Privacy Policy

filess (henceforward "we" or "us") understands that Users care about their privacy and how their personally identifiable information is used and shared. As such, we at filess have a firm commitment to the privacy and protection of our Users.

This Privacy Policy applies to the information we collect via our Service and our Site and describes how we collect and use such information. It also describes the choices available to you regarding our use of your personally identifiable information and how you can opt-out of or access and update this information. By visiting our Site or using our Service, you are consenting to the practices described in this Privacy Policy. This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Service or our Site.

All individuals whose responsibilities include the processing of personally identifiable information on our behalf are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Capitalized terms that are not defined in this Privacy Policy have been defined in our Terms of Service (available at https://filess.io/company/legal/tos/ ). Therefore, please make sure you have read and understand our Terms of Service.

filess complies with the requirements of the EU-U.S. Privacy Shield Framework and the Swiss- U.S. Privacy Shield Framework, as set forth by the U.S. Department of Commerce and the Federal Trade Commission ("FTC"), regarding the collection, use and retention of personal information from the European Union and Switzerland to the United States, respectively (collectively "Privacy Shield"). filess has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. The "Privacy Shield Principles" collectively means the 7 privacy principles and the 16 supplemental principles described in the Privacy Shield. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view filess's certification, please visit https://www.privacyshield.gov .

Additionally, filess may protect your data through other legally-valid methods, including international data transfer agreements. Adherence to the Privacy Shield Principles for personally identifiable information covered by the Privacy Shield may be limited (i) to the extent required or allowed by applicable law, rule or regulation; (ii) to the extent necessary to respond to lawful requests by public authorities, including to meet national security, law enforcement, legal or governmental requirements; and/or (iii) to protect the health or safety of an individual.

1. We only collect necessary information about you.
2. We do not share personally identifiable information except for obvious reasons (such as when necessary to provide our Service or if required by law).
3. We will not spam you.

As set forth below, we collect personally identifiable information regarding our current, prospective and former clients, customers, visitors and guests via our Service and/or our Site. The types of personally identifiable information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. As stated in our Guiding Principles above, we endeavor to collect information only relevant for the purposes of processing. Below are the legal bases and some of the ways we collect information and how we use it.

User-provided information - filess only collects personally identifiable information that you have provided to us. We only ask for information that's necessary for you (and your Authorized Users) to access, use and pay for our Service, including, but not limited to, the creation of your Account. This information may include, but is not limited to, names, email addresses, mailing addresses, telephone numbers, and billing or payment information (such as credit card numbers). If you correspond with us by email, we may retain the content of your email messages and our responses so that we can provide you with better customer service. We also store information that you have indirectly provided to us via Your Content and Application(s), which may include, without limitation, your Users' personally identifiable information.

Log file information - Information is automatically reported by your browser each time you access a web page. When you use the Service, our servers automatically record certain information that your web browser sends. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, and other such information. We use this information to identify potential security issues, to analyze (and may engage third parties to analyze) trends, to administer the Site, to track averaged User movements around the Site and to gather demographic information about our User base as a whole. We may also use this information to improve, customize and enhance our Service by expanding the Service's features and functionality and tailoring the Service to our Users' preferences. We do not use this information to identify individual Users.

We use your personally identifiable information only for the following purposes:

• Providing our Service: To provide you with the expected features and functionality of the Service;
• Administrative Purposes: To respond to customer service requests, to measure interest in our Service or our Site, programs or services, verify your identity, send you communications regarding the Service or the Site, such as filess news, updates or related product or service information, to process payments and to enforce our Terms of Service. By providing filess your email address you consent to our using the email address to send you important Service notices, including any notices required by law, in lieu of communication by postal mail;
• Marketing our Service: To market our products and services by providing you with materials about products and services offered by us, including new features on our Service or Site. We may provide you with these materials by phone or email, as permitted by applicable law. If you do not wish us to use your personally identifiable information you may contact us at any time and opt out of receiving such communications;
• Research and Development: We may use your personally identifiable information to create non-identifiable information that we may use for the testing of our products and services, in order to help us to optimally deliver our existing Service or to develop new products, processes and services;
• Research/Survey Solicitations: From time to time, we may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Service and Site, various types of communications, advertising campaigns and/or promotional activities. If an individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous individual and aggregate data for research and analysis purposes;
• Anonymous and Aggregated Information: We may use your personally identifiable information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information about the computer or device from which you access the Site or Service, or other analyses we create. We use this aggregated and anonymized information for a variety of functions, including the measurement of visitors' interest in and use of various portions of the Site or Service; and
• Other Uses: We may use your personally identifiable information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide personally identifiable information or with your consent.

filess does not sell, trade, rent or otherwise transfer to outside parties your personally identifiable information. This does not include trusted third parties who assist us in operating or analyzing our Site or Service, conducting our business, or servicing you (e.g. to process your credit card transactions, to provide IT and related services or provide customer support services). These companies are authorized to use your personally identifiable information only as necessary to provide these services to us or to comply with applicable legal requirements.

