End User Privacy Notice

Last updated 18 May 2018

This Privacy Notice describes how we handle your personal information for our Services on the Paddle websites, tools, and applications. It applies generally to information collected on the paddle.com website and content (the “Website”) or through the use of our Services. Capitalised terms used in this Privacy Notice shall have the meaning set forth herein or in the Paddle Terms and Conditions found at https://paddle.com/legal.

What information do we collect about you?

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

We may collect and store the following Personal Data:

  • e-mail address, phone number and physical contact information;

  • transactional information based on your activities on the Website (such as buying, selling, item and content you generate or that relates to your account);

  • billing and other information you provide to purchase a product;

  • community discussions, chats, dispute resolution, correspondence through our Website, and correspondence sent to us;

  • other information from your interaction with our Website, Services, and content, including device ID, computer and connection information, statistics on page views, traffic to and from the sites, IP address and standard web log information;

  • additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address);

  • information from other companies, such as demographic and navigation data;

  • if you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply; and

  • other supplemental information from third parties.

You can browse our Website without telling us who you are or revealing any Personal Data about yourself. Once you give us your Personal Data, you are not anonymous to us.

How do we use the information we collect?

Our primary purpose in collecting Personal Data is to provide you with a safe, smooth, efficient, and customized experience when purchasing software through Paddle.

We may use your Personal Data to:

  • process and fulfill an order you have made through our platform;

  • provide the customer support you request;

  • resolve disputes, collect fees, and troubleshoot problems;

  • facilitate the creation of and secure your account on our network;

  • prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our Paddle Terms and Conditions;

  • identify you as a User in the system;

  • send you a welcome e-mail to verify ownership of the e-mail address provided when your account was created;

  • customize, measure and improve our Services and content;

  • tell you about our Services, service updates, and promotional offers based on your communication preferences;

  • compare information for accuracy, and verify it with third parties; and

  • and other uses as described when we collect the information.

Retention, access to your information, and correction

You may change any of your Personal Data in your account by editing your profile within your account or by sending an e-mail to us at help@paddle.com.

You may request deletion of your Personal Data by us, but please note that in some cases we may be required to keep this information and not delete it (for example, we have a legal obligation to retain transactional records) or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. If this is the case, we will indicate this in our response.

We automatically remove Personal Data 60 days from collection where it is no longer required to provide a service; maintain legal or user records; or otherwise fulfil any requirements Paddle may have in line with the aforementioned ‘Use of Your Personal Data’ section.

Upon your request, we will close your account and remove your Personal Data from view as soon as reasonably possible, based on your account activity and in accordance with applicable law. We do retain Personal Data from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Paddle Terms and Conditions, and take other actions otherwise permitted by law.

Data is held by Paddle.com Market Limited, a company incorporated in England and Wales (company number 08172165) and registered with the ICO (reference ZA152280).

Disclosure of your personal data

We may disclose Personal Data to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone’s rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We may also share your Personal Data with:

  • Third party software providers in relation to the sale of software licensed to Paddle. Your Personal Data may be shared with more than one third party software provider, where there is an agreement to split revenues between multiple third party software providers.

  • Service providers under contract who help with our business operations (such as fraud investigations, bill collection, affiliate and rewards programmes).

  • Other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service).

  • Law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Paddle User to legal liability. In such events, we will disclose information relevant to the investigation, such as name, city, state, ZIP code, telephone number, e-mail address, User ID history, IP address, fraud complaints, bidding and listing history, and anything else we may deem relevant to the investigation.

  • Other business entities, should we plan to merge with or be acquired by that business entity, or any parent company, subsidiaries, or other companies under a common control. (Should such a combination occur, we will require that the new combined entity follow this Privacy Notice with respect to your Personal Data. If your personal information will be used contrary to this notice, you will receive prior notice.) In the event of an insolvency, bankruptcy or receivership, your Personal Data may also be transferred as a business asset.

Where do we store your data?

Paddle stores and processes customer data in the UK and the US. Under specific circumstances, data processed by Paddle may sometimes be moved between these zones in a secure manner.

All countries or territories where Paddle processes data ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of said data. All Third Party storage and processing facilities used by Paddle are compliant with, and bound by, the EU Model Clauses, approved in 2015 by the EU data protection authorities (called the Article 29 Working Party).

How do we keep your information secure?

Paddle takes the protection of customer data extremely seriously. Industry standard technical measures and procedures are in place to prevent unauthorised or unlawful access to data and against accidental loss or destruction of, or damage to, data.

Information collected via technology

To make our Website and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the Website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. Persistent Cookies can be removed by following Internet browser help file directions.

Information collected from third party companies

We may receive Personal Data and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labelled website or companies or individuals that offer their products on our Website or through our Services. These third party companies and individuals may supply us with Personal Data. We may add this information to the information we have already collected from you via our Website in order to improve the Services we provide.

Registration and sharing through third-party services

We may offer single sign-on services that allow you to use third party login credentials to sign into your account. With your permission, Paddle may also transfer to Paddle profile information contained in your third-party profile. Paddle may also, for your use, enable you to import information about who you are connected to, as well as enable you to share information with those third-party sites. If you wish to discontinue such sharing, you will be able to do so through your preference page.

Creation of anonymous data

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. We use this Anonymous Data to analyze usage patterns so that we may enhance the content of our Services. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

Account protection

Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your Paddle password to anyone. If you do share your password or your Personal Data with others, remember that you are responsible for all actions taken in the name of your account. If you lose control of your password, you may lose substantial control over your Personal Data and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Paddle and change your password.

Third parties

Except as otherwise expressly included in this Privacy Notice, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to third party software providers on our Website or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. Paddle does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your Personal Data to others.

Changes to this Privacy Notice

This Privacy Notice is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Website. Notices shall become effective immediately.

Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Notice may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us that you wish to deactivate your account with us.