PRIVACY STATEMENT
Accessible PDF has created this Privacy Policy (“Privacy Policy”) to set out how we collect, use, and disclose information about identifiable individuals and information which can be used to identify individuals (“Personal Information”) through our Website (as defined below) and in the course of providing our products and software (collectively, “Products”) and services (collectively, all of the foregoing the “Services”).
Privacy is of great importance to us. We do not collect Personal Information for the purpose of selling or marketing that Personal Information to third parties. In other words, we do not sell customer lists. Personal Information may be collected about users and visitors to the Website, as well as about personnel engaged by our customers, suppliers and resale channels. By visiting our website located at www.accpdf.com including subpages (collectively, the “Website”), or by using our Services in any manner, you acknowledge and agree with the practices and policies described in this Privacy Policy and you hereby consent to the collection, use and disclosure of your Personal Information in accordance with this Privacy Policy.
1. OVERVIEW
1.1 A Note About Children. The Services are intended for business use and are not intended for minors. We do not intentionally gather Personal Information (described in the Collection of Information section below) from persons who are under the age of 13. If a child under 13 submits Personal Information to Accessible PDF and we learn that the Personal Information is the Personal Information of a child under 13, we will attempt to delete the Personal Information as soon as possible. If you believe that we might have any Personal Information from a child under 13, please contact us at Accessible PDF INC at info@accpdf.com.
1.2 International Users. If you are a non-U.S. or non-Canadian user of the Services, by visiting the Services and providing us with data, you acknowledge and agree that your Personal Information may be processed for the purposes identified in this Privacy Policy. In addition, your Personal Information may be processed in the country in which it was collected and in other countries, including the United States and Canada, where laws regarding processing of Personal Information may be less stringent than the laws in your country. By providing your Personal Information, you consent to such transfers. If you are in the UK, Switzerland or the EEC, please see the additional specific terms below which apply to you.
1.3 Lawful processing. We process your Personal Information only to the extent necessary for the purposes described in this Privacy Policy. We set out below the type of Personal Information we collect and how we use and disclose such Personal Information. Except as set forth in this Privacy Policy, your Personal Information will not be used for any other purpose without your consent. You may withdraw your consent to our processing of your Personal Information at any time. However, withdrawing consent may result in your inability to continue using the Services.
1.4 Scope. This Privacy Policy covers the activities of Accessible PDF but does not apply to the practices of companies that we do not own or control, including third parties that may resell Accessible PDF services and any products or services offered by other companies or other sites linked from our Website or Services. You are responsible for ensuring that you have obtained the necessary authorizations and consents for any Personal Information you make available to us for use in accordance with this Privacy Policy.
2. COLLECTION AND USE OF PERSONAL INFORMATION 2.1 What we Collect. Set out below are the ways in which we may collect Personal Information:
Personal Information We Collect from our Customers. We may collect business contact information of individuals who work for our customers (such as name, business email address, business phone number and business address) in order to communicate with those customers about their business relationship with Accessible PDF. We may also collect payment credentials or related information from our customers in order to allow those customers to pay Accessible PDF for Services procured by such customers.
Personal Information Contained in Documents Provided to us for Processing via our Services. Our Services are generally designed to process PDF documents to assess and remediate accessibility compliance issues in PDF documents. Our expectation is that PDF documents that you submit to us will be public-facing documents and will not contain any Personal Information (and will not contain any sensitive Personal Information such as personal health information or personal financial information). Accordingly, please do not submit PDF documents containing any Personal Information to us for processing via our Services without first contacting us and obtaining our written approval to the processing of such PDF documents via our Services. We retain the right to decline any work that may involve the processing of PDF documents containing any Personal Information (particularly any sensitive Personal Information such as personal health information or personal financial information).
Device information. We may collect information about devices you use to access our Website and information about how you use our Website, such as your IP address and which websites you visited before accessing our Website.
Logs. Our servers automatically record information created by your use of our Services to help us diagnose and fix technical issues, and to improve the overall quality and user experience of our Services. Logs may include information such as your IP address, browser type, operating system, details of how you used our Services (such as the functions you asked our Services to perform), diagnostic information related to the Services (such as crash activity reports), the referring web page, pages visited, location, your device and application IDs, search terms, and cookie information.
