Nudocs Desktop Privacy Policy

Who we are

The Nudocs desktop application (the "Application") is published by PSPDFKit GmbH, doing business as Nutrient ("Nutrient", "we", "us"), Kaiserstrasse 117/17, 1070 Vienna, Austria, FN 548939P. Nutrient is the controller of the personal data described in this policy. You can contact us about this policy or your data at [email protected].

What stays on your computer

The Application runs on your computer. The documents you open, the files the Application creates while it works, and your sign-in tokens are stored on your computer. Nutrient does not receive them, except as described below.

What we collect and why

Nutrient account, document processing, and AI features

The Application signs you in with a Nutrient account and uses Nutrient Document Web Services ("DWS"), which Nutrient operates, to process documents and to run the AI assistant. DWS forwards AI requests to the model providers listed on the Nutrient Trust Center. How DWS handles your account and documents, including whether documents are retained on your plan, is described in the Nutrient API section of the Nutrient Privacy Policy and the DWS End User License Agreement.

Shared chats

While "Share chats" is on, the Application records how you use AI features and the Application and sends these records to an analytics service that Nutrient operates and hosts with Fly.io. A shared chat includes: (i) your instructions to the AI and the AI's responses, including its reasoning; (ii) the steps the AI took, including the commands and other tools it ran on your computer and their results, such as document text, the contents of files it read, and the output of commands; (iii) content you submit from the canvas and text the AI cites from your documents; (iv) actions such as opening, saving, or changing a document, without the document's name or location; (v) the AI model used, and token and cost information; and (vi) your Nutrient account identifier, your organization identifier, the Application version, your operating system, and a session identifier.

Depending on the access mode you choose, the AI can read files beyond the document you are working on. In Sandboxed mode it can read files across your computer while attempting to avoid secret information; in Full access mode it can read any file on your computer. Anything the AI reads can be included in a shared chat.

Before sending, the Application removes passwords, keys, and tokens, replaces images with their size, removes your email address, cuts each item of text to 12,000 characters, and shortens your home folder path to ~. File and folder names below your home folder are included as written. Shared chats are deleted 12 months after they are created. We do not use them to train AI models.

Error reports

While "Send error reports" is on, the Application sends an error report when it encounters an error. An error report contains the type of error, a standard error message, the Application's own file names and line numbers where the error occurred, your operating system, runtime, and Application version, the type and time of recent actions such as a click or navigation, and, if a process stopped, which one and why. Before an error report is sent, the Application replaces file paths and folder names with a placeholder and replaces any non-standard error message with "[message omitted]". Error reports do not include your documents or your account details, and we do not store your IP address with them. Despite these measures, an error report may occasionally contain a fragment of document content. Error reports are sent to our error reporting provider, Sentry, in the United States, and deleted after 90 days.

Your choices

You can turn shared chats and error reports off separately at any time with the "Share chats" and "Send error reports" settings in Settings → Privacy. After you sign in, the Application shows a notice with a link to these settings. Turning a setting off takes effect straight away and stops new data from being sent from that installation; data already being sent at that moment may still arrive. Turning a setting off does not delete data already sent. To have that data deleted, or to object to this processing, email [email protected].

Who receives your data

Nutrient staff who operate and improve the Application, and the service providers listed below and on the Nutrient Trust Center, which process data on our behalf. These include Fly.io, which hosts the shared chats service, Functional Software, Inc. (Sentry), which receives error reports, and the AI model providers used by DWS. We may also disclose data where the law requires it, or to a successor in a merger or acquisition. We do not sell your personal data.

International transfers

Some of our service providers are in the United States. Where your data is transferred outside the European Economic Area, we rely on the EU–U.S. Data Privacy Framework or the European Commission's standard contractual clauses. For Fly.io, we rely on the European Commission's standard contractual clauses. For Sentry, we rely on the EU–U.S. Data Privacy Framework, with the standard contractual clauses as a fallback.

Your rights

Under the GDPR, you have the right to access your personal data, to correct it, to have it erased, to restrict or object to its processing, and to receive it in a portable format. To use these rights, email [email protected]. We answer within one month. For complex requests, we may extend this by up to two further months, and we will tell you if we do. You also have the right to complain to a data protection authority, in particular in the EU country where you live or work. In Austria, that is the Austrian Data Protection Authority (Datenschutzbehörde). If you are in the United Kingdom or the United States, the sections below explain additional rights and information that apply to you.

