Privacy Policy

1. Definitions

The PaperPeace privacy policy is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). Our privacy policy should be legible and understandable for the general public, as well as our customers and business partners. To ensure this, we would like to first explain the terminology used.

In this privacy policy, we use, inter alia, the following terms:

a) Personal data

Personal data means any information relating to an identified or identifiable natural person (hereinafter the "data subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

b) Data subject

Data subject means any identified or identifiable natural person whose personal data is processed by the controller responsible for the processing.

c) Processing

Processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

d) Restriction of processing

Restriction of processing means the marking of stored personal data with the aim of limiting their processing in the future.

e) Profiling

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.

f) Pseudonymisation

Pseudonymisation means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.

g) Controller or controller responsible for the processing

Controller or controller responsible for the processing means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.

h) Processor

Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

i) Recipient

Recipient means a natural or legal person, public authority, agency or another body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law are not regarded as recipients.

j) Third party

Third party means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.

k) Consent

Consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

2. Name and address of the controller

The controller for the purposes of the General Data Protection Regulation, other data protection laws applicable in the Member States of the European Union and other provisions relating to data protection is:

Mr Timo Beyel operates this website and the app of the same name for iPhone, iPad and Mac under the PaperPeace brand. For better readability, the controller is also referred to as "PaperPeace" in the following privacy policy.

3. Collection of general data and information

Each time the PaperPeace website is accessed by a data subject or an automated system, it collects a series of general data and information. This general data and information is stored in the server log files. The following may be collected: (1) the browser types and versions used, (2) the operating system used by the accessing system, (3) the website from which an accessing system reaches our website (so-called referrer), (4) the sub-websites accessed via an accessing system on our website, (5) the date and time of access to the website, (6) an internet protocol address (IP address), (7) the internet service provider of the accessing system, and (8) any other similar data and information that serves to avert danger in the event of attacks on our information technology systems.

When using this general data and information, PaperPeace does not draw any conclusions about the data subject. Rather, this information is needed to (1) deliver the contents of our website correctly, (2) optimise the contents of our website and the advertising for it, (3) ensure the long-term functionality of our information technology systems and the technology of our website, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. This anonymously collected data and information is therefore evaluated by PaperPeace both statistically and with the aim of increasing data protection and data security within our company, in order to ultimately ensure an optimal level of protection for the personal data we process. The anonymous data in the server log files is stored separately from all personal data provided by a data subject.

4. Hosting, content delivery network and bot protection (Cloudflare)

This website is hosted by Cloudflare, Inc. (101 Townsend St, San Francisco, CA 94107, USA) and delivered via its content delivery network (CDN). In doing so, Cloudflare processes server log data, including the IP address of the data subject, in order to ensure the delivery of content, security (e.g. defence against attacks) and the continuous availability of the website.

The legal basis for the use of Cloudflare is our legitimate interest in the secure, performant and reliable provision of this website pursuant to Art. 6(1)(f) GDPR. A transfer of personal data to the USA may take place in this context. Cloudflare is certified under the EU-US Data Privacy Framework; in addition, standard contractual clauses exist as appropriate safeguards within the meaning of Art. 44 et seq. GDPR. A data processing agreement pursuant to Art. 28 GDPR has been concluded with Cloudflare.

To protect the beta sign-up form on this website against automated submissions (bots), we additionally use the Cloudflare Turnstile service. In doing so, technical information about your browser as well as your IP address is transmitted to Cloudflare and evaluated there in order to distinguish whether the input is made by a human or by an automated system. For this purpose, Turnstile does not set any cookies for advertising or tracking purposes. The legal basis is our legitimate interest in preventing misuse and in the security of our systems pursuant to Art. 6(1)(f) GDPR.

For further information on data protection at Cloudflare, please see https://www.cloudflare.com/privacypolicy/.

5. Contact option via the website

Due to legal regulations, the PaperPeace website contains information that enables quick electronic contact with our company as well as direct communication with us, which also includes a general address for so-called electronic mail (e-mail address). If a data subject contacts the controller by e-mail or via a contact form, the personal data transmitted by the data subject is automatically stored. Such personal data transmitted on a voluntary basis by a data subject to the controller is stored for the purposes of processing or contacting the data subject. This personal data is not passed on to third parties.

