Privacy Policy

We, Creative Tools Inc, a Corporation registered under the applicable laws, having its registered address at 8 The Green STE A, Dover, DE 19901 US
(“CTI”/ “We”/ “Our”/ “Us”). At ExportToPDF (“Platform”), We offer various form-building plans and packages to the customers (“You”/ “You’re”)  ranging from free trials to paid subscriptions.  We will not knowingly disclose Your personal data to any third parties, except as provided in this privacy policy. We are committed to protecting Your privacy, and therefore We take utmost care while processing Your personal information in accordance with the principles set out in the applicable legislation. We acknowledge that maintaining the confidentiality, integrity, and security of your personal information [ “Personal Data”] and have drafted this Privacy Policy  to give a detailed outline about how Your Personal Data is collected, stored, used, and disclosed by “Eszmeletlen Holding Co.” the brand owners of the brand “ExportToPDF”, a partnership firm, having its headquarters at 1014 Opal Square, Wagle Estate, Thane West, MH, India.- 400604 as a data controller, with respect to (i) Your access and use of Our site that can be accessed at the URL https://exporttopdf.dev and (ii) the access to, and use of the content of the Site including of the services provided by Platform ( collectively, “Services” ). Each time We are required by the applicable law or, otherwise, to use this legal basis, We will request Your free, informed, specific, and unequivocal consent for the processing of Your Personal Data.  When You visit the Platform, You are not required to provide any Personal Data unless and until You choose to avail of the Services. By expressing Your consent, to avail of the Services You agree that We can collect, use, reveal, process, and transfer Your Personal Data in accordance with this Policy. We may from time to time amend the provision of the Privacy Policy. Any updates made to this Policy will be available on the site with the “Last Updated” date. We will also inform You about the changes that have occurred, to ensure that You are aware of how We use Your Personal Data. With the exception of changes that require Your prior consent, and which will apply as of the moment when You express such consent, any amendments to this Policy will apply on the date that they are made. “Personal Data” means and includes any information or data which includes but not limited to:

• Name and Address of Users
• Email ID
• Login ID and Password
• Mobile Number
• Gender
• Bank Details
• Company Name
• Designation

CATEGORIES OF PERSONAL DATA, PURPOSES OF PROCESSING, AND LEGAL GROUNDS 1.1. Browsing data: Computer systems and software procedures used for the Site’s operation acquire, during their normal operation, some information (so-called log files), the transmission of which is implicit in the use of internet communication protocols. This information is not collected in order to be associated with identified persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, and other parameters concerning the user’s operating system and computer environment. Insofar such information leads to the identification of a user, the provisions of this Policy shall become applicable.

Purpose of processing	Legal ground
We use this data for the sole purpose of obtaining anonymous statistical information concerning the use of the Site and to check its correct operation.	Our legitimate interest in the improvement of our services and in managing the server capacities, and in the bug-free preservation of our Platform and products

1.2. Creating the user account:

1. Registration and log in with email address: 

To register and create an account at Platform , We will need Your email address:

Purpose of processing	Legal ground
The purpose of this processing is to create the account, to log into the Site and to provide our services through the Site, and to provide help in using the Site.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

1. Registration and log in with Google:

Our Platform also offers You the possibility to register using Your Google account. While You do so, You are redirected to a Google page where You can log in using Your Google username and password. After this process, Your ExportToPDF / MakeForms account will be connected to Your Google profile. While connecting, Platform automatically receives from Google the information You agreed to email, first name, last name, and profile picture. This information will be processed by Us in order to offer You the possibility of creating the account and to the extent necessary to identify You in the context of the features offered by the Site and to offer You the various features on Our Site. We are not responsible for the processing by Google of your Personal Data. For further information about Google’s privacy settings, please refer to Google’s privacy policy. 1.3 Adding information to your profile: Once You have created Your user account, You can fill in other details about yourself in order to complete Your profile: first name, last name, telephone number, and industry.

