Effective date: August 22, 2018
The Paperless Agent, Inc. (“The Paperless Agent”, “us”, “we”, or “our”) operates the https://thepaperlessagent.com/ website and any current or future mobile application associated with this website (hereinafter referred to as the “Service”).
Using our Services may involve the processing of personal information. Our intention is for the following information to summarize these processes, so you can understand them. To ensure fair processing, we would also like to inform you about your rights under the European General Data Protection Regulation (GDPR).
This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service means the https://thepaperlessagent.com/ website and any current or future mobile application operated by us, including any and all information contained thereon in any form.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small files stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device (“Usage Data”).
This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Use of Data
The Paperless Agent uses the collected data for various purposes:
- To provide and maintain our Service
- To notify you about changes to our Service
- To allow you to participate in interactive features of our Service when you choose to do so
- To provide customer support
- To gather analysis or valuable information so that we can improve our Service
- To monitor the usage of our Service
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)
The Paperless Agent may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it is not overridden by your rights
- To comply with the law
This is provided in Art. 6 paragraph 1 sentence 1 letter a-f of the European General Data Protection Regulation (GDPR) GDPR.
Retention of Data
The Paperless Agent will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.
Transfer of Data
Your information, including Personal Data, 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 of your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.
Disclosure of Data
Disclosure for Law Enforcement
Under certain circumstances, The Paperless Agent may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
The Paperless Agent may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of Future Mobile App
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights under the General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. The Paperless Agent aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.
If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where The Paperless Agent relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.
The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent cookies from being stored by adjusting the settings to their browser software accordingly.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter a- f GDPR. Users can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).
We use the “visitor action pixels” from Facebook Inc. (1 Hacker Way, Menlo Park, CA 94025, USA, or, if you are based in the EU, Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (“Facebook”)) on our website.
This allows user behavior to be tracked after they have been redirected to the provider’s website by clicking on a Facebook ad. This enables us to measure the effectiveness of Facebook ads for statistical and market research purposes. The data collected in this way is anonymous to us, i.e. we do not see the personal data of individual users. However, this data is stored and processed by Facebook, which is why we are informing you, based on our knowledge of the situation. Facebook may link this information to your Facebook account and also use it for its own promotional purposes, in accordance with Facebook’s Data Usage Policy https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and off Facebook. A cookie may also be stored on your computer for these purposes.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter a-f GDPR. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address: https://www.facebook.com/settings?tab=ads.
Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (https://www.privacyshield.gov/participant?id=a2zt0000000GnywAAC&status=Active).
On our website we use the marketing and remarketing services of Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”), including Google AdWords. These services allow us to display advertisements in a more targeted manner in order to present advertisements of interest to users. Through remarketing ads and products are displayed to users relating to an interest established by activity on other websites within the Google Network. For these purposes, a code is used by Google when our website is accessed and what are referred to as (re)marketing tags are incorporated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user’s device (comparable technologies may also be used instead of cookies). Cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com or googleadservices.com. This file records which apps users have visited, which content they are interested in and which offers have been used. In addition, technical information about the browser and operating system, referring websites, the length of the visit as well as any additional data about the use of the online products and services are stored. The IP address of users is also recorded, although we would like inform you that within the framework of Google Analytics, IP addresses within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area are truncated.
All user data will only be processed as pseudonymous data. Google does not store any names or e-mail addresses. All displayed ads are therefore not displayed specifically for a person, but for the owner of the cookie. This information is collected by Google and transmitted to and stored by servers in the USA.
One of the Google marketing services we use is the online advertising program Google AdWords. In the case of Google AdWords, each AdWords customer receives a different conversion cookie. Cookies can therefore not be tracked through the websites of AdWords customers. The information collected by the cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. AdWords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users.
The legal basis for the use of this service is Art. 6 paragraph 1 sentence 1 letter f GDPR. If you wish to object to interest-based advertising by Google marketing services, you can do so using the settings and opt-out options provided by Google: http://www.google.com/ads/preferences.
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.
Links to Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
- By email: email@example.com
- By visiting this page on our website: https://thepaperlessagent.com/contact/
- By phone number: 512.271.5818
- By mail: The Paperless Agent 706 W Ben White Blvd #248A Austin, TX 78704 with copy to Joel S. Pace, Esq., Levatino|Pace PLLC, 1101 S. Capital of Texas Hwy., Building K, Ste. 125, Austin, Texas 78746.