6. Beta sign-up and product information by e-mail (Brevo)

On this website, you can sign up with your e-mail address for the PaperPeace TestFlight beta in order to receive an invitation and to be informed about the beta and the market launch. For this purpose, we collect only the e-mail address you provide; there are no other mandatory details. The sign-up form is protected against automated submissions by Cloudflare Turnstile (see the preceding section on Cloudflare).

Sign-up takes place using the double opt-in procedure: after entering your e-mail address, you receive an e-mail asking you to confirm the sign-up via a confirmation link. Only after this confirmation do we add your e-mail address to the beta distribution list. If you do not confirm, the sign-up does not take effect. The time of the sign-up and of the confirmation is logged in order to be able to prove the consent.

For sending the confirmation and information e-mails and for managing the distribution list, we use the Brevo service of the provider Brevo GmbH, Köpenicker Straße 126, 10179 Berlin, Germany. Brevo processes your e-mail address as well as technical dispatch and log data exclusively on our behalf and on servers within the European Union. A data processing agreement pursuant to Art. 28 GDPR has been concluded with Brevo. For details on data protection at Brevo, please see https://www.brevo.com/de/legal/privacypolicy/.

The legal basis for the processing is your consent pursuant to Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future, for example via the unsubscribe link at the end of every e-mail or by an informal notification to the contact details stated in the legal notice. The lawfulness of the processing carried out up to the withdrawal remains unaffected by the withdrawal. After a withdrawal or unsubscription, your e-mail address is removed from the distribution list; we may furthermore retain the sign-up and confirmation log for as long as this is necessary to prove the consent given.

7. In-app purchases / App Store

Purchases and subscriptions within the PaperPeace app are processed exclusively via the Apple App Store. Apple is responsible for the payment processing and the payment and account data processed in this context (Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA, or, for users in the European Economic Area, Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland).

We do not receive any personal payment data of the purchasers from Apple, but only anonymised or aggregated sales and payout statistics. We have no influence on the processing by Apple; Apple's privacy provisions apply: https://www.apple.com/legal/privacy/.

8. Routine erasure and blocking of personal data

The controller processes and stores the personal data of the data subject only for the period necessary to achieve the purpose of storage, or where this is provided for by the European legislator or another legislator in laws or regulations to which the controller is subject.

If the purpose of storage ceases to apply, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data is routinely blocked or erased in accordance with the statutory provisions.

9. Rights of the data subject

a) Right to confirmation

Every data subject has the right granted by the European legislator to obtain from the controller confirmation as to whether or not personal data concerning him or her is being processed. If a data subject wishes to exercise this right to confirmation, he or she may, at any time, contact an employee of the controller.

b) Right of access

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller, free of charge and at any time, information about the personal data stored concerning him or her and a copy of this information. Furthermore, the European legislator has granted the data subject access to the following information:

• the purposes of the processing
• the categories of personal data being processed
• the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients in third countries or international organisations
• where possible, the envisaged period for which the personal data will be stored, or, if this is not possible, the criteria used to determine that period
• the existence of the right to request rectification or erasure of the personal data concerning him or her, or restriction of processing by the controller, or to object to such processing
• the existence of the right to lodge a complaint with a supervisory authority
• where the personal data is not collected from the data subject: all available information as to the source of the data
• the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject

Furthermore, the data subject has the right to obtain information as to whether personal data has been transferred to a third country or to an international organisation. Where this is the case, the data subject also has the right to be informed of the appropriate safeguards relating to the transfer.

If a data subject wishes to exercise this right of access, he or she may, at any time, contact an employee of the controller.

c) Right to rectification

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain without undue delay the rectification of inaccurate personal data concerning him or her. Furthermore, the data subject has the right, taking into account the purposes of the processing, to have incomplete personal data completed — including by means of providing a supplementary statement.

