parties mentioned above are committed with standard contractual clauses approved by the EU Commission certification in case of transfers to the USA.
How do We protect your personal data?
Your trust is very important to Us. For this reason, your personal data is stored confidentially and securely in our information systems. We have established the appropriate technical and organizational measures to safeguard and protect your personal data against illegal or unauthorized access, loss or accidental destruction, damage, use, and illegal or unauthorized disclosure.
What rights do you have and how can you exercise them?
We inform you that the Users can withdraw their consent to processing their personal data at any time. Users may also exercise the following rights: access, verify and seek rectification, have their Personal Data deleted or otherwise removed, restrict the processing of their data, object to processing of their data, as well as the right to have the Personal Data transferred to another controller (portability), with a written request, addressed to us, via the following e-mail: info@faxer.app. We also inform you of your right to lodge a complaint to the Supervisory Authority. As a general rule, We will respond to data protection rights requests within one (1) month. Occasionally, this period may be extended by two (2) further months where necessary, taking into account whether your request is particularly complex or you have made several requests. In this case, We will notify you of this event and explain the reasons for the delay to you. Finally, We inform you that should you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, especially if you consider that your data protection rights have not been adequately addressed. We remain at your disposal for any doubts or questions you may have about this Policy, please contact Us by email at info@faxer.app
What are cookies and what are they used for?
For the purposes of this Policy, the single term ‘cookies’ refers to cookies and similar technologies that track information about accessing and interaction with our app, for different purposes, such as facilitating information about the user’s device, the user’s your navigation through our app, remembering your browsing preferences, customizing the services offered on this app, the user’s purchase and cancellation history, and generating aggregate statistics based on user interaction, among others. The memorized data recorded by cookies takes up a small space on a device’s memory and does not harm the device in any way.
When are cookies installed?
Interacting with our app and purchasing the paid services offered in it implies the installation of cookies, which may belong to us or belong to third parties. The use of third-party cookies is subject to the Cookies and Privacy Policies of these third parties. Therefore, We will not be responsible for the content or veracity of the mentioned policies of said third parties. Please consult the website(s) and/or app(s) of said third parties to obtain more information, or in the event that you want to change your preferences for setting these cookies.
What type of cookies are installed?
Cookies that can be installed include the following:
Session cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and are automatically deleted when the browser on the User’s device is closed.
Persistent cookies: these are used to identify the User during the session, prevent the User from having to repeat processes in the app and remain installed for a certain time in the browser of the User’s device.
Owned cookies: these are sent to the User's device from our app and/or computer equipment, managed by Us, and their information is collected for our own purposes.
Third-party cookies: these are sent to the User's device from computer equipment or Website or app managed by another company (partners and/or service providers) and their information can be collected for our own purposes (i.e to know the geographical location of the User) and/or to manage or improve the services that these third-party companies offer (i.e to manage the payment of the app’s services.).
Technical cookies: these allow the management and operation of this app and enable its functions and services, for example, to carry out the purchase process and manage payment, etc.
Analytical cookies: these allow Us to analyze the use of this app and recognize which functionalities interest users the most, in order to improve the quality and functionalities of our services (i.e the app’s look and feel, messages’ design for usability, etc.) This information is obtained from disaggregated data which is not associated with a particular User or his/her personal information.
To install cookies in your device's browser, We need your express consent, although there are other cookies that are exempt from such consent. The exempt cookies are user authentication or identification cookies (session cookies only). We have enabled adequate mechanisms to obtain your consent for the installation of cookies that require it. However, please be informed that, in accordance with the applicable laws and regulations, (i) it will be understood that your consent has been given if you modify the configuration of the browser by disabling the restrictions that prevent the installation of cookies and that, (ii) when the installation of cookies is necessary to provide you with the services that you have expressly requested, your consent will not be necessary.