Cookies. We use technologies like cookies and pixel tags to gather information about how you are interacting with our Website or our Services, which may include identifying your IP address, browser type, and referring page. For further information, please see our Cookie policy available at: https://accpdf.com/cookie-policy/.
Employee and Contractor Candidate Information. When we seek candidates for potential jobs or contracting engagements, we collect information that those candidates choose to provide to us when applying, which may include contact information, education and employment history, credentials, place of residence and other information the candidate believes to be relevant. For people who become our employees or contractors, we will typically retain the information provided by those candidates in the application process along with additional information to manage their employment or contractor relationship with us, including, without limitation, banking or other payment information (for payment of salaries, consulting fees or other remuneration), information related to income tax reporting and withholding and enrollment in Accessible PDF benefit plans (in each case, to the extent applicable for the relevant relationship).
Marketing Information. Our Website contains electronic forms that allow visitors to submit contact information (name, email address, phone number and physical address (including country)) for the purposes of submitting sales inquiries and/or receiving marketing materials from us. From time to time, we may conduct surveys or hold contests or other events or attend industry conferences and in connection with such surveys, contests, events or conferences, we may collect information you elect to provide about yourself, such as your name, email address, telephone number, organization name and address; and general information about the company for whom you work. In addition, we may use third-party service providers to collected business-related information about your employer such as its name, size, and publicly available revenue in connection with potentially offering our Products and/or Services to your employer.
Accessible PDF Suppliers and Resale Channels. Accessible PDF collects business contact information (such as name, business email address, business phone number and business address) of individuals who work for our suppliers and resale channels to communicate with those suppliers and resale channels about their business relationships with Accessible PDF.
2.2 Use of Personal Information. Accessible PDF uses the Personal Information described above to:
Conduct business and contractual relationships that we have with various persons and companies (such as customers, suppliers, resale channels and employees);
Verify identities for the purposes of complying with know-your-customer laws and regulations, economic sanctions laws and regulations and other similar laws and regulations;
Provide, operate, maintain and improve the Products and/or Services;
Send technical notices, updates, security alerts and support and administrative messages;
Respond to comments, questions, and requests and provide customer service and support;
Communicate with you and provide news or information about us;
Investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities;
Monitor and analyze trends, usage, and activities in connection with the Products and/or Services, including generating aggregated and anonymized statistics;
For other purposes which we will notify you about and seek your consent.
3. STORAGE LOCATION AND TRANSFER OF PERSONAL INFORMATION Accessible PDF processes and stores its data, including Personal Information, on servers located in Canada and/or the United States. Accessible PDF also transfers data to third-party service providers, including the third-party service providers described on our Sub-Processors webpage, available at: https://www.accpdf.com/sub-processors (“Sub-Processors”). You agree to the transferring, storing or/or processing of your Personal Information in Canada and United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in Canada and the United States under lawful access regimes or court orders.
4. DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES
4.1 Service Providers and Business Partners. We may from time to time employ third parties to perform tasks for us and we may need to share Personal Information with them to perform those tasks. Unless we tell you differently, such third parties do not have any right to use the Personal Information we share with them beyond what is necessary for them to perform the relevant tasks for us that we have allocated to them. The third parties we currently engage include third-party companies and individuals employed or contracted by us to provide certain capabilities in respect to the Products and/or Services and for certain general business functions, including the provision of database management, payment processing and customer relationship management tools, including the Sub-Processors.
4.2 Business Transfers. If our business (or substantially all of our assets) are acquired by a third party, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law. Your Personal Information may also be transferred in connection with due diligence for any such transactions. In all cases, if any such transactions occur, your Personal Information will remain subject to the restrictions and protections set forth in this Privacy Policy.