If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact an employee of the controller.

d) Right to erasure (right to be forgotten)

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, where one of the following grounds applies and insofar as the processing is not necessary:

• The personal data was collected or otherwise processed for purposes for which it is no longer necessary.
• The data subject withdraws the consent on which the processing was based pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, and there is no other legal basis for the processing.
• The data subject objects to the processing pursuant to Art. 21(1) GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Art. 21(2) GDPR.
• The personal data was processed unlawfully.
• The erasure of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which the controller is subject.
• The personal data was collected in relation to the offer of information society services referred to in Art. 8(1) GDPR.

If one of the above grounds applies and a data subject wishes to arrange for the erasure of personal data stored by PaperPeace, he or she may contact us at any time. We will comply with an erasure request without undue delay.

Where the personal data has been made public by PaperPeace and our company, as controller, is obliged to erase the personal data pursuant to Art. 17(1) GDPR, PaperPeace, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the published personal data that the data subject has requested the erasure by those other controllers of any links to, or copy or replication of, that personal data, insofar as the processing is not necessary. PaperPeace will take the necessary action in each individual case.

e) Right to restriction of processing

Every data subject affected by the processing of personal data has the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:

• The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
• The processing is unlawful, the data subject opposes the erasure of the personal data and requests instead the restriction of their use.
• The controller no longer needs the personal data for the purposes of the processing, but the data subject requires it for the establishment, exercise or defence of legal claims.
• The data subject has objected to the processing pursuant to Art. 21(1) GDPR and it is not yet established whether the legitimate grounds of the controller override those of the data subject.

If one of the above conditions is met and a data subject wishes to request the restriction of personal data stored by PaperPeace, he or she may contact us at any time. We will arrange the restriction of the processing.

f) Right to data portability

Every data subject affected by the processing of personal data has the right granted by the European legislator to receive the personal data concerning him or her, which was provided to a controller by the data subject, in a structured, commonly used and machine-readable format. He or she also has the right to transmit that data to another controller without hindrance from the controller to which the personal data was provided, where the processing is based on consent pursuant to Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR, or on a contract pursuant to Art. 6(1)(b) GDPR, and the processing is carried out by automated means, provided that the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Art. 20(1) GDPR, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible and provided that this does not adversely affect the rights and freedoms of others.

To exercise the right to data portability, the data subject may contact us at any time.

g) Right to object

Every data subject affected by the processing of personal data has the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to the processing of personal data concerning him or her which is based on Art. 6(1)(e) or (f) GDPR. This also applies to profiling based on these provisions.

In the event of an objection, PaperPeace will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

If PaperPeace processes personal data for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data for the purpose of such marketing. This also applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to PaperPeace processing for direct marketing purposes, PaperPeace will no longer process the personal data for these purposes.

In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her carried out by PaperPeace for scientific or historical research purposes, or for statistical purposes pursuant to Art. 89(1) GDPR, unless such processing is necessary for the performance of a task carried out for reasons of public interest.

To exercise the right to object, the data subject may contact us directly at any time. The data subject is furthermore free, in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to exercise his or her right to object by automated means using technical specifications.

h) Automated individual decision-making, including profiling

Every data subject affected by the processing of personal data has the right granted by the European legislator not to be subject to a decision based solely on automated processing — including profiling — which produces legal effects concerning him or her or similarly significantly affects him or her, provided that the decision (1) is not necessary for entering into, or performance of, a contract between the data subject and the controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and the controller, or (2) it is based on the data subject's explicit consent, PaperPeace shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

If the data subject wishes to exercise rights concerning automated decision-making, he or she may, at any time, contact an employee of the controller.

i) Right to withdraw data protection consent

Every data subject affected by the processing of personal data has the right granted by the European legislator to withdraw consent to the processing of personal data at any time.

If the data subject wishes to exercise the right to withdraw consent, he or she may, at any time, contact an employee of the controller.

