GENERAL
This Privacy Policy (“Privacy Policy”) explains how we (“Company”, “we”, “our” or “us”), as the provider of our Relay Convert software (the “Software”), collect, store, use, disclose, and otherwise process Personal Data (as defined below) related to you when you (“you”, “your” or “Users”) install, access, use, or otherwise engage with the Software and any of our other online activities made available by us in connection with the Software. This Privacy Policy forms an integral part of our End User License Agreement (“EULA”) or any other agreement that references this Privacy Policy. Terms not expressly defined in this Privacy Policy have the meanings assigned to them in the EULA.
This Privacy Policy may also include, or incorporate by reference, additional disclosures required under applicable privacy and data protection laws for residents of specific jurisdictions.
This Privacy Policy sets out the types of information the Company may process in connection with your use of the Software, the purposes for which such information is used, the circumstances in which it may be disclosed, and the rights available to you regarding your Personal Data.
Where applicable law distinguishes between privacy roles (for example, a "Controller" under the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) or a "Business" under certain U.S. state privacy laws), we act as the party that determines the purposes and means of the processing described in this Privacy Policy in connection with the Software.
This Privacy Policy applies worldwide to any individual who installs, accesses, uses, or otherwise engages with the Software. Certain jurisdictions, including the European Economic Area and U.S. states such as California, provide additional privacy rights and may require additional disclosures under applicable law.
We encourage you to read this Privacy Policy carefully and contact us if you have any questions. You acknowledge that providing Personal Data is voluntary. Where required under applicable law, we will process Personal Data relating to you based on your consent. You are not legally obligated to provide us with Personal Data; however, if you choose not to provide certain Personal Data, or do not permit us to process it, certain features or functionalities of the Software may not operate properly or may not be available.

CHILDREN
The Software is not designed for, or intended to be used by, individuals under 16 years of age, and we do not knowingly process Personal Data relating to children under this age.
If you have reason to believe that a child has shared Personal Data with us, please contact us at [email protected].
Following verification, we will take appropriate steps to delete such information in accordance with applicable law.

CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time, at our sole discretion, to reflect changes in applicable legal requirements, our services, or our internal practices. The most current version of this Privacy Policy will be available on our Website, which is available here, and the “Last Updated” date at the top of this Privacy Policy indicates when it was most recently updated.
We recommend that you review this Privacy Policy periodically to remain informed about how we handle information.
If we make a material change to this Privacy Policy, or if required by applicable law, we will provide notice of the change, and it will take effect within the timeframe specified in that notice. Unless otherwise required by applicable law or stated in the notice, changes will take effect upon publication on our Website.

DATA CONTROLLER
We are the “data controller” (as that term is defined in the GDPR, or as any equivalent term is defined under other applicable data protection laws) and determine the purposes and means of processing Personal Data.
If you have any questions about this Privacy Policy, or if you believe that your privacy rights have been compromised, please email: [email protected]

TYPES OF DATA PROCESSED
“Personal Data” means any information that identifies an individual, or that can reasonably be used to identify an individual, either directly or indirectly, as further defined under applicable privacy and data protection laws (including equivalent terms such as “personal information” or “personally identifiable information”). “Non-Personal Data” means information that does not identify an individual and cannot reasonably be used to identify an individual. Non-Personal Data may include aggregated or anonymized technical information, such as operating system type and version, device characteristics and general configuration, language preferences, and general performance indicators.
We may process, including by collecting, different categories of Personal Data and Non-Personal Data, depending on the nature of your interaction with the Software. Such information may be collected automatically when you install, access, or use the Software, including through technical means described in this Privacy Policy, and directly from you when you choose to provide it, including when you contact us or upload content through the Software. We describe below the categories of Personal Data we process, the relevant purposes of processing, and the applicable lawful bases. In addition, we may process certain Personal Data to detect, prevent, and address fraud, misuse of the Software, unauthorized access or use, violations of our applicable terms, and other activities that may affect the security, integrity, or operation of the Software, as well as to protect our rights and defend against legal claims. Such processing is based on our legitimate interests.
The Software is not intended to process (and, to the best of our knowledge, does not) “Sensitive Data” as defined under applicable privacy and data protection laws (including equivalent terms such as “highly sensitive information”, “special categories of personal data”, or “sensitive personal information”). Users are therefore requested not to submit or upload any such Sensitive Data through the Software, including as part of documents uploaded for conversion. Depending on the applicable jurisdiction, Sensitive Data may include, for example, data revealing racial or ethnic origin, religious or philosophical beliefs, sexual orientation, health-related information, or other categories of sensitive information recognized under applicable laws.

PERSONAL DATA PROCESSING & LEGAL BASES (WHERE APPLICABLE)
Below is detailed information regarding the Personal Data we process, the purposes for which we process it, and, where applicable under relevant privacy and data protection laws (such as the GDPR), the lawful bases for such processing:
Online Identifiers and Technical Information: When you use the Software, we, together with our service providers, may process online identifiers and related technical and contextual information, including IP address, installation ID, timestamps, device type and version, language and regional settings, and referral or traffic-source data (collectively, “Technical Information”). We use Technical Information to operate and secure the Software, perform analytics, provide the Software and its functionalities, respond to support requests, inquiries, and other requests you submit, monitor performance, identify technical issues, and improve the overall User experience. Such processing is based on our legitimate interests in ensuring the security, integrity, functionality, and ongoing improvement of the Software.
Support: When you contact us for customer support or otherwise submit inquiries or requests, we will process your contact information, as well as any information you choose to provide as part of our communications and correspondence. We use this information to respond to your support requests, inquiries, and other requests, to communicate with you, and to maintain records of the support provided for future reference and service improvement. We process such information as necessary to provide support and, where applicable, to perform our contract with you, and otherwise based on our legitimate interests in recordkeeping and improving the Software and our support processes.
User Content: We may further process, directly or indirectly through our third-party service providers, information relating to content, such as documents, that you upload through the Software in order to provide the Software’s document processing services, including converting uploaded documents into editable formats and providing related services. We process such information as necessary to perform our contract with you in order to provide these services and, where required under applicable law, based on your consent. If such content contains Personal Data relating to other individuals, you are responsible for ensuring that you have the necessary rights, permissions, and consents to upload it.

