II. DATA CONTROLER
Unless otherwise stated in a service-specific privacy notice, the data controller responsible for processing your information depends on where you are based is:
FileCloud Technologies Limited
Hamilton House 2,
Company registration number IE 3991657RH.
Email: You may submit inquiries regarding personal data protection, privacy and security matters to: email@example.com
III. WHAT IS FILECLOUD AND WHAT PRODUCTS DOES IT OFFER?
IV. GENERAL INFORMATION ABOUT THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA
1. What categories of persona data does FileCloud collect?
Our Services have optional features which and if used, we may require additional information. You will be notified of such a collection, as appropriate before the processing activity and with the observance of the applicable legal provisions. If you choose not to provide the information needed to use a feature, you will be unable to use the feature.
We receive and store personal data such as:
A. Information you provide to us:
We collect information you provide to us which includes:
- a. your name, email address, telephone number, country of residence, region, address, company you are employed with or represent. We collect this information in a number of ways, including when you enter it while registering on our Site, when you update your account, interact with our customer service, or participate in surveys. We refer to this information as User Data;
- b. Information required for troubleshooting technical issues related to using FileCloud software, via emails, discussion forums and other avenues
- c. payment method(s) (cardholder name, card expiration date, the card type, and certain digits of your card number (Note: For security, we never store your full card number), and CVV / CVC code; this information is transmitted to our payment processor. We refer to this information as Payment and Purchase Data.
- d. When you respond to a survey or take part in user research, we collect and use the personal data you provide. We refer to this information as Survey and Research Data.
B. Information we collect automatically:
We collect information about you and your use of our Services, your interactions with us and our advertising, as well as information regarding your network, network devices, and your computer or other capable devices you might use to access our service (e.g. mobile devices). We refer to this information as Usage Data.
This information includes:
- a. your interactions with our emails and texts, and with our messages through push and online messaging channels;
- c. device IDs or other unique identifiers, including for your network devices (such as your router);
- d. device and software characteristics (such as type and configuration), connection information including type (Wi-Fi, cellular), statistics on page views, referring source (for example, referral URLs), IP address (which can be used to tell us your general location, such as your city, state/province, and postal code), browser and standard web server log information;
C. Information from other sources:
- b. security service providers that provide us with information to secure our systems, prevent fraud and help us protect the security of our accounts;
- c. payment service providers that provide us with payment or balance information, or updates to that information, based on their relationship with you.
2. How does FileCloud use this information and for what purpose?
The table below sets out:
- our purpose for processing your personal data;
- our legal justifications (each called a “legal ground”) under data protection law, for each purpose;
- categories of personal data which we use for each purpose.
Here is a general explanation of each legal ground to help you understand the table:
- Performance of a Contract (Legal ground: Article 6 paragraph (1) letter (b) of the GDPR):
When we (or a third party) process your personal data in order to:
- verify information before a new agreement with you is concluded.
- Legitimate Interest (Legal ground: Article 6 paragraph (1) letter (f) of the GDPR):
When we or a third party has a legitimate interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and other users.
- Consent (Legal ground: Article 6 paragraph (1) letter (a) of the GDPR): When we asks you to actively indicate your agreement to our use of your personal data for a certain purpose.
- Compliance with Legal Obligations (Legal ground: Article 6 paragraph (1) letter (c of the GDPR): When we must process your personal data to comply with any applicable legal provisions.
|Purpose for processing your data
|Legal basis that permits the purpose
|Categories of personal data used for the purpose
To provide our Services and/or Products to you. For example, when we use your personal data to:
|Performance of a Contract
|To provide certain additional voluntary features of our Services. When this is the case, we will clearly ask for your consent.
|To evaluate and develop new features, technologies, and improvements to our Site. For example:
Our legitimate interests here include developing and improving Products/Services and features for our users.
|For other marketing, promotion and advertising purposes where the law does not require consent. For example, when we use your personal data to tailor advertising to your interests.
To comply with a legal obligation that we are subject to. This might be:
|Compliance with Legal Obligations
|To comply with a request from law enforcement, courts, or other competent authorities.
|Compliance with legal obligations, and legitimate interest. Our legitimate interests here include assisting law enforcement authorities to prevent or detect serious crime.
|To fulfil contractual obligations with third parties.
|Performance of a Contract
|To take appropriate action with reports of intellectual property infringement and inappropriate content.
Our legitimate interests here include protecting intellectual property and original content.
|To establish, exercise, or defend legal claims. For example, if we are involved in litigation and we need to provide information to our lawyers in relation to that legal case.
