Papero - Data Protection Statement
Effective Date: October 10, 2025 Last Updated: October 10, 2025
This Data Protection Statement supplements our Privacy Policy and details how Papero handles, protects, and manages your personal data in compliance with global data protection regulatory requirements.
1.1 Legal Basis (Applicable to GDPR) We process your personal data based on the following legal grounds:
Contractual Performance: Data processing necessary to provide the Papero service.
Legitimate Interests: Improving service quality, fraud prevention, technical support.
Consent: Optional features (e.g., location services, marketing communications).
Legal Obligation: Compliance with applicable laws and regulations.
1.2 Data Minimization
We only collect data necessary to fulfill the service purposes.
We regularly review our data collection practices to ensure compliance with the minimization principle.
We provide granular privacy control options.
2.1 Identity Data
Data Collected: Name, email address, User ID
Collection Method: Third-Party Authentication (e.g., Google Sign-In)
Purpose of Use: Account management, service provision
Retention Period: Until account deletion
2.2 Financial Data
Data Collected: Transaction amount, merchant name, transaction category, date
Collection Method: User input, receipt scanning
Purpose of Use: Personal financial management, report generation
Retention Period: User-controlled, retained until account deletion.
2.3 Technical Data
Data Collected: Device ID, IP address, operating system, app version
Collection Method: Automatic collection
Purpose of Use: Technical support, bug fixing, service optimization
Retention Period: Anonymized after 24 months
2.4 Usage Data
Data Collected: Feature usage statistics, session duration, user behavior
Collection Method: Analytics Service Providers
Purpose of Use: Product improvement, user experience optimization
Retention Period: 26 months
2.5 Image Data
Data Collected: Receipt photos, document images
Collection Method: User upload
Purpose of Use: AI text recognition, transaction records
Retention Period: Uploaded receipt images are stored in your private cloud storage to facilitate multi-device synchronization. They are retained until you delete the transaction or delete your account.
3.1 Automated Processing
AI Text Recognition: Using industry-leading Cloud Vision APIs to process receipt images.
Data Analysis: Automatically generating expense reports and trend analyses.
Anomaly Detection: Identifying possible duplicate transactions or abnormal patterns.
3.2 Processing We Do Not Conduct
We do not perform credit scoring or financial assessments.
We do not engage in automated decision-making.
We do not use identifiable personal data for targeted advertising profiling (unless explicit consent is given). However, we may perform analytics on aggregated, anonymized data for market research purposes.
4.1 Service Providers
We engage the following categories of service providers to support our operations:
Cloud Infrastructure Provider
Data Type: Identity, Usage, and Technical Data
Purpose: Cloud storage, database management, and analytics
Location: US, APAC (Asia-Pacific)
Safeguards: SOC 2 Type II, ISO 27001 compliance
AI Processing Provider
Data Type: Receipt images
Purpose: Optical Character Recognition (OCR) and text extraction
Location: US / Global
Safeguards: Data is processed ephemerally and is not retained by the AI model for training.
Ad Network Providers
Data Type: Ad ID, Technical Data
Purpose: Ad serving and monetization
Location: Global
Safeguards: Usage of Privacy Sandbox technology to protect user anonymity.
4.2 Data Transfer Protections
Encrypted Transmission: All data transfers use TLS 1.3 encryption.
Access Control: Strict authentication and authorization mechanisms.
Audit Logs: Recording all data access activities.
Contractual Protections: Signing Data Processing Agreements (DPAs) with all vendors.
5.1 Technical Protections
End-to-End Encryption: Sensitive data is encrypted during transit and at rest.
Access Control: Role-based access control (RBAC) system.
Firewall Protection: Multi-layered network security defenses.
Intrusion Detection: 24/7 security monitoring.
Backup Encryption: All backup data is stored in an encrypted state.
5.2 Platform Security & Review
As an independent developer utilizing Cloud Infrastructure Provider infrastructure, we rely on provider's industry-leading security measures (SOC 2 Type II, ISO 27001). We regularly review our security configurations and access rules (Security Rules) to ensure they adhere to best practices. We perform internal code reviews and vulnerability assessments before each major update.
6.1 Right to Access (GDPR Art. 15)
Request Content: A copy of the personal data we process about you.
Response Time: Within 30 days.
Provision Format: Electronic, readable format.
Fee: Free for the first request.
6.2 Right to Rectification (GDPR Art. 16)
Scope: Correcting inaccurate or incomplete personal data.
Method: In-app settings or by contacting customer support.
Verification: May require identity verification.
6.3 Right to Erasure (GDPR Art. 17)
Applicable Situations:
Data is no longer necessary.
Withdrawal of consent.
Data was unlawfully processed.
Limitations: Except where data must be retained due to legal obligations.
Implementation: Deletion completed within 30 days.
6.4 Right to Restrict Processing (GDPR Art. 18)
Applicable Situations: Temporarily halting processing during a dispute.
Effect: Data will only be stored, not otherwise processed.
6.5 Right to Data Portability (GDPR Art. 20)
Provision Format: Machine-readable formats such as CSV, JSON.
Scope: Data you provided and data generated through automated processing.
Transfer: Can be transferred directly to another controller (where technically feasible).
6.6 Right to Object (GDPR Art. 21)
Direct Marketing: An unconditional right to object.
Other Processing: Objections based on legitimate grounds.
7.1 Retention Periods
We retain different types of data for specific periods to ensure service quality and legal compliance:
Account Information
Retention Period: Until account deletion
Reason: Necessary for ongoing service provision.
Transaction Records
Retention Period: Until account deletion (or user-controlled up to 7 years)
Reason: To meet personal financial record-keeping requirements or tax compliance needs.
Technical Logs
Retention Period: 12 months
Reason: For troubleshooting bugs and monitoring system health.
Analytics Data
Retention Period: Anonymized after 24 months
Reason: For long-term product improvement and trend analysis.
Customer Support Records
Retention Period: 3 years
Reason: For dispute resolution and quality assurance.
7.2 Automatic Deletion
Automatic deletion mechanisms are in place.
Regular purging of expired data.
Users can set personal retention preferences.
8.1 Age Verification
We do not knowingly collect data from children under 13.
If we discover data from a minor, it is deleted immediately.
Parental control protection mechanisms are in place.
8.2 Special Protections
Enhanced privacy protections.
Restricted scope of data collection.
Regular review of child protection policies.
9.1 Transfer Mechanisms
Adequacy Decisions: Prioritizing transfers to countries with an adequacy decision.
Standard Contractual Clauses (SCCs): Using EU Commission's SCCs.
Binding Corporate Rules (BCRs): Protection for intra-group data transfers.
9.2 Transfers to the US
Adherence to the EU-U.S. Data Privacy Framework.
Implementation of supplementary technical safeguards.
Regular assessment of transfer risks.
10.1 Detection and Assessment
Detection and assessment within 24 hours.
Determining the scope and severity of the impact.
Assessing the risk to individuals' rights and freedoms.
10.2 Notification Procedures
Supervisory Authority: Notification within 72 hours (in case of high risk).
User Notification: Notifying affected users without undue delay.
Transparency Reports: Publishing annual transparency reports.
10.3 Remedial Actions
Immediately containing the breach to prevent further data loss. Identifying the root cause and implementing technical patches. Notifying affected users and providing guidance on how to protect their accounts (e.g., changing passwords).
11.1 Policy Updates
30-day notice prior to material changes.
Providing a comparison between new and old versions.
Users may opt-out of material changes.
11.2 Contact Us
Email: sjapps6685@gmail.com