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| Viewing: https://notability.com/privacy | [Back] [Original] |
Effective date: August 21, 2025
At Ginger Labs, we know you care about how your personal information is used and shared, and we take your privacy seriously. We only collect and process your personal data as necessary to develop, provide, and improve our Services, as required by law, or for the limited purposes stated in this Privacy Policy, including marketing the Services. Please read this Privacy Policy to learn how we treat your personal data.
This Privacy Policy only applies to our processing of personal data in connection with the Notability Services. Notability is one of our products and services. Your use of our other products and services and their associated websites, applications, and other materials are subject to other terms applicable to them.
As described in our Terms of Use, if you are using the Services in MDM Mode (as defined in the Terms of Use), you're also subject to the Additional Terms and Privacy Notice to MDM Users (the Additional MDM Terms"). Specifically, the Additional MDM Terms explain how we deal with the collection and processing of the personal information of users under the age of 16 and what features that collect personal information may be disabled for such users under the separate experience of the MDM Mode. In the event of a direct conflict between this Privacy Policy and the Additional MDM Terms, the Additional MDM Terms shall prevail with respect to your use of the Services under the MDM Mode.
By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and disclose your information as described in this Privacy Policy.
Remember that your use of Notability's Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use.
You may print a copy of this Privacy Policy by clicking here.
If you have a disability, you may access this Privacy Policy in an alternative format by contacting [email protected].
This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. Personal Data means any information that identifies or relates to a particular individual and also includes information referred to as personally identifiable information or personal information under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we dont own or control or people we dont manage.
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
| Category of Personal Data (and Examples) | Business or Commercial Purpose(s) for Collection | Categories of Third Parties With Whom We Disclose this Personal Data |
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| Profile Data such as first and last name, email, and unique identifiers. |
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| Payment Data such as financial and account information, payment card type, last 4 digits of payment card, and billing address, phone number, and email. |
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| Device/IP Data such as IP address, device ID, and type of device/ operating system/ browser used to access the Services. |
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| Web Analytics such as the date and time of visit and links clicked in emails. |
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| Consumer Demographic Data such as age and/or date of birth. |
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| Geolocation Data such as IP-address-based location information. |
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| Sensory Data such as audio recordings of you and/or of your environment. |
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| Identifying Information in Your Synced Data such as notes, texts, handwritten contents, pictures, documents, audio recordings synced by you with the Services. |
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| Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, or other communications you send us. |
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We collect Personal Data about you from the following categories of sources:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.
As described in our Terms of Use, you represent, warrant, and agree that you will not contribute any Input Content or other content that contains Prohibited Data in connection with your use of the Services, except that the foregoing doesn't prohibit you from storing or processing such data on (and only on) your local device(s). We reserve the right to disable all the features that allow you to submit any data/content to our servers if you violate the foregoing, and repetitive violations of the foregoing is ground for termination of your right to use or access the Services.
"Prohibited Data" means:
We only disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the U.S. State Privacy Rights section below.
We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under Meeting Legal Requirements and Enforcing Legal Terms in the Our Commercial or Business Purposes for Collecting Personal Data section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it to third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.
The Services use tracking technologies such as pixel tags, cookies, web beacons, clear GIFs and JavaScript (collectively, "Tracking Tools") to enable our servers to recognize you, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Tracking Tools are small pieces of data usually text files placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Tracking Tools on your device(s). Please note that because of our use of Tracking Tools, the Services do not support "Do Not Track" requests sent from a browser at this time.
We use the following types of Tracking Tools:
You can decide whether or not to accept Tracking Tools through your internet browser or device settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new Tracking Tools, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Tracking Tool in a variety of ways. You can also delete all Tracking Tools that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Tracking Tool settings are available to you or to modify your preferences with respect to Tracking Tools, you can navigate to your device settings by selecting Settings > General > Privacy & Security > Tracking and toggle off permission for the Notability application. To find out more about cookies, including information about how to manager and delete cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Except for if you are using the Services in MDM Mode, we may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors ("Interest-Based Ads"). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users' activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Tracking Tools, including a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites and may allow ad networks to view, edit or set their own cookies on your browser if applicable, just as if you had requested a web page from their site.
