Last revised on 1st September 2023

This policy has been drafted to be compliant with the European General Data Protection Regulation (GDPR) and is provided to explain what information we collect when you visit our website or when you use our services, how we use it and the choices you can make about it. For your convenience we made it accessible from every page of our website.


These definitions should help you understand this policy.

  • "We" or "Us" refers to Sober Lemur S.r.l.
  • “You” or “your” refers to the individual who uses our Website, Downloadable product, and services, or engages with us directly by email
  • "Website" refers to or any related subdomain
  • "Downloadable product" or "Desktop application" refers to software products that can be downloaded from our Website

Scope of Privacy Policy

This Privacy Policy is effective with respect to any data that we have collected, or collect, about and/or from you through your use of our Website or Downloadable Products.

Information collection

Information we collect from visitors of our Website

“Automatically Collected" Information

When you browse our Website we may, directly or through our third party partners, automatically collect certain information about your visit for statistical purposes, by using various types of technology, including cookies, "clear gifs" or "web beacons". The information we automatically collect may include but are not limited to:

  • IP address
  • Date, time and duration of your visit
  • Browser and/or device type
  • Operating system

You can opt out from the collection of navigation information about your visit to our Website by Google Analytics by using the Google Analytics Opt-out feature.

Support requests

When you contact us with a support request or other customer service requests, through an online form available on the Website, by sending us an email or by other means of communication, we maintain support tickets and other records related to the requests, including any information you provided related to such requests. We use these information to provide you with proper support and fulfill your request.

We use third-party service providers to manage customer requests. These third parties are governed by their own Privacy Policies (Zendesk, GrooveHQ, Lulu, InMotion and Gmail).

Cookie Information

We use cookies and similar technologies in our Website. For more details about how we use these technologies and how to disable the non-necessary ones, please refer to our full Cookies Policy.

Information we collect from users of our Desktop applications

All our applications process PDF files locally. No content in your PDF files is automatically sent or uploaded to our servers from our desktop applications.

PDFsam Basic

Nothing is sent and/or collected by PDFsam Basic

PDFsam Enhanced

PDFsam Enhanced desktop application is provided and operated by LULU Software 7075 Robert-Joncas Place, Suite 142 Saint-Laurent, QC H4M 2Z2 Canada. The usage and purchase of the software is governed by their own Privacy Policies.

PDFsam Visual

Customer information

When you purchase a PDFsam Visual license (perpetual or subscription), we collect information to process your payment, for accounting purposes, to send you necessary communications (for example, related to payments or expiration of your subscription) and to comply with our contractual obligations when providing our service to subscribers and customers. This information may include but it's not limited to:

  • Email address
  • Physical address
  • Telephone number
  • Company name
  • First billing date
  • Current billing status
We use third-party service providers for payments processing, invoicing, licenses and subscriptions managing purposes. These third parties are governed by their own Privacy Policies (Fatture In Cloud, MongoDB Atlas and FastSpring).

Desktop application information

When using PDFsam Visual, it may communicate with our servers for licensing purpose, updates checking and news checking and we may collect information about the device and the product used in order to verify your customer status and prevent abuses. Information that qualifies as Personal Information is anonymized as requested by the GDPR. This information may include but it's not limited to:

  • Type of device
  • Application version
  • Operating system
  • Username
  • Hostname

Desktop application error reporting

When PDFsam Visual encounters an error, a troubleshooting report may be sent to our server and we may collect information about the error. Troubleshooting reports may be automatically sent if the user opts-in the relevant option in the settings panel. A troubleshooting report may include but it's not limited to:

  • Type of device
  • Details about the failed operation (may include files path, logs and other details about the system running the PDFsam Visual)
  • Operating system
  • Available RAM

We use these information to fix software defects and improve our products. We use third-party service providers to manage troubleshooting reports. These third parties are governed by their own Privacy Policies (Zendesk, GrooveHQ and MongoDB Atlas).

How we use the collected information

We use the information that we collect to operate our business and provide our services, send you marketing communications, respond to your requests, improve our Downloadable products and Website.

How we share the collected information

Except as described in this Privacy Policy, we will not intentionally disclose any personal data that we collected to third parties without your consent.

Third party services

We work with third party service provides who provide hosting, maintenance, issue tracker, help ticket system, billing platform and other services for us. These third parties may have access and/or process your information as part of providing those services for us.

Law enforcement

We will disclose your information where required to do so by law, if subject to subpoena or other legal proceeding or if we believe in good faith that such action is necessary to:

  • Comply with the law and the reasonable requests of law enforcement
  • Protect ourselves or others from fraudulent, abusive, or unlawful uses or activity
  • Investigate and defend ourselves against any third-party claims or allegations
  • Protect the security or integrity of our Website and Desktop applications and any facilities or equipment used to make them available
  • Enforce our contracts, or protect the rights, property, or safety of others

Change of Ownership

We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Information we collected about you may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company. We will notify you via a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.


We may revise this Privacy Policy from time to time. All changes to this Privacy Policy are effective when they are posted on this page and the effective date located at the top of this page is updated. When we change the policy in a material manner, we will let you know via a prominent notice on our Website. We encourage you to check this page periodically for any change. If any change to this Privacy Policy is unacceptable to you, you must immediately contact us and stop using the Website and our Downloadable products until the issue is resolved.

Data Transfer

The collected information may be stored and processed in the United States, Europe, or any other country in which we or our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that we collect about you, including personal information, to affiliated entities, or to other third parties across borders and from your home country or jurisdiction to other countries or jurisdictions around the world where data protection and laws governing data collection may be different from those in your home country.


We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect your personal data from unauthorized access, improper use or disclosure, unauthorized modification or unlawful destruction or accidental loss and any other unlawful form of processing. This includes, for example, password protection and other access and authentication controls and SSL technology to encrypt data during transmission through public internet. However, you acknowledge that no environment is completely secure or error-free, and that these processes, systems, and technologies utilized and maintained are subject to compromise. Accordingly, we cannot be held responsible for unauthorized or unintended access that is beyond our control. In the event that personal information is compromised as a breach of security, we will promptly notify our customers in compliance with applicable law.

External links

Our Website may contain links to third party sites. We don't control and we are not responsible for the privacy practices of those websites. Please remember that when you use a link to go from our Website to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link or advertisement on our Website, are subject to that third party’s own rules and policies.

Do Not Track

The term do-not-track refers to a feature certain web browsers offer to request that websites refrain from tracking the user. We take no action in response to do-not-track requests.

Your rights

Subject to applicable law, you may have rights available to you in respect of your personal data, including:

  • Request a copy of the information that we hold about you
  • Rectify your personal data if inaccurate or incomplete
  • Delete your personal data. We may retain your personal data if it is required to comply with legal obligation, for backups, archiving, prevention of fraud and abuse, analytics, or where we in good faith believe that we have a legitimate reason to do so
  • Change your preference and opt out of receiving certain marketing communications from us by clicking the unsubscribe link included on the bottom of all such communications, or by contacting us

Children’s Privacy

We don't knowingly collect or solicit personal information from anyone under the age of 16. In the event that we learn that we have collected personal information from a child under age 16, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us.

Contact us

If you have any questions or comments, or if you want to modify or delete any personal information we hold, if you have any concern about the way in which we have handled any privacy matter, the data controller you should contact is Sober Lemur S.r.l..

  • by email at [email protected]
  • by mail at Sober Lemur S.r.l., via Rosemberg 4, 42021, Bibbiano (Reggio Emilia), Italy