Last updated: July 2, 2024
CILIARA TRADING LIMITED (“we”) welcome you. This Privacy Notice (“Privacy Notice”) applies to our platform (“FormsPal” or “Platform”) available following the link.
The Privacy Notice describes which of your personal data FormsPal collects, how stores, processes, and uses it, and what happens when you use the Platform.
We are the shared controllers of your personal data processed through the Platform. This means that we determine the purposes and means of personal data processing.
| Name | CILIARA TRADING LIMITED | |||
| Organization number | 267435 | |||
| Address | Strovolou 77, Strovolos Center, Office 301, 2018 Nicosia, Cyprus | |||
| support@formspal.com – for general inquiries | ||||
When you visit the Platform, you become our user (“User”).
We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.
| Type of User | Description | ||
| Registered User | User who has registered on the Platform | ||
| Document Builder User | User who builds the document using the templates on the Platform | ||
| Content Uploader | User who uploads the content to the Platform | ||
| Support Requester | User who fills out the “Contact us” form on the Platform | ||
| Please note! We do not knowingly process the personal data of Users under the age of 13. If you are such a User or the legal representative of such a User, please contact us. | |||
We receive your data when you visit the FormsPal and interact with it, depending on your actions on the Platform.
You can change your personal data in FormsPal by exercising your right to rectification or by the Platform’s functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also receive data from third parties. It depends on your settings and the features you use.
To process your personal data, we rely on the following lawful bases:
When you visit the Platform, we collect some data automatically. We collect some technical data about the Users to optimize performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.
Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.
| Data | Reasons for processing | Lawful basis |
| Information about the сoarse location (IP address, country) | The optimization of the performance, debugging, enhancement of the features’ proper functioning, and improvement of the Platform | Legitimate interest |
| Technical device information and network information (including, IP address, HTTP user agent, HTTP referrer, URL) | ||
| Data storage | We store the data for 3 years from its collection | |
We also need cookies to operate, support, and improve the Platform’s functionality.
| Data | Description | Reasons for processing | Lawful basis |
| Necessary cookies | Information that is necessary for the operation of the Website | Improving your experience of using the Website | Performance of the contract |
| Marketing cookies | Marketing information used to match relevant advertising to you | Marketing | Consent |
| Preference cookies | Information necessary for operating some services on the Website | The operation of some services on the Website | Consent |
| Statistics cookies | Information that helps us to understand how you interact with the Website by collecting and reporting information | Improvement of the Website and analysis of the statistic for other purposes | Consent |
| Data storage | We store the data during the expiry period, provided in the Cookie Policy | ||
We collect some of your personal data when you register on the Platform.
| Data | Reasons for processing | Lawful basis |
| To create an account on the Platform | Performance of the contract | |
| Password | ||
| Data storage | We store the data for 3 years from your deletion of the account | |
We collect some of your personal data when you upload, edit or convert your files on the Platform.
| Data | Reasons for processing | Lawful basis |
| Data filled in and other content attached | To provide you with the functionality of the Platform | Performance of the contract |
| Data storage | We do not store your content | |
We collect some of your personal data when you upload, edit or convert your files on the Platform.
| Data | Reasons for processing | Lawful basis |
| Documents and other content attached | To provide you with the functionality of the Platform | Performance of the contract |
| Data storage | We do not store your content | |
We collect some of your personal data when you register on the Platform.
| Data | Reasons for processing | Lawful basis |
| Name | To personalize our response to your request | Performance of the contract |
| To respond to your request | ||
| The text of your message | To fulfill your request | |
| Data storage | We store the data for 3 years after the termination of the Terms of Service | |
We may receive some personal data from third parties.