When you use our Services on your local devices, such as by using the Notability downloadable apps, some of your data (such as your notes) will be stored locally on these devices. You may choose to keep your data stored locally and not sync it with our Services. Data that is stored locally and not synced is only accessible to you. We do not have access to your local data.
If you decide to sync your data with the Services, such Synced Data will be replicated on servers maintained in the United States. This means that if you store information in or submit data to the Notability app or website, and sync such app or website with the Services, you acknowledge your personal data will be transmitted to, hosted, and accessed in the United States.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. No one at Ginger Labs can view your Synced Data unless you expressly give us permission or it's necessary to comply with our obligations in the Terms of Use, this Privacy Policy, or any legal requirements. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
The Children's Online Privacy Protection Act (COPPA) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13 years of age.
As described in our Terms of Use, we offer different experiences to users under the Individual Mode as compared to users under the MDM Mode, and please refer to the Additional MDM Terms that explain how we deal with the collection and processing of personal information of users under the age of 16 and what features that collect personal information may be disabled for such users under the separate experience of the MDM Mode.
If you reside in certain U.S. states such as California, Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia you may have certain rights afforded to you (as described below) depending on your state of residence. Please see the Exercising Your Rights under U.S. State Privacy Laws section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers' end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Please note that your rights may be subject to certain conditions or exceptions in accordance with applicable U.S. State Privacy Laws. If you have any questions about this section or whether any of the following rights apply to you, please contact us at [email protected].
Depending on your state of residence, you may have the right to opt out from the "sale," "share," or disclosure of your Personal Data for the purposes of targeted advertising. These or similar terms may be defined differently depending the applicable U.S. State Privacy Law.
You have the right to opt-out of the sale or share of your Personal Data by following the instructions in the Exercising Your Rights under U.S. State Privacy Laws section. Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months.
As described in the Tracking Tools, Advertising and Opt-Out section above and except if you are using the Services in MDM Mode, certain Tracking Tools placed by third parties into our Services may allow those third parties to collect your Personal Data for targeted advertising purposes. Under certain U.S. State Privacy Laws, this may also constitute a "sale" and/or "share" of your Personal Data. For clarity, when we use the term "sell," we mean for valuable consideration and not for any monetary value.
We sell or share your Personal Data to the following categories of third parties:
Over the past 12 months, we have sold or shared the following categories of your Personal Data to categories of third parties listed above:
We do not use your Private User Submissions or Limited Audience User Submissions (for example, your personal notes, recording, images, or documents) for the purposes of targeted advertising.
To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.
We will not discriminate against you for exercising your rights under applicable privacy laws. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under applicable privacy laws. However, we may offer different tiers of our Services as allowed by applicable data privacy laws with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties' direct marketing purposes; in order to submit such a request, please contact us at [email protected].
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. You can exercise this right by contacting us at [email protected] with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account.
To exercise the rights described in this Privacy Policy, you or your Authorized Agent (if applicable and as defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data (such as your Profile Data), and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a "Valid Request." We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
To opt-out from any sales, shares, or targeted advertising through Tracking Tools, you can navigate to your device settings by selecting Settings > General > Privacy & Security > Tracking and toggle off permission for the Notability application.
As applicable, you may submit a Valid Request for your right to access, delete, correct, or obtain a copy of your Personal Data described in this Privacy Policy by emailing us at [email protected].
If you are a California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey Oregon, or Texas resident, you may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
If you are a Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia resident and we refuse to take action on your request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the State Privacy Laws (as applicable). We will respond to your appeal within the time period required under the applicable law. You can submit a Verified Request to appeal by emailing us at [email protected] (title must include "[STATE OF RESIDENCE] Appeal").