4.3 With Your Consent. If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.
4.4 As Required by Law. We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may also disclose your Personal Information to third parties without your consent to prevent damage to property, bodily injury and/or death. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
Satisfy any applicable law, regulation, legal process or governmental request (including in pursuant to subpoenas, civil investigative demands, or similar processes); enforce our contracts or user agreements, including investigation of potential violations thereof; and
Detect, prevent, or otherwise address fraud, security, or technical issues. The above may include exchanging information with other companies and organizations for fraud protection, spam/malware prevention, and know-your-customer purposes. Notwithstanding the general terms of this Privacy Policy, the collection, use, and disclosure of Personal Information may be made outside of the terms of this Privacy Policy to the extent provided for in any applicable privacy or other legislation in effect from time to time, or pursuant to court orders (including in respect to depositions, interrogatories, subpoenas, civil investigative demands, and other court or regulatory-mandated discovery processes).
5. RETENTION We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. Personal Information in respect to financial transactions is retained for at least seven years by Accessible PDF for financial compliance and to meet regulatory requirements. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.
6. RESIDENTS OF THE EUROPEAN ECONOMIC COMMUNITY (“EEC”) AND THE UK If you are a resident of the EEC, the UK or Switzerland, you have certain data protection rights. Accessible PDF takes reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information (known as “Personal Data” under the EU General Data Protection Regulation and under the UK Data Protection Act 2018 and the UK GDPR and the Swiss Federal Act on Data Protection).
We process Personal Data under the following legal bases:
Where the processing is necessary for the purpose of legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the applicable data subject and require the protection of such Personal Data. Specifically, we process Personal Data of personnel employed by or retained as contractors by entities with whom we have the legitimate interest of entering contracts or the legitimate interest of performing contracts.
Where the processing is necessary for compliance with a legal obligation applicable to us. Where the processing is necessary to protect the vital interest of the data subject or another natural person; Where the applicable data subject has given consent to the processing of his or her personal data. If you wish to be informed about what Personal Data we hold about you and if you want that Personal Data to be removed from our systems, please contact us using the contact information set out below. In certain circumstances, where we act as data controller, you have the following data protection rights:
The right to request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you where we are the data controller and to check that we are lawfully processing it.
The right to request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
The right to request erasure of your Personal Data. This right allows you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your erasure request for specific legal reasons which we will tell you when responding to your request.
The right to request object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
The right to request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
The right to request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
The right to request withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time we respond to your request. Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority. If you wish to exercise any of the rights set out above, please contact us using the contact details below. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
7. ACCESS, CORRECTION AND ACCURACY You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected about you and to receive a general account of our uses of that Personal Information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant Personal Information available to you, such as where that Personal Information also pertains to another individual. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access to and modifications of Personal Information in a timely manner.
We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your Personal Information.
8. CALIFORNIA PRIVACY RIGHTS This section provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act (the CCPA).
For more details about the Personal Information that Accessible PDF has collected over the last 12 months, please see the section “What we collect” above. We collect this Personal Information for the commercial purposes described above. Accessible PDF does not sell (as that term is defined in the CCPA) the Personal Information we collect.
Subject to certain limitations, the CCPA provides California consumers the right to request details about the categories or specific pieces of Personal Information we collect about them (including how we use and disclose this Personal Information), to delete their Personal Information, to opt out of any “sales” of Personal Information that may be occurring, and to not be discriminated against for exercising these rights. California consumers may make a request pursuant to their rights under the CCPA by contacting us at the contact information below. We will verify your request using the information (including Personal Information) associated with your account, if available, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.
9. CHANGES TO THIS PRIVACY POLICY We may amend or update this Privacy Policy from time to time. Processing of Personal Information we collect will be subject to the Privacy Policy in effect at the time such Personal Information is collected, used or disclosed, provided that if this Privacy Policy is subsequently amended or updated in accordance with this Section 9, then processing of Personal Information we collect will be subject to such amended or updated Privacy Policy following the date on which we provided notice of such amendment or update in accordance with this Section 9. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our website or via the Services or sending you an email prior to the change becoming effective.
10. ADDITIONAL INFORMATION Questions regarding this Privacy Policy or Accessible PDF’s privacy practices should be directed to our Privacy Officer:
Accessible PDF Re: Privacy Compliance Officer
1200 G ST NW. Suite 800 Washington DC 20005
or by email to Accessible PDF at info@accpdf.com
Updated: 2021-02-04