Privacy Policy

Effective Date: 22 October 2025 

1. Introduction 

This privacy policy ("Privacy Policy") applies to Fleur Wharton, Aanya Tashfeen and Paperfly and our related entities (“Paperfly App” , “us”, “we”, and “our”) and outlines our commitment to protecting the privacy of our customers and users when you visit our website, use our products or services or interact with us in any other way including through your use of our software and IT services.  

Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.  

2. Key terms 

• "Paperfly Services" refers to any products and services we provide.  
• "Personal Information" means any information that identifies you or could be used to identify you, including names, identification numbers, location data, and online identifiers. Personal Information can include information you provide to us (for example, through our websites and your use of the other Paperfly Services), publicly available information, and/or information we collect from other sources as described in this Privacy Policy.  

3. Updates to the Privacy Policy 

We may update this Privacy Policy periodically. If significant changes are made, we will attempt to notify you via email or a notice on our website. Continued use of the Paperfly Services after such updates constitutes your acceptance of the new terms.  

4. Why we collect personal information 

We collect Personal Information to:  

• Provide and improve our website, software and Paperfly Services.  
• Personalize your experience, or to manage your account. 
• Manage customer support.  
• Send relevant information and marketing communications.  
• Support security, audit, internal investigation, and fraud prevention purposes. 
• Fulfil any other purposes as outlined in our terms and this Privacy Policy.  
• Comply with legal obligations and protect our legal rights.  

If you do not provide the necessary Personal Information or ask for it to be deleted, some services may not be available to you.  

5. Types of personal information we collect 

We may collect the following Personal Information:  

• Contact details: name, email, phone numbers, etc.  
• Usage data: information about your interactions with the Paperfly Services.  
• Log data: IP address, browser type, access times, and cookie data.  
• Device information: type, settings, operating system, and crash data.  

We may also process sensitive information included in user-uploaded content, but it is your responsibility to ensure that any such data is lawfully collected and used. 

AI chatbot interaction data: If you interact with our AI financial advisor agents, we may collect transcripts from these interactions, or metadata (such as messaging duration). These interactions may be recorded and analyzed. 

‍6. How we collect personal information 

We collect Personal Information through:  

• Account creation and profile updates.  
• Your use of Paperfly Services.  
• Direct submissions via forms or communications.  
• Third-party sources and services you integrate with Paperfly Services. 
• Analytics generated from your use of the services.  
• Third Parties or Publicly Available Sources  
• AI Financial Advice chatbot interactions: When you communicate with our automated financial advisor agents, we may collect and process data from those interactions 

7. How we disclose personal information 

We may disclose your Personal Information:  

• To employees, contractors and service providers who assist us in delivering Paperfly Services. This may include third-party vendors who provide services or functions on our behalf, such as data analysis, email delivery, hosting services, and customer service etc.  
• As required by law or to protect our rights.   
• To related entities of Paperfly for operational purposes.  
• To potential buyers if Paperfly's business ownership changes.  

Some recipients may be located overseas.  

8. Data retention, access, and deletion 

We retain Personal Information as long as necessary to fulfil the purposes outlined in this policy or as required by law. You have the right to request access, correction, or deletion of your Personal Information, subject to legal restrictions. We will delete or anonymize your Personal Information when it is no longer needed.  

9. Cookies and tracking technology 

We use cookies and similar technologies to improve your experience and target relevant advertising. You can manage cookies through your browser settings. Note that disabling cookies may affect the functionality of Paperfly Services.  

10. Security 

We use various security measures to protect your Personal Information, including encryption and access controls. Despite our efforts, no system is entirely secure, and there are inherent risks in transmitting information over the internet.   

11. Legal basis for processing (EEA and UK) 

For visitors from the EEA or UK, we process your Personal Information based on your consent, the need to perform a contract, or our legitimate interests. We process it in accordance with the EEA GDPR, UK GDPR and DPA 2018, which state your rights include:  

• The Right to be Informed – you have the right to be informed about the collection and use of personal data (Articles 12, 13, 14). 
• The Right of Access - you have the right to obtain confirmation as to whether your personal data is being processed, and in this case, to gain access to this personal data (Article 15). 
• The Right for Rectification – you have the right to have inaccurate personal data corrected, or completed if it is incomplete (Article 16). 
• The Right for Deletion - you have the right to request the deletion of personal data in certain circumstances (e.g., when no longer necessary for the original purpose (Article 17). 

You have the right to request access to, correction of or deletion of your personal information at any time. You also have the right to object to our processing or withdraw consent at any time.  

12. Legal basis for processing (Australia) 

For visitors from Australia, we process your Personal Information in accordance with the Australian Privacy Act 1988 (Cth), which states your rights include:  

• The Right to Access – you have the right to request copies of your personal data (APP 12).  
• The Right to Rectification – you have the right to request that we correct any information you believe is inaccurate, out-of-date, incomplete, irrelevant or misleading (APP 13).  

You have the right to request access to or correction of your personal information at any time. 

13. Legal basis for processing (United States – California and Washington) 

For visitors from California, we process your Personal Information in accordance with the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), which states your rights include: 

• The Right to Know: You have the right to request that we disclose to you the specific pieces and categories of Personal Information we have collected about you, the sources from which we collected it, the purposes for collecting and sharing it, and the categories of third parties with whom we share it (Cal. Civ. Code § 1798.110 and § 1798.115). 
• The Right to Correct: You have the right to request that we correct any inaccurate Personal Information we maintain about you (Cal. Civ. Code § 1798.120). 
• The Right to Opt-Out of Sale/Sharing: You have the right to direct us not to sell or share your Personal Information for cross-context behavioral advertising. 

For visitors from Washington, we process your Personal Information in accordance with the Washington My Health My Data Act (MHMD Act), particularly if your purchase data is used to infer your health status, which states your rights include: 

• The Right to Access: You have the right to confirm whether we are collecting, sharing, or selling your Consumer Health Data and to accessthat data (RCW 19.373.040). 
• The Right to Correction/Amendment: You have the right to request that we correct inaccurate Consumer Health Data we maintain about you (RCW 19.373.040). 

You have the right to request access to or correction of your Personal Information at any time. 

14. International data transfers (EEA, UK, Australia) 

Your Personal Information may be transferred to and processed in countries outside your residence. These countries may have different privacy laws, but we ensure adequate protection for your data.  

15. Links to third-party websites 

For your convenience, our website may contain links to third-party websites and/or information. When you access those links, you leave our site and are redirected to a third-party website. We do not control third-party websites, and the privacy practices of third parties might differ from our privacy practices. We do not endorse or make any representations about third-party websites. When you share personal information with third-party websites, the third-party processing is not covered by this Privacy Policy. We encourage you to review the privacy policy of any website or company before sharing personal information.  

16. Contacting Paperfly about privacy 

If you have questions or concerns about our Privacy Policy or wish to exercise your privacy rights, please contact us: 

Team@paperflyapp.com 

We take privacy seriously and will respond to your enquiries and complaints promptly.