PRIVACY POLICY – REVO PDF LOADER

This Privacy Policy describes how REVO PDF Loader (“REVO”, “Service”) processes personal data of users who visit the website, create an account, and use the REVO PDF Loader service.

REVO PDF Loader is a web application designed for the automated processing and compilation of PDF documents, including through batch procedures and data import from CSV/Excel files.

1. Data Controller

The Data Controller is:

Fudosoftware

Brand/Service: REVO PDF Loader – FudoSoftware

Privacy email: support@revopdfloader.com

For any request regarding personal data protection, you can contact the Controller at the address indicated above.

2. What data are processed

Depending on the use of the Service, REVO may process the following categories of data.

2.1 Account data

During registration and use of the Service, data such as the following may be processed:

• email address;

• name or other information optionally provided by the user;

• account identifiers;

• information regarding subscription status;

• technical data necessary for account authentication and security.

2.2 PDF, CSV, and Excel documents

REVO allows users to upload PDF documents and files containing data intended for automated document compilation.

Such files may contain personal data concerning the user or third parties.

REVO does not determine the content of documents uploaded by the user.

The user is therefore responsible for ensuring they have an appropriate legal basis and the necessary authorizations to process through REVO the personal data contained in their documents.

3. How documents are processed

REVO is designed to minimize the retention of processed documents.

During processing:

1. the document is transmitted to the REVO backend via an encrypted HTTPS connection;

2. the file is received temporarily in the RAM memory of the backend system;

3. PDF processing is performed in memory;

4. the result is returned to the user through the browser;

5. REVO does not intentionally retain the file beyond the time necessary to process the request.

In particular, based on the current application architecture:

REVO does not save uploaded documents to a persistent filesystem.

REVO does not save uploaded documents to the database.

REVO does not save document contents in application logs.

REVO does not send uploaded documents to external services to perform PDF processing.

PDF processing is performed on the REVO backend using software tools local to the processing system.

4. Data stored by the Service

REVO may store information necessary for the operation of the account and the Service.

In particular, the system may store:

• account-related data;

• information necessary for authentication;

• subscription status;

• user configurations;

• PDF template coordinates and configurations;

• technical information strictly necessary for the operation and security of the Service.

PDF/CSV documents uploaded for processing, on the other hand, are not stored in the application database.

5. Purposes of processing

Personal data may be processed for:

Service delivery

Creation and management of the account, user authentication, document processing, and provision of REVO features.

Legal basis: performance of a contract or pre-contractual measures requested by the user.

Subscription and payment management

Management of the trial period, subscription, renewals, cancellations, and payment status.

Legal basis: performance of the contract and compliance with applicable legal obligations.

Security

Prevention of unauthorized access, abuse, fraud, and improper use of the Service.

Legal basis: legitimate interest of the Controller in the security of the Service and, where applicable, compliance with legal obligations.

Support

Handling requests sent by users to customer support.

Legal basis: performance of the contract, pre-contractual measures, or legitimate interest in managing the relationship with users, depending on the request.

Administrative, tax, and legal obligations

Retention and processing of information required by applicable law.

Legal basis: compliance with legal obligations.

6. Payments – Stripe

REVO uses Stripe for payment and subscription management.

When the user makes a payment, certain data necessary for the transaction are processed directly by Stripe according to its own terms and privacy notices.

REVO does not need to directly store the user's full payment card details.

REVO may receive transaction- and subscription-related information from Stripe, such as payment status, technical identifiers, subscribed plan, renewal, or subscription cancellation.

For more information on the processing carried out by Stripe, users may consult the privacy policy and data protection documentation provided by Stripe.

7. Data security

REVO adopts technical measures aimed at protecting the information processed by the Service.

Based on the current application configuration:

• communications take place via HTTPS;

• access to protected endpoints requires authentication;

• authentication uses JWT tokens;

• features reserved for subscribers are protected by backend-side controls;

• processed documents are not saved to persistent disk;

• processed documents are not inserted into the database;

• document contents are not intentionally inserted into application logs;

• documents are processed temporarily in memory during the request.

However, no IT system can guarantee absolute security. The Controller maintains and updates security measures in response to the evolution of the Service and identified risks.