The amount of data collected, the purposes, and the lawful basis for processing is determined by the respective privacy documents of these third parties.
| Third party | Privacy documents |
| Privacy Policy | |
| Privacy Policy | |
| PayPal | Privacy Statement |
| Checkout | Privacy Policy |
| Solidgate | Privacy Policy |
| Mailchimp | Privacy Statement |
| DropBox | Privacy Policy |
| Microsoft | Privacy Policy |
We receive some data from Solidgate when you buy a single document, monthly or annual subscription to FormsPal. The data may include:
| Data | Reasons for processing | Lawful basis |
| To confirm your payment | Legal obligation | |
| Name and surname of card’s holder | ||
| Masked card number | ||
| Payment confirmation | ||
| Date of the transaction | ||
| Data storage | We store the data for 5 years from the time you unsubscribe from your subscription. | |
Please note! We do not have access to the data you are filling in the payment form in the Platform.
We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organizational and technical measures to ensure the security of personal data during data transfer to third-party.
| Third parties | Description |
| Analytics tools | We use analytics tools to understand and promote our business. |
| Messengers | We use messengers to communicate with you in ways that are convenient for you. |
| Contractors, services providers on Platform | We cooperate with service providers and contractors to provide you with their services, operate, develop, and improve the features and functionality of the Platform, fulfill your support requests, complete payment transactions, etc. |
| Providers of the services our team uses | We use CRM systems, messengers, and other services in our organisation to provide you with our services. |
| State authorities, courts, law enforcement agencies, etc | We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies:
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| To get a detailed list of the third-party recipients of your personal data, contact us. | |
To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.
We apply a variety of security measures appropriate to the possible risks.
| Staff training | Internal policies and instructions |
| Non-disclosure agreements (NDA) | Transfer protection |
| Video monitoring | Signalling |
| Limited access to premises | Round the clock security |
| Two-factor authentication | Backups |
| Firewalls | Encryption technologies |
You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.
Your rights vary depending on the state of your residency, as indicated below.
| Right | Description | Area | |
| Right to access | You can request an explanation of the processing of your personal data. |
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| Right to correct | You can change the data if it is inaccurate or incomplete. |
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| Right to delete | You can send us a request to delete your personal data from our systems. |
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| Right to portability | You can request all the data you provided to us and request to transfer data to another controller. |
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| Right to opt out of sales | The right to opt out of the sale of personal data to third parties. |
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| Right to opt out of certain purposes | The right to opt-out of processing for profiling/targeted advertising purposes. |
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| Right to opt out of processing of sensitive data | The right to opt-out of processing of sensitive data. |
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| Right to opt in for sensitive data processing | The right to opt in before processing of sensitive data. |
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| Right against automated decision-making | A prohibition against a business making decisions about a consumer based solely on an automated process without human input |
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| Private right of action | The right to seek civil damages from a controller for violations of a statute. |
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| To exercise your rights, contact us. | |||
| We will answer your request within 30 to 60 days, depending on the state and legislative requirements. If your complaint is not satisfied, you can submit a complaint with the Federal Trade Commission. | |||
| Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If your state is not on the list, please contact us. | |||
California residents have the right under the California Consumer Privacy Act (“CCPA”) to opt out of the “sale” of their personal information by a company governed by CCPA.
We do not sell your personal information to anyone nor use your data as a business model.
However, we support CCPA by allowing California residents to opt out of any future sale of their personal information. If you would like to record your preference that we will not sell your data in the future, please contact us.
California residents visiting the Platform may request that we do not automatically gather and track information about their online browsing movements across the Internet.
Such requests are typically made through web browser settings that control signals or other mechanisms that allow consumers to exercise choice regarding collecting personal data about an individual consumer’s online activities over time and across third-party websites or online services.
We currently do not have the ability to honor these requests. We may modify this Privacy Notice as our abilities change.
We use cookies that are needed for the Platform’s operation. By using cookies, we receive automatically collected data. You can read more in the Cookie Policy.
If you want to turn off cookies, you can find instructions for managing your browser settings at these links:
The Privacy Notice is developed according to the Delaware Personal Data Privacy Act, US privacy legislation, other applicable privacy laws, and best privacy practices.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Platform.
If there are material changes to the Privacy Notice or the Platform that affect your data privacy rights, we will notify you by displaying information on the Platform and, if necessary, ask for your consent.