You do not have to give us personal data, but without your account data the Application cannot sign you in or provide its features. We do not make decisions based solely on automated processing that have legal or similarly significant effects on you.

Users in the United Kingdom

If you are in the United Kingdom, the UK GDPR and the Data Protection Act 2018 apply to our processing of your personal data. You have the same rights described under "Your rights", and the same legal bases described under "What we collect and why" apply.

UK representative. Nutrient has group companies in the United Kingdom, including Aquaforest Ltd and Muhimbi Ltd. Aquaforest Ltd, Midshires House, Midshires Business Park, Smeaton Close, Aylesbury, Buckinghamshire, HP19 8HL, United Kingdom, acts as our representative in the United Kingdom for the purposes of the UK GDPR. You can contact it instead of us about any question relating to your personal data.

International transfers. Where we transfer your personal data from the United Kingdom to a country that does not have UK adequacy regulations, we rely on the UK Extension to the EU–U.S. Data Privacy Framework, or on the UK International Data Transfer Addendum to the European Commission's standard contractual clauses. For Sentry, we rely on the UK Extension to the EU–U.S. Data Privacy Framework, with the UK International Data Transfer Addendum as a fallback. For Fly.io, we rely on the UK Extension to the EU–U.S. Data Privacy Framework.

Complaints. If you have a concern about how we use your personal data, please contact us first at [email protected]. We will acknowledge your complaint within 30 days and tell you the outcome without undue delay. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

Users in the United States

This section applies to residents of US states with comprehensive privacy laws, including California, Colorado, Connecticut, Virginia, and Texas. It supplements the rest of this policy.

Categories of personal information we collect. In the past 12 months, we have collected the following categories of personal information, from you and from your use of the Application, for the purposes and with the retention periods described under "What we collect and why": (i) Identifiers: your email address, Nutrient account identifier, organization identifier, and session identifiers; (ii) Internet or other electronic network activity: shared chats, which record your instructions, the AI's responses, the tools the AI runs, and the actions you take in the Application, and error reports; (iii) Content you provide: document text and file contents that the AI reads and that are included in shared chats; and (iv) Device information: your operating system, runtime, and Application version.

Sensitive personal information. We do not ask for sensitive personal information. Documents and files you work on may contain it, and it can then be included in shared chats. We do not use sensitive personal information to infer characteristics about you, and we use it only for the purposes described in this policy. You can stop it from being shared by turning off "Share chats".

Disclosures. We disclose the categories above to the service providers described under "Who receives your data", for the business purposes described in this policy. We do not sell your personal information. We do not share it for cross-context behavioral advertising or targeted advertising, and we do not use it for profiling that produces legal or similarly significant effects. We have not done any of these things in the past 12 months. We do not knowingly sell or share the personal information of anyone under 16.

Your rights. Depending on your state, you have the right to: (i) know what personal information we have collected about you, and get a copy of it in a portable format; (ii) correct inaccurate personal information; (iii) delete your personal information; (iv) opt out of the sale or sharing of your personal information, targeted advertising, and profiling (we do none of these); and (v) not be discriminated against for using your rights.

How to use your rights. Email [email protected]. We will verify your request by confirming that it comes from the email address linked to your Nutrient account. You can use an authorized agent to make a request for you. We may ask the agent for proof that you authorized them, and may ask you to verify your identity directly. We will respond within 45 days, and may extend this by a further 45 days where reasonably necessary, in which case we will tell you.

Appeals. If we deny your request, you can appeal by emailing [email protected] with "Appeal" in the subject line. We will respond within the time your state's law requires. If you disagree with the outcome, you can contact your state attorney general.

California residents. The rights above include your rights under the California Consumer Privacy Act, as amended. We do not offer financial incentives in exchange for your personal information.

Security

We protect personal data with technical and organizational measures, including encryption in transit and access controls on the systems that store it.

Children

The Application is not intended for anyone under 16. We do not knowingly collect personal data from anyone under 16.

Changes to this policy

We may update this policy. We will tell you about material changes in the Application before they take effect.

Contact

PSPDFKit GmbH, Kaiserstrasse 117/17, 1070 Vienna, Austria. Email: [email protected].