reMarkable is established in Norway, and adheres to the General Data Protection Regulation (GDPR). reMarkable processes personal data relating to customers and other persons who have contacted reMarkable. The different types of personal data processed, as well as the purpose of the processing, legal basis and source are further described below.
REMARKABLE’S CUSTOMERS AND USERS
reMarkable processes the following data for the purpose of providing our customers with the products and services the customer has ordered, including entering into an agreement, placing a purchase, processing payment, delivering the product and the cloud service with its connected features. We also provide our customers and users with information relevant to the product and the cloud service (e.g. user manuals, software updates, etc.):
- Contact and payment information: Name, e-mail address, phone number, credit card information or other payment information.
- Device information: a reMarkable ID (e-mail address), IP-address, wi-fi password (stored locally on the customer’s device, and not otherwise transferred to or accessed by reMarkable). Storage of data, information and documents the customer uploads, enters into or generates in reMarkable’s cloud service.
After a purchase, we store your order and service details to ensure that we can provide you with the rights you are granted in our terms and conditions.
The legal basis for the processing is fulfilling an agreement to which the customer/user is party.
The data is provided to reMarkable by the customer or user when purchasing a product or using a service from reMarkable, or subsequently provided or generated by the customer when using reMarkable’s cloud service. reMarkable ID is generated by reMarkable upon registration to the cloud service. If a customer does not wish to provide the necessary contact and payment information, the customer will be unable to purchase or use reMarkable’s products and services.
reMarkable processes the following personal data for the purpose of sending marketing to the customer as well as finding potential new customers based on similarities between the customer and the potential customer, using social media tools such as lookalike audience and similar:
- Contact information: E-mail address
The legal basis for the processing is consent from the data subject, which is voluntary to submit.
The data is provided to reMarkable by the customer. The customer can choose to provide this information in the ordering process. If you have given a previous consent you now wish to withdraw, either choose the “unsubscribe” option provided in our marketing e-mails or contact reMarkable via email@example.com.
SUBSCRIBERS TO REMARKABLE’S NEWSLETTER
reMarkable processes the following personal data for the purpose of providing subscribers with the newsletters the subscriptions comprise:
- Contact information: E-mail address
The legal basis for the processing is consent, which is voluntary to submit.
The data is provided to reMarkable by the subscriber. The subscriber can at any time choose the “unsubscribe” option included in our newsletter should the subscriber no longer wish to be a recipient of the newsletter.
CUSTOMERS AND OTHERS CONTACTING REMARKABLE’S SUPPORT SERVICE
reMarkable has a support service on our web site which is open for everyone to use if they have questions about our products and services, both before and after purchase. reMarkable processes the following information for the purpose of answering any question or inquiry received by reMarkable’s support service:
- Contact information: e-mail address
- Any other requested and unrequested information sent to reMarkable in the inquiry
The legal basis for the processing is fulfilling an agreement as requested by the inquirer.
The data is provided to reMarkable by customer/sender.
DISCLOSURE TO THIRD PARTIES
reMarkable does not disclose the personal data to unauthorized third parties. Any transfer of personal data is in accordance with law.
HOW LONG IS THE DATA STORED?
reMarkable deletes or irreversibly anonymizes data as soon as the purpose of the processing is fulfilled or we are no longer required by law to store your data:
reMarkable’s customers and users
Data uploaded or generated by the customer when using reMarkable’s cloud service is deleted 3 months after the customer has deleted their account. The customer may delete data at any time through the cloud service.
Name, contact information and order details are deleted when they are no longer necessary to fulfill the purpose of processing, and when they are no longer necessary to process in order to fulfil legal obligations or for reMarkable to be able to handle claims and complaints.
Subscribers to reMarkable’s newsletter
The personal data is deleted when the subscriber unsubscribes to reMarkable’s newsletter or when the newsletter is discontinued.
Customer data relating to reMarkable’s cloud service is irreversibly anonymized, and thereafter used in anonymized and aggregated form for statistical purposes, as well as for improvement and development of reMarkable’s products and services. Anonymized data may also be used for other purposes. The legal basis for the anonymization is our legitimate interest and it is not overridden by your rights.
Your rights under GDPR:
• Requesting information about the processing of personal data and access to the data
• Rectification and deletion of inaccurate or incorrect data
• Restriction of processing
• Objecting to processing
• Data portability
• Being forgotten
If you are a customer permanently located in California, US, you have the following rights:
• Deletion of personal data, unless reMarkable has a legal obligation to store the personal data
• Requesting information about the processing of personal data and access to the personal data collected by reMarkable
• Non-discrimination where you exercised your rights under the CCPA
Customers with a subscription to the cloud service may at any time rectify and/or delete personal data by logging into their user account. Persons who are registered or believe they are registered by reMarkable can contact reMarkable at by mail or e-mail for any use of their rights: reMarkable AS, Biermanns gate 6, 0473 Oslo, Norway or email at firstname.lastname@example.org.
If you are dissatisfied with reMarkable’s processing of personal data or have questions or inquiries concerning reMarkable’s processing of personal data, please write to reMarkable at Biermanns gate 6, 0473 Oslo, Norway or email us at email@example.com. We are happy to assist. Data subjects may also file a complaint by contacting the Data Protection Authority in Norway or if the customer is resident elsewhere in Europe their local data protection authority.
Last updated: July 1st, 2020.