10. Legal basis for the processing

Art. 6(1)(a) GDPR serves as the legal basis for our company for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, with processing operations that are necessary for the supply of goods or the provision of any other service or consideration, the processing is based on Art. 6(1)(b) GDPR. The same applies to processing operations that are necessary for carrying out pre-contractual measures, for example in the case of enquiries about our products or services. If our company is subject to a legal obligation that requires the processing of personal data, such as for the fulfilment of tax obligations, the processing is based on Art. 6(1)(c) GDPR. In rare cases, the processing of personal data may become necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured on our premises and his or her name, age, health insurance data or other vital information had to be passed on to a doctor, a hospital or other third parties. The processing would then be based on Art. 6(1)(d) GDPR. Finally, processing operations could be based on Art. 6(1)(f) GDPR. This legal basis applies to processing operations not covered by any of the aforementioned legal bases where the processing is necessary to safeguard a legitimate interest of our company or of a third party, provided that the interests, fundamental rights and freedoms of the data subject do not override it. Such processing operations are permitted to us in particular because they were specifically mentioned by the European legislator. In this respect, it took the view that a legitimate interest may be assumed where the data subject is a customer of the controller (recital 47, sentence 2 GDPR).

11. Legitimate interests pursued by the controller or by a third party

Where the processing of personal data is based on Art. 6(1)(f) GDPR, our legitimate interest is the conduct of our business activities for the benefit of the well-being of all our employees and our shareholders.

12. Period for which the personal data will be stored

The criterion used to determine the storage period of personal data is the respective statutory retention period. After the period expires, the corresponding data is routinely erased, provided that it is no longer required for the performance or initiation of a contract.

13. Provision of personal data; necessity for the conclusion of a contract

We clarify that the provision of personal data is in part required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary for the conclusion of a contract that a data subject provides us with personal data that must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company concludes a contract with him or her. Failure to provide the personal data would mean that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, he or she must contact one of our employees. Our employee clarifies to the data subject on a case-by-case basis whether the provision of the personal data is required by law or contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and what the consequences of not providing it would be.

14. Existence of automated decision-making

As a responsible company, we do not use automated decision-making or profiling.

A. Core principle: processing on the device

PaperPeace is designed as a data-minimising, locally operating app. There is no PaperPeace server and no user account. The recognition of documents, the text recognition (OCR) as well as the automatic classification and tagging take place exclusively on your device. The contents of your documents are at no time transmitted to us or to third parties for processing or analysis.

B. Documents and storage location

You decide for yourself where your documents are stored: locally on the device, in your iCloud Drive or with a cloud provider you have configured. The files remain in your chosen storage location; PaperPeace stores them there as ordinary files (e.g. PDF) with additional, legible metadata. For processing in a cloud you have chosen, the privacy provisions of the respective provider additionally apply.

C. Camera and photo access

To scan documents, PaperPeace requires access to the camera or photo library if you wish. This access serves exclusively to capture the documents you have selected. The captures are processed locally and stored at your chosen storage location; no transmission to us takes place. You can revoke the permission at any time in the system settings.

D. Synchronisation via iCloud

If you choose iCloud Drive as the storage location, your documents are synchronised between your devices via your Apple iCloud service. Apple is responsible for this processing within the scope of your iCloud account; Apple's privacy provisions apply (https://www.apple.com/legal/privacy/). We ourselves do not gain any access to your contents in the process.

E. Collaboration via shared folders

If you use a shared folder (e.g. in iCloud Drive or with another cloud provider) to work on documents together with other people, the sharing takes place via the respective provider and under your control. The terms and privacy notices of the respective provider apply.

F. In-app purchases

Optional paid features are unlocked exclusively via the Apple App Store. The payment processing is carried out by Apple; we do not receive any personal payment data. The "In-app purchases / App Store" section above applies.

G. No tracking, no advertising, no analytics

PaperPeace does not integrate any advertising networks, nor any third-party analytics or tracking services, and does not create usage profiles. No cross-app tracking within the meaning of Apple's App Tracking Transparency framework takes place.

H. Contact and rights of the data subject

For enquiries about data protection in the app, you can reach us at kontakt@paperpeace.app. The data subject rights described under "Rights of the data subject" apply accordingly. Since we do not store any personal data from the app on our own servers, we are generally unable to provide information about app-internal contents that are processed exclusively locally — these are solely within your control at your chosen storage location.

Last updated: June 2026.

Developed by the LegalTech specialists at Willing & Able, who also developed the system for data-protection-conscious online time tracking. The texts of the privacy policy generator were created and published by Prof. Dr. h.c. Heiko Jonny Maniero and the lawyer Christian Solmecke.