Our legitimate interests here include:
|To conduct business planning, reporting, and forecasting. For example, when we look at aggregated user data like the number of new sign ups in a country in order to plan new locations to launch our products and features in.
Our legitimate interests here include researching and planning so that we can keep running our business successfully.
|To process your payment. For example, when we use your personal data to let you purchase a subscription.
|Performance of a Contract
|To keep our Website secure and to detect and prevent fraud. For example, when we analyse Usage Data to check for fraudulent use of the Services.
Our legitimate interests here include protecting our Website and our users against fraud and other illegal activity.
|To conduct research and surveys. For example, when we contact our users to ask for your feedback.
Our legitimate interests here include to understand more about how users think about and use our Services.
V. LEGAL FRAMEWORKS FOR DATA TRANSFERS
Except as mentioned below, we shall not sell, rent, trade or otherwise transfer any personal and/or traffic data or communications content to any third party without your explicit consent, unless it is obliged to do so under applicable laws or by order of the competent authorities.
In addition, disclosure may take place in connection with official enquiries, court orders and legal proceedings if it is necessary for legal prosecution or enforcement. When governments make a lawful demand for customer data from us, we strive to limit the disclosure. We will only release specific data mandated by the relevant legal demand.
If compelled to disclose your data, we will promptly notify you and provide a copy of the demand unless legally prohibited from doing so.
If we commission third parties with the collection, processing and use of data within the scope of commissioned processing in accordance with Art. 28 GDPR, this will also take place exclusively in compliance with the statutory provisions on data protection.
Data Transfer to third Countries
Where the European Commission has not issued an adequacy decision (Art. 45 GDPR) for the aforementioned countries, we have taken appropriate precautions to ensure an adequate level of data protection for any data transfers.
If a third country transfer is provided for and no adequacy decision or appropriate safeguards are in place, it is possible and there is a risk that authorities in the respective third country (e.g. intelligence services) may gain access to the transferred data in order to collect and analyze it, and that enforceability of your data subject rights cannot be guaranteed. In this situation, we will rely on Article 49 paragraph (1) letter a) of the GDPR, and obtain your prior consent.
VI. LINKED WEBSITES AND THIRD-PARTY APPLICATIONS
VII. HOW DOES FILECLOUD PROTECT YOUR PERSONAL INFORMATION?
FileCloud shall take appropriate organizational and technical measures to protect the personal data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. Your customer profile and traffic data can only be accessed by authorized employees or consultants of FileCloud that need to have access to this data in order to be able to fulfill their given duties.
VIII. CONTACTING YOU
FileCloud may, as an opt-in feature, from time to time ask you to provide feedback on your experiences which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the website or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the FileCloud software products and websites.
Your continued use of the site after such modifications will constitute your:
(a) acknowledgment of the modified Policy; and
X. YOUR PERSONAL DATA RIGHTS AND CONTROLS
The table below explains:
- your rights
- circumstances when they apply (such as the legal basis required)
- how to use them.
|Description of your rights
|Be informed of the personal data we process about you and how we process it
|Request access to the personal data we process about you
|Request that we amend or update your personal data where it’s inaccurate or incomplete.
Request that we erase certain of your personal data. For example, you can ask us to erase personal data:
|Request that we stop processing all or some of your personal data. You can do this if:
|Object to us processing your personal data. You can do this if:
|Request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service.
|Not be subject to automated decision making
|Not be subject to a decision based solely on automated decision making (decisions without human involvement), including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
|Withdrawal of consent
|Withdraw your consent to us collecting or using your personal data. You can do this if we process your personal data on the legal ground of consent.
|Right to lodge a complaint
|Contact the Authority for Privacy Protection about any questions or concerns.
Please send your requests to firstname.lastname@example.org. We will respond to your requests within a reasonable period of time and upon verification of your identity. FileCloud will use its best endeavors to accommodate all your requests in due time.
XI. STORAGE AND DELETION OF YOUR DATA
As a general rule we only store personal data for as long as is necessary to fulfill contractual or legal obligations for which we collected the data. After that, we delete the data immediately, unless we still need the data until the expiry of the statutory limitation period for evidence purposes for claims under civil law or due to statutory retention obligations.
We delete or block the personal data of the data subject as soon as the purpose of the storage is fulfilled. It may also be stored if provided for by the European or national legislator in EU regulations, laws or regulations to which we are subjected to.
XII. MINIMUM AGE REQUIREMENT TO USE FILECLOUD AND OTHER PRODUCTS
You must be at least 18 years old to have our permission to use this site. Our policy is that we do not knowingly collect, use or disclose information about visitors that are under 18 years of age.
XIII. MISCELLANEOUS PRIVACY ISSUES
Date of Last Revision: November 16, 2023