Privacy Policy

At FaxPal, operated by Panter AS (“we,” “us,” “our”), we value your privacy and are committed to maintaining the trust and confidence of our users. This privacy policy explains how we collect, use, share, and protect your personal information when you use our FaxPal app (“Application”) and any related services, in compliance with the General Data Protection Regulation (GDPR) and relevant Norwegian law.

Our Commitment to You We aim to be transparent about why we collect your data and how we use it. We process your personal data on lawful bases, including your consent (where applicable), the necessity to perform our contract with you (i.e., to provide the FaxPal service), and our legitimate interests (such as improving our service), always ensuring your rights are protected.

Information We Collect

When you use the FaxPal Application, we may collect the following types of information:

1. Information You Provide to Us:

   • Account Information: When you create a FaxPal account or download and register the Application, we may collect your name, email address, and potentially payment information (processed by secure third-party payment processors) for processing orders and subscription fees. Registration is not always mandatory, but some features may require it.
   • Communications: If you contact us (e.g., via email at pal@faxpal.co), we will collect the information included in your communication.

2. Information Collected Automatically:

   • Usage Data: We collect information about how you use the FaxPal app, including the frequency of sent and received Faxes, FaxClub participation (if applicable), and feature usage.
   • Device and Technical Information: This includes the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, and the type of mobile Internet browsers you use.
   • Location Information: The Application may collect your device’s approximate location. We do not gather precise real-time location. This helps us determine your general geographical area to:
     • Provide personalized content or location-based services.
     • Analyze user behavior (in an aggregated and anonymized form) to improve our Application.
     • Occasionally transmit anonymized location data to external services to help us enhance the Application.

3. Message Content:

   • The content of your Faxes is encrypted during transmission. We temporarily store this data only until it is successfully delivered to the recipient. Once delivered, the content is deleted from our active servers.

How We Use Your Information

We use the information we collect for the following purposes:

1. To Provide and Maintain Our Service:

   • To operate the FaxPal Application and deliver the services you request.
   • To process your registration and manage your account.
   • To process transactions and subscription fees.

2. To Improve Our Service:

   • To understand how users interact with our Application, allowing us to enhance user experience and develop new features.
   • For analytics and to measure performance.

3. To Communicate With You:

   • To send you important information, required notices, updates about the Application, and, if you consent, marketing promotions. You can opt-out of marketing communications at any time.

4. For Security and Legal Compliance:

   • To protect the security and integrity of our Application and users.
   • To comply with legal obligations, respond to lawful requests from public authorities, or protect our rights.

Sharing Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

1. With Trusted Service Providers: We may share information with third-party vendors and service providers who work on our behalf and need access to your information to carry out their work for us (e.g., payment processors, analytics providers like Google Analytics for Firebase, Firebase Crashlytics). These providers are contractually obligated to protect your data and use it only for the services we’ve requested.

   • You can find links to the privacy policies of key third-party service providers we use here:
     • Google Analytics for Firebase
     • Firebase Crashlytics
     • [Add any other key third-party services here, e.g., payment processors]

2. For Legal Reasons: We may disclose your information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

3. Aggregated or Anonymized Data: We may share aggregated or anonymized data (which cannot be used to identify you) with third parties for research, analytics, or other purposes.

Your Rights Under GDPR

As a user in the EEA, you have the following rights regarding your personal data:

1. Right to Access: You can request a copy of the personal information we hold about you.
2. Right to Rectification: You can request that we correct any inaccurate or incomplete personal information.
3. Right to Erasure (Right to be Forgotten): You can request that we delete your personal information, subject to certain legal limitations.
4. Right to Restrict Processing: You can request that we limit the processing of your personal information under certain conditions.
5. Right to Data Portability: You can request to receive your personal information in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller.
6. Right to Object: You can object to the processing of your personal information, particularly for direct marketing purposes.
7. Right to Withdraw Consent: If we process your data based on your consent, you can withdraw that consent at any time.
8. Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement. In Norway, this is the Datatilsynet.

To exercise any of these rights, please contact us at pal@faxpal.co.

Data Retention and Management

We will retain User-Provided data for as long as you use the Application and for a reasonable time thereafter, as necessary to fulfill the purposes outlined in this policy, or as required by law. Automatically Collected information may be retained for up to 24 months for analytical purposes and then may be stored in an aggregated, anonymized form.

If you’d like us to delete User-Provided Data that you have provided via the Application, please contact us at pal@faxpal.co. We will respond within a reasonable time. Please note that some or all of the User-Provided Data may be required for the Application to function properly.

You can stop all collection of information by the Application by uninstalling it using the standard uninstall processes for your mobile device.

Children’s Privacy

Our Application is not intended for and we do not knowingly solicit data from or market to children under the age of 13 (or a higher age if stipulated by local law for processing personal data, e.g., 16 in some GDPR contexts unless national law provides for a lower age). If we discover that a child under this age has provided us with personal information, we will delete it immediately from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at pal@faxpal.co so we can take necessary actions.

Data Security

We are concerned about safeguarding the confidentiality of your information. We implement appropriate technical and organizational measures, including physical, electronic, and procedural safeguards, to protect the information we process and maintain. For example, access to this information is limited to authorized employees and contractors who need to know that information to operate, develop, or improve our Application. However, please be aware that although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

International Data Transfers

Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction (e.g., if our servers or third-party service providers are located outside the EEA). If we transfer your personal data outside the EEA, we will ensure that appropriate safeguards are in place to protect your data, such as Standard Contractual Clauses approved by the European Commission, or by transferring to countries deemed to provide an adequate level of data protection.

Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on this page and updating the “effective as of” date. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

This privacy policy is effective as of [Current Date, e.g., 2024-MM-DD].

Your Consent

By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing” means using cookies on a computer/handheld device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which activities will take place in accordance with this Privacy Policy and applicable law.

Contact Us

If you have any questions regarding privacy while using the Application, or have questions about our practices, please contact us via email at Pal@faxpal.co.

Our Data Controller is: Panter AS