SHARING PERSONAL DATA
We share Personal Data relating to you with third parties, including service providers and other third parties that assist us in operating, providing, and supporting the Software. When we share Personal Data with such parties, we ensure that they have access only to the information reasonably necessary for the relevant purpose. Such parties are contractually obligated to protect the Personal Data they receive and to process it only for the agreed purposes, in accordance with applicable privacy and data protection laws. Without derogating from the foregoing, such service providers may use Non-Personal Data for their own independent purposes.
Information regarding the categories of third-party recipients with whom we share Personal Data is set out below.
Service Providers – To operate, provide, and support our Software, we engage third-party service providers that process Personal Data on our behalf, subject to applicable contractual obligations and confidentiality requirements. These may include providers of cloud hosting, content delivery, internet connectivity, operating systems and platforms, data security and cybersecurity, fraud detection, analytics, crash and error monitoring.
Subsidiaries and Affiliated Companies – We may share Personal Data with our subsidiaries and affiliated companies in connection with the operation and support of the Software and, where relevant, as part of a corporate transaction, such as a merger, acquisition, reorganization, or sale of all or a portion of our assets or business.
Legal and Regulatory Requirements – We may disclose Personal Data to courts, law enforcement authorities, regulators, governmental agencies, or authorized third parties where we believe in good faith that such disclosure is required by applicable law, regulation, legal process, or governmental request, or is otherwise necessary to investigate, prevent, or take action regarding suspected illegal activity, fraud, misuse of the Software, or other wrongdoing, or to protect our rights, property, or the security or integrity of the Software.
User Consent – Where such sharing requires your explicit approval, which will be obtained in advance.

SECURITY MEASURES
We use reasonable technical and organizational measures designed to protect Personal Data against unauthorized access, loss, misuse, alteration, or disclosure, and we review and update these measures as appropriate. We also maintain processes designed to identify and respond to security incidents that may affect Personal Data. However, no system or method of transmission can be guaranteed to be completely secure, and you should not expect that the Software will be immune from information security risks or attacks. You acknowledge that the security of Personal Data also depends, in part, on the security of the devices, systems, and networks you use to interact with the Software.
If you believe your Personal Data was accessed or used without authorization, please contact us promptly at [email protected].

INTERNATIONAL PERSONAL DATA TRANSFERS
If we transfer your Personal Data to a country outside your jurisdiction, we will take appropriate steps to ensure that such Personal Data is afforded an adequate level of protection, as required under applicable privacy and data protection laws.
In addition, where Personal Data collected within the European Economic Area ("EEA") is transferred outside the EEA to a country that has not received an adequacy decision from the European Commission, we will take the necessary measures to ensure appropriate safeguards are in place for such transfers, in accordance with the standard contractual clauses approved by the European Union. Accordingly, we will obtain contractual commitments or assurances from the data importer to protect your Personal Data, using contractual protections pre-approved by the EEA (known as standard contractual clauses), or we will rely on adequacy decisions adopted by the European Commission. Certain assurances may also take the form of well-recognized certification schemes.
To request more information about these safeguards, contact us at [email protected]

YOUR PRIVACY RIGHTS
Depending on your jurisdiction and the applicable law, you may have rights that include the ability to:
Access and review the Personal Data we hold about you.
Request correction or deletion of inaccurate or outdated information.
Object to, or request restriction of, certain data processing activities.
Withdraw consent where processing is based on consent.
Lodge a complaint with a competent supervisory or data protection authority.
To the extent the California Consumer Privacy Act of 2018 (CCPA) (“CCPA”) applies, you may have the right not to be discriminated against for exercising any of your rights. This includes not being denied goods or services, being charged different prices or rates for goods or services (including through the use of discounts or other benefits or the imposition of penalties), or being told that you will receive a different price or rate. You may also have the right to request that your Personal Data not be sold, where applicable. In addition, to the extent the CCPA applies, you may request, free of charge, a copy of your Personal Data in a readily usable and readable format up to twice per year, and, in responding to an access request, we will provide, among other things: (i) the categories of Personal Data we collect about you; (ii) the categories of sources from which we collect Personal Data; (iii) the purposes for collecting your Personal Data; (iv) the categories of third parties with whom we share your Personal Data; and (v) the specific pieces of Personal Data we have collected about you.
Depending on your state of residence, you may be entitled to additional disclosures and/or privacy rights, including those provided under applicable U.S. state privacy laws.
If you believe you may be entitled to such disclosures or rights, please contact us at [email protected]. We will provide you with the relevant information and instructions on how to exercise your rights, as required by applicable law.
We will handle requests in accordance with applicable legal requirements and may ask for additional information to verify your identity.

DATA RETENTION
We retain Personal Data only for as long as is reasonably necessary to achieve the purposes described in this Privacy Policy, to comply with applicable legal and regulatory requirements, or to maintain an ongoing relationship with you. However, we may keep Personal Data for longer periods in circumstances such as the following:
Required by applicable legal, tax, or regulatory obligations;
Necessary to maintain accurate records in connection with disputes, claims, or audits; or
Where there is a reasonable anticipation of litigation or enforcement activity.
In certain cases, information may be anonymized or aggregated so that it can no longer be linked to an identifiable individual. Such information is no longer treated as Personal Data under this Privacy Policy.