This Privacy Policy provides information about how PaperLess Europe Ltd processes and uses personal information. We are committed to respecting your privacy and the confidentiality of the personal information you supply to us and all personal data will be processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”) Reference to “data controller”, “data processor”, “personal data”, “data subject”, “processing” in this Privacy Policy shall have the same meaning as indicated in the GDPR and other applicable laws such as the Data Protection Act, Chapter 440 of the Laws of Malta and subsidiary legislation thereto, as may be amended from time to time.

PaperLess has appointed a designated person in privacy and data protection matters which has been identified in the person of Robert Jones and who may be contacted by email at paperless.gdpr@paperlesseurope.com

1. About us

PaperLess Europe Ltd. is a software company bearing company registration number C79307, having its registered office situated at 105/2 Old College Str. Sliema, Malta (hereinafter referred to as “PaperLess”)..

2. Contacting us

Our Privacy Policy ensures that our operations are subject to continuous review to maintain alignment with GDPR.

If you require further information relating to PaperLess and our privacy practices, please contact us at this email address: paperless.gdpr@paperlesseurope.com

3. Protecting Your Privacy

This privacy policy describes our practices relating to the protection of personal data by PaperLess. We assure you that we will only use and disclose any personal data collected from you in accordance with the manner set out in this policy.

4. What information do we hold?

Most of the personal information that we may collect about you through this website is given to us at your own will. We typically collect personal data:

• as part of our client engagement procedures,
• when you submit a demo request, you would fill in the details in the contact form or provide your contact details via the website chat;
• when your company provides services to us or refers clients to us
• When you contact us voluntarily in other circumstances such as when seeking employment or traineeship with us or other reason as the case may be.

The personal information we collect from you normally includes the following:

• Name and Surname;
• Email address
• Telephone/Mobile Number

5. How do we use your data?

Irrespective of the manner that we have collected your personal data, we will only process such data for the purposes of providing you with our services or purposes which are strictly related thereto, including the fulfilment of any legal or regulatory obligation imposed on us (if applicable).

We will use your personal data:

• To contact you in relation to services provided by PaperLess in case you have engaged us to provide you with such services and/or purchased our products;
• To contact you when you have willingly provided your contact details to request further information with respect to the services we provide.
• To manage our relationship with you or your company, including for billing and debt collection purposes;
• For the purpose of legitimate interest pursued by us or by a third party, provided that such interest is not overridden by your interests, fundamental rights and freedoms;
• For the purposes you would have requested when providing us with your personal data; and
• To Keep you updated with software updates, new products and other relevant news where it is in our legitimate interests to do so.
• On the basis of your explicit consent, in which case we will process your data for the purposes for which your explicit consent was requested. Data may be processed on the basis of consent when you apply for a job at PaperLess and you wish that we retain your personal data for the purposes of being contacted with future potential job openings. Personal data may be processed on the basis of consent when we communicate with you certain updates and newsletters in case we do not have a legitimate interest to send you such communications.

6. Where does the personal data we hold come from?

Your data was shared with us by you when purchasing the software, signing an agreement or requesting a demo of PaperLess software. For suppliers this data was provided at your request when you commenced a supply of services to us.

We may also process your data because:

• We are legally obliged to e.g. to confirm your identity;
• the processing is necessary for the performance of the contract with you to provide our services; or
• it is in ours or a third party’s legitimate interests to do so.

7. How long do we keep your personal information?

We keep your personal information in a form which permits identification of individuals for no longer than is necessary for the purposes for which it was collected or for any longer  period for which we are required to keep personal information to comply with our legal and regulatory requirements.When we are acting as data processors, at the choice of the data controller, we shall delete the personal data of the data controller permanently after the end of the provision of services relating to processing and the settlement of the outstanding bills unless we are required to retain personal data to comply with our legal and regulatory requirements and in the event that we have reasons to believe that personal data is to be retained for the establishment, exercise or defence of legal claims.

8. Where is your personal data stored?

The data that we collect from you is stored in servers within the European Economic Area (“EEA”). By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. All your data is stored in servers located within the EEA area, therefore subject to EU legislation. Some data is also stored on in-house servers, being that the necessary security measures have been put in place to ensure that the data is kept safe.

9. Keeping your Data Safe

We shall keep your personal data secure and shall commit to take appropriate technical and organisational measures to protect your personal data against unauthorised or unlawful processing, including against accidental loss, destruction, storage or access. Your personal data may be stored in paper files or electronically on our technology systems.