Purpose of processing	Legal ground
The purpose of this processing is to complete the user’s profile in order to better provide our Services.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

1.4. Informing the users added to the account:  Once created the account, You can add new users in order to collaborate on projects. In this case, Platform will use their email address to invite them to the project. In such a case, they also need to create a user account.

Purpose of processing	Legal ground
The purpose of this process is to inform the newly added user of the collaboration invitation.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

The source of this Personal Data (the email address of the invited person) is the user who invited the respective person. 1.5. Invoicing When providing You with the Services, We will issue invoices for the fees. In this case, we will process your first name, last name, and address.

Purpose of processing	Legal ground
The purpose of this processing is to issue the invoices for the payment of the services.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.  Processing is necessary for compliance with a legal obligation to which the controller is subject.

1.6. Payments:  When You make payments, the order process is conducted by our online reseller & Merchant of Record, Paddle.com, who also handles order-related inquiries and returns. Your data will be shared with Creative Tools Inc. for product fulfilment. Paddle.com Market Ltd, Judd House, 18-29 Mora Street, London EC1V 8BT. Paddle will process your bank card details (first and last name, card number, CCV, expiring date) or other available modes of payment. We are not responsible for the collection of bank card details.

Purpose of processing	Legal ground
The purpose of this processing is to send the bank card details to the payment processor in order to process the payment.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

1.7. Contractual notifications During the provision of Our Services, We will use your email address to notify You of any changes in the terms of use and in connection with any other issues related to the performance of the contract between You and Platform.

Purpose of processing	Legal ground
The purpose of this processing is to carry out contractual and service notices.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

1.8. Contact us:    If You have questions or concerns or grievances regarding this Policy, You can  email Us at support@exporttopdf.dev. In such a case, Platform might collect the following Personal Data: contact detail (email, first name, last name) and any other information regarding the issue or the request at hand.

Purpose of processing	Legal ground
In this situation, we will use your Personal Data only to contact you in connection with the requested offer or in connection with the resolution of the problem you need support with.	Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

1.9. Marketing & in-product messages / Communications You can opt-in to receive marketing messages via email.

Purpose of processing	Legal ground
We will send communications via in-product notices or by email to your registered email address or we will post updates on our Platform .	Your consent.

You can revoke Your prior consent at all times and without any costs, with altering consequences for the future.

FAILURE TO PROVIDE PERSONAL DATA
You may refuse to provide certain Personal Data (indicated above) . Failure to provide the same may result into You not being able to benefit from certain services and features, including, but not limited to, the creation of an account or contacting You to solve your problem and to provide support.

AUTOMATIC PROCESSING OF PERSONAL DATA
Your Personal Data will not be processed for taking decisions based solely on automatic processing that would result in legal effects concerning you or could similarly significantly affect You.

DATA COLLECTED THROUGH FORMS
Form records are private and can be used exclusively by the account owner or other users that received such permissions from the account owner. Platform never discloses the content of form submissions under any circumstance, unless specifically requested by Government authorities. The forms created on Platform can be viewed, which is in unfilled stage by using a link or embed options to show them the Platform’s capabilities. You are free to recommend our services to anyone who you feel can benefit from Our services. Any data/ information gathered through forms and surveys created using Platform belong to the end-user and neither Platform can hold ownership over them nor be liable for it.

RETENTION PERIOD
As a rule, We will process Your Personal Data as long as the user account exists. The Personal Data collected in order to solve an issue will be stored for the period necessary to resolve the request. In certain circumstances, We may retain Personal Data for longer periods of time, for example, if we are obliged to do so in accordance with the legal, regulatory, tax, or accounting requirements. We may also keep Personal Data for longer periods of time so that we have accurate records of your interactions with us in the event of any complaints or if we reasonably appreciate that there is a prospect of litigation related to the processing of your personal data. We will try to delete Your Personal Data, upon reasonable request.  please note that there might be latency in deleting Your Personal Data from Our servers and back up versions, in addition We do not delete from Our servers’ file that You have in common with other users.

