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 Paddle which is made up of each of the Controller entities that are listed in Section (U) below (together, “Paddle”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact in our course of business as a Merchant of Record, 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”). Please note that not all provisions of this Policy will apply to you and your Personal Data, as this will depend on your specific relationship with Paddle.
Defined terms used in this Policy are explained in Section (V) 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 30 June 2023.
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 Section (M) below. Similarly, Residents of certain US states, including California and Virginia, may find information on their rights as a Consumer in Sections (R), (S) and (T) below.
Summary: We collect or obtain Personal Data: when that data is 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 Merchant of Record or if you make a purchase from Paddle); 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:
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 that data is collected from different sources.
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. billing address); information about your interaction with 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:
Please note that not all of the above will apply to you, as it will depend on your relationship with Paddle (e.g. Employee, customer, etc).
Summary: We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business as a Merchant of Record. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:
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.
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.
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.
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.
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.
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
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.
Financial management: sales; finance; corporate audit; and vendor management.
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our products, or our services.
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
Legal compliance: compliance with our legal and regulatory obligations under applicable law.
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.
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.
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.
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.
We disclose Personal Data to other entities within the Paddle group, for legitimate business purposes and the operation of our Sites, products, or services to you, in accordance with applicable law. In addition, we disclose Personal Data to:
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, including the provisions at Section (H) below, with respect to international transfers.
Summary: We transfer Personal Data to recipients in other countries. Where we transfer Personal Data from the UK/EEA to a recipient outside the UK/EEA that is not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses and in the presence of appropriate safeguards.
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. For this reason, we may 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 UK/EEA to recipients located outside the UK/EEA who are not in an Adequate Jurisdiction, we do so on the basis of Standard Contractual Clauses and the presence of appropriate safeguards. Please contact the privacy team at privacy@paddle.com 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 UK/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.
Summary: We have implemented appropriate technical and organisational security measures to protect your Personal Data against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.
Insofar as you are able, please ensure that any Personal Data that you send to us is 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, from the point of collection to the point of destruction, 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.
Summary: We take reasonable steps to ensure that your Personal Data is kept accurate and up-to-date and is erased or rectified if we become aware of inaccuracies.
We take reasonable steps to ensure that:
Summary: We take reasonable steps to limit the volume of your Personal Data that we Process to what is necessary.
We take reasonable steps to ensure that your Personal Data that we Process is limited to the Personal Data reasonably necessary in connection with the purposes set out in this Policy.
Summary: We take reasonable steps to ensure that your Personal Data is only retained for as long as it is needed in connection with its lawful purpose.
We take reasonable steps to ensure that your Personal Data is 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 is as follows:
1. We will retain Personal Data in a form that permits identification as long as:
Plus:
2. The duration of:
And:
3. 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:
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:
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
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, you may submit your request via https://preferences.paddle.com/privacy or email privacy@paddle.com
Please note that:
Depending on applicable law, you may have the right to appeal our decision to deny your request. You can contact us as set forth above to appeal such decision.
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.
Summary: All Suppliers are subject to Terms of Use that govern all use of our Site.
All use of our Merchant of Record services 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 as this may influence your rights under this Policy.
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 as this may influence your rights under this Policy.
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 as amended (“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 that 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, relative to your relationship with Paddle:
Please note that not all of the above will apply to you, as it will depend on your relationship with Paddle (e.g. Employee, customer, etc).
Use of Personal Information
We may use the categories of Personal Information described above for the following business or commercial purposes:
Categories of Sources of Personal Information
We collect or obtain Personal Information about you from the following sources:
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 to which we disclose information and the categories of Personal Information disclosed:
To:
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 etc.), located anywhere in the world, subject to the requirements noted in 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 relevant third party provider, where our Sites use third party advertising, plugins or content;
Retention
We determine the duration for which we will retain your Personal Data is as follows:
Plus, the duration of:
And:
Summary: Subject to the 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, the right to opt out of a Sale or Sharing of your Personal Information, the right to correct inaccurate records of your Personal Information, the right to limit the use and disclosure of any Sensitive Personal Information and the right to non-discrimination when you exercise your rights under the CCPA
You may make a request to exercise a right as set forth above. Generally, in order to verify your request, we will compare the Personal Information we already hold about you to the Personal Information we will request in the course of processing your request. The Personal Information required for verification may include your name and email address, or further information if we reasonably believe it is necessary to verify you. 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 request that we disclose the following information, in a readily useable format, covering the 12 month period preceding the request:
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. Your request may be subject to certain exemptions under applicable laws.
We may keep a record of deletion requests solely as a record of compliance.
Right to correct inaccurate records of your Personal Information. Consumers have the right to request that we use commercially reasonable efforts to correct any inaccurate Personal Information.
Right to opt out of a Sale or the Sharing of your Personal Information. Please note that Paddle does not Sell or Share your information within the meaning of the California Privacy Acts.
Right to limit the use and disclosure of any Sensitive Personal Information. Consumers have the right to direct a business to limit its use and disclosure of Sensitive Personal Information. Please note that Paddle will only collect and use Sensitive Personal Information where it is absolutely required to do so in the course of its relationship with you and all information collected is subjected to record retention timeframes based on law and industry standards.
Requests to know, correct, or delete data may be submitted via preferences.paddle.com/privacy
Right to Non-Discrimination. Consumers have the right to be free from discrimination as set forth in the CCPA when they exercise their Consumer rights under the CCPA.
Notice of Financial Incentive. We do not offer financial incentives or a 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 that they are authorised to submit a request on your behalf. Should your authorised agent fail to submit proof that they have been authorised to act on your behalf, we will deny their request.
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 for the purposes of their direct marketing.
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:
If you have any questions about this Policy, please contact us at privacy@paddle.com
Paddle Billing
ProfitWell Metrics