8. Hosting and infrastructure

REVO PDF Loader uses technological infrastructure provided through the Emergent platform.

Prior to the final publication of this Privacy Policy, the following will be specified where required by applicable regulations:

• geographic location of the infrastructure used;

• any data transfers outside the European Economic Area;

• key suppliers/sub-processors involved;

• any safeguards used for international data transfers.

9. Data retention

Account data are retained for the period necessary to deliver the Service and manage the relationship with the user, except for additional periods required by legal, tax, or administrative obligations, or necessary for the protection of the Controller's rights.

Transaction-related data may be retained for the periods prescribed by applicable tax and accounting regulations.

PDF/CSV/Excel documents submitted for processing are not archived by REVO in the database or the persistent filesystem of the application and are used in memory for the time necessary to execute the request.

Template configurations and coordinates may, however, be retained to enable the operation of the relevant features.

10. Data contained in user documents

REVO is a technical tool used by the user to process documents of their choice.

REVO does not determine what personal data the user enters into their PDFs, CSVs, or other documents.

When a customer uses REVO to process third-party personal data within the scope of their professional or business activities, the respective privacy roles must be determined based on the activities actually carried out and applicable regulations.

Where REVO acts as a Data Processor on behalf of a customer who is a Data Controller, the relevant processing may be governed by a specific Data Processing Agreement (DPA), where necessary.

11. Special categories of data

Documents uploaded by users could, at the user's discretion, contain special categories of personal data.

The user is responsible for the lawfulness of the uploaded data and must avoid using the Service for data for which they do not possess an appropriate legal basis or the necessary authorizations.

The use of REVO for processing activities presenting high risks or for categories of data subject to specific regulatory requirements must be evaluated in advance by the customer in relation to their activities and obligations.

12. Data disclosure

Personal data may be processed by entities that provide services necessary for the operation of REVO, within the limits of their respective functions.

These may include:

• technology infrastructure providers;

• payment services;

• technical providers;

• professional consultants, where necessary;

• public authorities, when required by law.

The list and role of infrastructure providers will be updated based on official information provided by the respective providers.

13. International transfers

Certain providers used by the Service might involve processing or transfers of data outside the European Economic Area.

When applicable, such transfers must occur in compliance with the conditions laid down by the GDPR and through the legal instruments provided by applicable law.

Specific information regarding the Emergent infrastructure will be integrated upon relevant official confirmation.

14. Rights of the data subject

In cases provided for by applicable law, the data subject may exercise the rights recognized by the GDPR, including:

• obtaining information on the processing of their data;

• requesting access to their personal data;

• requesting the rectification of inaccurate data;

• requesting the erasure of data;

• requesting restriction of processing;

• exercising the right to portability, when applicable;

• objecting to processing in cases provided for;

• withdrawing consent when processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal.

Requests may be sent to:

support@revopdfloader.com

The data subject also has the right to lodge a complaint with the competent supervisory authority, including, for Italy, the Garante per la protezione dei dati personali, in the cases provided for by law.

15. Automated decision-making

REVO PDF Loader does not use the contents of uploaded documents to make automated decisions producing legal or similarly significant effects on data subjects.

The application carries out technical processing and document compilation operations based on the instructions provided by the user.

16. Cookies and similar technologies

The website and application may use cookies or technical technologies necessary for the operation of the Service, session management, and security.

Any future use of analytics, marketing, or profiling tools will be documented in the dedicated cookie policy and, when required by applicable law, subject to user consent.

17. Minors

REVO PDF Loader is a service primarily intended for professional and business activities and is not specifically designed for use by minors.

18. Changes to the Privacy Policy

This Privacy Policy may be updated to reflect changes in the Service, infrastructure used, providers, or applicable regulations.

The updated version will be published on the REVO PDF Loader website, indicating the date of the last update.

In the event of substantial changes, additional means of communication to users may be utilized where appropriate or required by law.

19. Contacts

For questions regarding this Privacy Policy or personal data processing:

REVO PDF Loader – FudoSoftware

Controller: Fudosoftware

Email: support@revopdfloader.com