STORAGE OF PERSONAL DATA
Your Personal Data is filed and stored on the servers of our contractual partners that are helping Us to provide our services to You as per the requirements of applicable laws.

SECURITY
The security of your Personal Data is important to us. Your Personal Data will therefore be processed by applying reasonable technical and organizational measures to protect Personal Data, such as limiting access to Personal Data, encryption or anonymization of Personal Data, and storage in secure environments. All the forms created using Platform are served via cloud infrastructure We monitor Our Platform 24/7 and security is Our top priority. All the forms are served over HTTPS via a 256-bit SSL encryption. The SSL encryption is a standard offering independent of the service plan. Our customer subscribes to [ Free or Paid ]. We ensure security through various other security features including but not limited to captcha protection, anti-spam features, HIPAA & SOC-2 Compliance. You can read more about our security feature at https://makeforms.io/security-compliance/.  You may wish to perform a pentest on our platform. However, doing so is forbidden without explicit permission from Platform. Feel free to reach out to Your account manager or customer care team to get more details. You are responsible for all actions of Your user account and password. Therefore, We do not recommend that You disclose any information with respect to Your account to any third party. If You choose to share Your account information or any Personal Data with third parties. You are solely responsible for the same.

RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA Your rights

You have the following rights in connection with the processing of your Personal Data:

Access right: You have the right to obtain from Us confirmation that Your Personal Data is processed by us, as well as information on the specific processing, such as: the purposes of the processing, categories of processed Personal Data, recipients of Personal Data, the period for which Personal Data is stored, if we transfer the Personal Data abroad and how we protect it, Your rights, the right to lodge a complaint before the supervisory authority, the source of your Personal Data.

Right to rectification: You have the possibility to request rectification of your Personal Data, provided that the applicable legal requirements are met. In the event of errors, after notification, We will immediately correct your Personal Data.

Right to erasure: In certain cases, you have the possibility to request the deletion of Personal Data, namely when: (i) the Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) You withdraw consent on which the processing is based according to and where there is no other legal ground for the processing; (iii) You exercise the right to object to the processing; (iv) the Personal Data has been unlawfully processed. We are not obliged to comply with your request when the processing is necessary (among others) for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims. There are also other circumstances in which We are not obliged to comply with this request for the deletion of Personal Data.

Restriction of processing: You may request us to restrict the processing of your Personal Data in the following circumstances: (i) You contest the accuracy of the Personal Data, for a period enabling Us to verify the accuracy of the Personal Data; (ii) the processing is unlawful and You oppose to the erasure of the Personal Data and request the restriction of their use instead; (iii) We no longer need the Personal Data for the purposes of the processing, but You require them for the establishment, exercise or defense of legal claims; (iv) You have objected to processing, pending the verification whether our legitimate grounds override yours. However, We can continue to process your Personal Data (i) when You consent; (ii) for the establishment, exercise, or defense of legal claims, or (iii) for the protection of the rights of another natural or legal person.

Right to data portability: Insofar the Personal Data is processed based on Your consent or on the execution of the agreement and the processing is carried out by automated means, You have the right to have your data Personal Data provided to you in a structured format, which is currently used and can be read automatically, and You have the right to request us to transfer this Personal Data to another controller. This right shall not adversely affect the rights and freedoms of others.

Right to opposition: In certain situations, such as when we process your Personal Data on the basis of a legitimate interest or for sending marketing messages, You have the right to object to the processing of your Personal Data by Us. In the event of an unjustified objection, Platform is entitled to continue processing Personal Data. Revocation of consent: Insofar as You consented to the processing of your Personal Data, You can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. Such right cannot be exercised when the decision: (i) is necessary for entering into, or performance of, a contract between you and us; (ii) is authorized by law which lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or (iii) is based on your explicit consent.