If we deny your appeal, you have the right to contact the Attorney General of your State, including by the following links: Colorado, Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, and Virginia.
If you are a resident of the European Union ("EU"), United Kingdom ("UK"), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the "GDPR") with respect to your Personal Data, as outlined below.
For this section, we use the terms "Personal Data" and "processing" as they are defined in the GDPR, but "Personal Data" generally means information that can be used to individually identify a person, and "processing" generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Notability will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected]. Note that we may also process Personal Data of our customers' end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
The Categories of Personal Data We Collect section above details the Personal Data that we collect from you.
The Our Commercial or Business Purposes for Collecting Personal Data section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our "legitimate interests" or the legitimate interest of others, as further described below.
Examples of these legitimate interests include (as described in more detail above):
The How We Disclose Your Personal Data section above details how we disclose your Personal Data with third parties.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at [email protected]. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
The Services are hosted and operated in the United States ("U.S.") through Notability and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Notability in the U.S. and will be hosted on U.S. servers, and you authorize Notability to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses and/or the Data Privacy Framework(s), as discussed below.
Notability complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"), the UK Extension to the EU-U.S. DPF ("UK-U.S. DPF"), and the Swiss-U.S. Data Privacy Framework ("Swiss-U.S. DPF") as set forth by the U.S. Department of Commerce. Notability has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles ("EU-U.S. DPF Principles") with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF (the "EU-UK DPF Principles"). Notability has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles ("Swiss-U.S. DPF Principles") with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles shall govern. To learn more about the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-US DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/.
The Federal Trade Commission has jurisdiction over Notability's compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. This Privacy Policy describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data, and the purposes for which we disclose your Personal Data to certain types of third parties in the sections above. Pursuant to the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to them in the U.S. Upon request, we will provide EU, UK, and Swiss individuals with access to the Personal Data that we hold about them. EU, UK, and Swiss individuals may also correct, amend, or delete the Personal Data we hold about them where it is inaccurate, or has been processed in violation of the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy in the case in question, or where the rights of persons other than the individual would be violated. An EU, UK, and Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, should direct their query to [email protected]. If requested to remove data, we will respond within a reasonable timeframe. For more information about rights afforded to EU, UK, and Swiss individuals, please see the European Union, United Kingdom, and Swiss Data Subject Rights section of this Privacy Policy.
In addition, under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, we will provide EU, UK, and Swiss individuals with the choice to opt-out from the sharing of their Personal Data with any third parties (other than our agents or those that act on our behalf or under our instruction), or before we use it for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized.
In addition to any other disclosures described in our Privacy Policy, in certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Notability's accountability for Personal Data that it receives in the U.S. under the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on our behalf is described in the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles. In particular, Notability remains liable under the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles if our agents process Personal Data in a manner inconsistent with the EU-U.S. DPF Principles, the EU-UK DPF Principles, and the Swiss-U.S. DPF Principles, unless Notability proves that we are not responsible for the event giving rise to the damage.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Notability commits to resolve EU-U.S. DPF Principles, EU-UK DPF Principles, and Swiss-U.S. DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should first contact Notability at [email protected].
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Notability commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the U.S. If you are an EU, UK, or Swiss individual and you do not receive timely acknowledgment of your EU-U.S. DPF Principles, EU-UK DPF Principles, or Swiss-U.S. DPF Principles-related complaint from us, or if we have not addressed your EU-U.S. DPF Principles, EU-UK DPF Principles, or Swiss-U.S. DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.
If your EU-U.S. DPF, UK Extension to the EU-U.S. DPF, or Swiss-U.S. DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the Data Privacy Framework Principles, located at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.
We're constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to material changes by placing a notice on the Notability website, by sending you an email and/or by some other means. Please note that if you've opted not to receive legal notice emails from us (or you haven't provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.
If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:
If you are located in the EU or UK, you may use the following information to contact our EU and UK Representative:
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