10. Your rights

You have certain rights in relation to your personal data held by PaperLess including:

• Right of access: you have the right to obtain confirmation whether or not personal data concerning you is being processed and, where that is the case, receive a copy of such personal data;
• Right to rectification: you have the right to obtain the rectification of inaccurate personal data concerning you.
• Right to erasure: in certain circumstances you may request that we delete the personal data that we hold about you;
• The right to object: you have the right to object and request that we cease the processing of your personal data where we rely on our, or a third party’s legitimate interest for processing personal data;
• The right to data portability: you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format and, where technically feasible, have the right to transmit those data to another controller without hinderance from us where:
  • The processing is based on consent or on a contract;
  • The processing is carried out by automated means
• The right to lodge a complaint: you have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority for data protection matters, namely the Information and Data Protection Commissioner;
• Right to restriction: you have the right to request that we stop using your personal data in certain circumstances, including if you believe that we are unlawfully processing your personal data or the data that we hold about you is inaccurate;
• The right to withdraw consent: where our processing is based on your consent, you have the right to withdraw your consent.
• The right to be informed of the source: where the personal data we hold about you was not provided to us directly by you, you may also have the right to be informed of the course from which your personal data originates.

In case you are a client of PaperLess and have an ongoing relationship with PaperLess, we may contact you about any updates of the software or other relevant news and updates on products on the basis of our legitimate interest to keep you informed of such updates. In this respect, you have the right to opt-out and to object to receiving any further such communications from us.

In terms of applicable laws, your rights in relation to your personal data are not absolute.

You may exercise the rights indicated in this section by contacting us or our designated person in privacy and data protection matters at paperless.gdpr@paperlesseurope.com

11. Cookies

Our website uses cookies, as almost all websites do, to help us provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites

Our cookies help us to:

• Make our website work as you’d expect
• Save you from having to login every time you visit the website when accessing our private access area
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you
• Make our marketing more efficient (ultimately helping us to offer the service we do at the price we do)

You can learn more about all the cookies we use below

Granting us permission to use cookies

By accepting our use of cookies, we take this, and your continued use of our website, to mean that you are fine with this. Should you wish to remove or not use cookies from our site you can learn how to do this below, however doing so will likely mean that our site will not work as you would expect.

By not accepting our use of cookies you can still access our website and view content but some features like video may not work properly. If you choose this option we will not create any cookies on your device.

• Third party functions

Our website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube video. Our website includes the following third-party functions, which in turn use cookies:

Disabling these cookies will likely break the functions offered by these third parties

AddThis.com; AppNexus.com; Adsrvr.org; Canddi.com; YouTube.com; DoubleClick.com/Google; GoogleAnalytics.com; Greenrope.com; MediaMath.com; Olark.com; Semasio.com; Tapad.com

• Social Website Cookies

You can easily “Like” or “Share” our content on Facebook and Twitter. For this purpose we have included the liking and sharing buttons on our site.

The privacy implications in relation to the social website cookies will vary from social network to social network and will be dependent on the privacy settings you have chosen on the respective networks.

• Anonymous Visitor Statistics Cookies

We use cookies to compile visitor statistics such as how many people have visited our website, what type of technology they are using (e.g. Mac or Windows) which helps us identify when our site is not working as it should for particular technologies, how long they spend on the site, what page they look at etc. This helps us to continuously improve our website. These so called Analytics programs also tell us if, on an anonymous basis, how people reached this site (e.g. from a search engine) and whether they have been here before, helping us to invest more in developing our services for you.

For the aforementioned purposes we use Google Analytics

• Turning Cookies Off

You can turn off cookies by adjusting your browser settings to stop it from accepting cookies. Doing so however will likely limit the functionality of our and a large proportion of the world’s websites as cookies are a standard part of most modern websites.

12. Accuracy of the Information

It is important that the personal information we hold about you is accurate and up to date. Please keep us informed if your personal information changes during your working relationship with us by sending an email to  paperless.gdpr@paperlesseurope.com

13. Access to Information?

You have the right to obtain a copy of the personal data we hold about you. You can make your request by sending an email to paperless.gdpr@paperlesseurope.com

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

14. Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy policy.

15. Complaints

If you are unhappy with how we have handled your information, send an email to paperless.gdpr@paperlesseurope.com and our Data Protection Officer will investigate the issue in further detail and, if necessary, take all the necessary measures to ensure it does not happen again.

If you are not satisfied with our response to your complaint or believe our processing of your information does not comply with data protection law, you can make a complaint to the data protection authority in your home country (for data subjects based in Malta you can make a complaint to the Information Commissioner’s Office: https://idpc.org.mt/en/Pages/Home.aspx