Identity verification: We take utmost care of the confidentiality of all Personal Data and we reserve the right to verify your identity if you make a request in relation to your Personal Data

Fees: As a rule, you can exercise your rights free of charge. However, we reserve the right to request a reasonable fee if your claims are manifestly unfounded or excessive, in particular, because of their repetitive nature.

Response Time: We make every effort to respond to your request within one month of receiving the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests, in which case we will inform you of any such extension and of the reasons for the delay.

COOKIES POLICY: A “Cookie” is a small piece of information stored by a web browser on a web browser so it can be later read back from that browser. Cookies are useful for enabling the browser to remember information specific to a given user. Our Platform uses different cookies for different purpose. Some of them are required in order to provide You with or Services while others are used for marketing purposes such as Google Ads. We may place both permanent and temporary cookies in Your computer’s hard drive while using Our Services. These cookies do not contain any of Your personally identifiable information. You may choose to disable the cookies using the settings in Your operating system of the device. However, if You do so, You may not be able to use the full functionality of Our Platform.

ANTI SPAM POLICY: Our Platform is totally against spam. To fight spam, we have implemented Captcha protection, by default on all the forms built using Platform. Platform uses Google Recaptcha on all the forms published on frms.link. For forms being published on Your domain names, You can choose to use Google Recaptcha V2 or V3. However, You will have to procure the site key credentials for the same. If You choose to not use Google Recaptcha, then Platform will by default implement the HCaptcha Anti Spam solution for all the forms published on your domain name. You can also choose to limit the number of submissions coming from the same IP address each day by editing the Source setting. We reserve the right to automatically add ReCaptcha or any other anti-spam measures at any time We discover abuses of Our Services.

ACCOUNT POOLING OR SHARING: Due to security concerns, Platform is not accepting account pooling or sharing. We kindly recommend You contact us and create a user for each person building forms. Forms with high email bounce rates: These forms will be limited for abuse. To avoid this, make sure You only send email notifications to valid email addresses. Collecting Personally Identifiable Information (PII):  Any data that could potentially be used to identify a particular person is classified as Personally identifiable information, or PII (e.g. Social Security Numbers, ID Numbers, Driver’s License).

DISCLOSURES: We may use the uploaded activity data, in an aggregated manner, to enhance the quality of Our Services. Keeping in mind the rules regarding Privacy Policy, We may send, rent, share, distribute, lease or otherwise provide or disclose User’s Personal Data to third parties in the following circumstances:

• Administrators – We may provide access to user’s Personal Data to any of Our authorized administrator for an internal business purpose, who shall be under confidentiality obligations towards the same.
• Affiliates– We may provide Personal Data that We collect to our affiliates. For example, We may disclose Personal Data to our affiliates in order to respond to Your requests for information or Services, or to help limit Your receipt of marketing materials You have requested not to receive.
• Third-Party Applications–We may share Your information to third party application, for example when You choose to access our Services through an application or a platform e.g. Facebook, LinkedIn, Google, Instagram etc. You understand and acknowledge that We are not responsible for those third parties use Your information, so You should make sure You trust the application or platform and that it has a Privacy Policy which is acceptable to You.
• Information shared with other users – As part of the Services, Your Personal Data may be shared to the other users on the Platform. These users may download, upload, share, re-share your Personal Data on any other Platform or to any third party. You understand that in the event these users share your Personal Data, then the same shall be available to the connections of such users or to the users of any other Platform, if such users have displayed your Personal Data for public at large.
• Joint marketing arrangements – Where permitted by law, We may share your Personal Data with joint marketers with whom We have a marketing arrangement, who shall be under confidentiality obligations towards the same.
• Legal and Regulatory Authorities – We may be required to disclose Your Personal Data due to legal or regulatory requirements. In such instances, We reserve the right to disclose Your Personal Data as required in order to comply with our legal obligations, including but not limited to complying with court orders, warrants, or discovery requests. We may also disclose Personal Data about our Users to law enforcement officers or others, in the good faith that such disclosure is reasonably necessary to enforce this Privacy Policy; respond to claims that any Personal Data violates the rights of third parties; or protect the rights, property, or personal safety of Platform, our users or the general public. You agree and acknowledge that we may not inform You prior to or after disclosures made according to this section.
• Persons who acquire our assets or business – We may transfer your Personal Data if We are acquired by / we acquire or merge with another entity or transfer a part of our business, including the Platform to a third party. Any third party or resultant entity that receives Your Personal Data pursuant to a merger, demerger or business transfer shall have the right to continue to use Your Personal Data. In the event of such a sale or transfer, we reasonably notify You.
• Service providers or business partners – We may use certain trusted third party and individuals to help us to provide, analyse, and improve the Services or provide marketing, development or consulting services, data storage, payment processing and other features related to the Service. These third parties may have access to Your Personal Data only for the purposes of performing their respective tasks and are under obligations similar to those in this Privacy Policy. We may disclose Your Personal Data to service providers who perform hosting services on Our behalf.
• Testimonials – We may publish any testimonials that you have provided about the Platform or Services and such testimonials and other marketing, promotions and advertisements may include Your Personal Data that You have provided to Us.

Notwithstanding anything mentioned hereinabove, We shall not be responsible for the actions or omissions of the parties (including but not limited to the entities listed above) with whom the Personal Data is shared, nor shall we be responsible and/or liable for any additional information user may chooses to provide directly to any third party.

THIRD PARTY LINKS: We may have links to other Platform or You are referred to Our Platform through a link from another Platform. We shall not be responsible for the privacy policies and practices of other platforms. Such content is subject to their terms of use and any additional guidelines and privacy information provided in relation to that use on their platform. We recommend that You check the policy of each platform You visit to better understand Your rights and obligations especially when You are submitting any type of content on those third party platform. Please contact the owner or operator of such platform if You have any concerns or questions.

INDEMNIFICATION: You agrees to indemnify Us, our partners, affiliates, officers, agents and employees and hold us harmless from and against any claims and demand, including reasonable attorney’s fees, made by any third party due to arising out of or relating to: (i) accuracy and correctness of Personal Data and contents that You submits or shares through the Platform (ii) user’s violation of this Privacy Policy (iii) user’s violation of any rights of another user.

LIMITATION OF LIABILITY: We will not be liable for any damages, direct or indirect, incidental, special or consequential or exemplary damages and all liabilities (including for negligence, loss or damage such as loss of revenue, unavailability of system or loss of data and loss of Your Personal Data) and for use of or inability to use Services of any kind that is offered or to provide indemnity or any other remedy to You or any third party. We make reasonable efforts to ensure that the Platform is free from defects or viruses. It is Your responsibility to ensure that You use the correct devices for accessing and using the Platform and to protect from anything that may damage it.

GOVERNING LAW AND DISPUTES: This Privacy Policy is governed by the applicable laws which is designed to protect Personal Data; other relevant laws, and Our policies. You agree that the Governing Laws in whatsoever case shall be Indian Laws and regulations.   Any dispute arising, between You and Eszmeletlen Holding Co. shall be governed under the laws of India and courts of law at Mumbai, Maharashtra, India shall have exclusive jurisdiction over such disputes. You agree that You may not receive the similar protection granted under this Privacy Policy outside the geography.

Representative for data subjects in the EU and UK

For the EU:

Rickert Rechtsanwaltsgesellschaft mbH
– Eszmeletlen Holding Co. –
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-eszmeletlen@rickert.law

 

For the UK:

Rickert Services Ltd UK
– Eszmeletlen Holding Co. –
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
art-27-rep-eszmeletlen@rickert-services.uk

List of subprocessors