With respect to onward transfers to any third party Agent (as such term is defined in the Privacy Shield Principles), Privacy Shield requires that filess should remain liable should its Agents process personally identifiable information in a manner inconsistent with the Privacy Shield Principles.

We may also share your anonymous and aggregated information as described above with our third-party service providers for research, product improvement, analytics and any other legally permissible purposes.

We may store personally identifiable information in locations outside the direct control of filess (e.g. on servers at hosting providers).

We may also disclose your personally identifiable information:

• as required by law, such as to comply with a subpoena, or similar legal process
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others or the public in general, investigate fraud, or respond to a government request, or to stop any activity that we consider illegal or legally actionable
• if filess Corporation is involved in a merger, acquisition, or sale of all or a portion of its assets
• to any other third party but only with your prior consent to do so
• if you invite another User to share your Application (e.g. by adding an additional account user), we will share the Application and associated Content with that User

Rights of Access, Rectification, Erasure, and Restriction

If you are an EU-based user, you may seek confirmation regarding whether we are processing personally identifiable information about you, request access to personally identifiable information, and ask that we correct, amend or delete your personally identifiable information where it is inaccurate or has been processed in violation of the Privacy Shield Principles. Where otherwise permitted by applicable law, you may contact us at the contact information under the "Contact Us" section below to request access to, receive (port), restrict processing, seek rectification or request erasure of personally identifiable information held about you by filess. Such requests will be processed in accordance with local laws. Although filess makes good faith efforts to provide individuals with access to their personally identifiable information, there may be circumstances in which filess is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others' privacy or other legitimate rights, 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 it is commercially proprietary. If filess determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, filess will take commercially reasonable steps to verify your identity before granting access to or making any changes to your personally identifiable information.

Data Retention

We will retain your information for as long as your Account is active or as needed to provide you with the Service. We will retain and use your information as necessary to comply with our legal obligations, back-up and audit purposes, resolve disputes, and enforce our agreements.

General

Where you have consented to filess's processing of your personally identifiable information, you may withdraw that consent at any time and opt out by following the instructions in this section. Additionally, before we use personally identifiable information for any new purpose not originally authorized by you, we will provide information regarding the new purpose. Where your consent for the processing of personally identifiable information is otherwise required by law or contract, we will comply with the law or contract.

Opt Out from Email Communications

Out of respect for your privacy, you may choose to stop receiving email messages from us by following the unsubscribe instructions included in these emails or you can email us at [email protected] . We do need to send you certain communications regarding the Service and you will not be able to opt out of those communications - e.g., communications regarding important Service notifications, updates to our Terms of Service or this Privacy Policy or information about billing.

Advertising Choices

For information on how to opt out of the collection and use of your information for targeted interest-based advertising on other sites, please refer to the description in the "What tracking technologies do we utilize?" section below.

We use cookies and pixel tags/web beacons on our Site. A cookie is a small text file that is stored on your computer for record-keeping purposes.

We use both session ID cookies and persistent cookies. Session cookies are required for most of the functionality of our Site and for web tools such as our administrative application. These cookies are used to implement application authentication, allowing us to implement secure access to your data. A session ID cookie expires when you close your browser.

A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser's "help" file. Persistent cookies enable us to track and target your interests and to improve our Site.

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users' engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

If you reject cookies or web beacons, you may still use our Site, but your ability to use some key areas of our Site, such as our administrative application tools, will be impaired.

In addition, our Site utilizes Google Analytics to gather information about how our Users engage with the Site and Google Invisible reCAPTCHA to validate Users on the Site. This analytics data is not tied to any personally identifiable information. Google Analytics and the Google Invisible reCAPTCHA are services provided by Google and are subject to the Google Privacy Policy and the Google Terms of Service . For more information about Google Analytics, please visit https://policies.google.com/privacy/partners . You can opt out of Google's collection and processing of data generated through your use of the Service by using the Google Analytics Opt-out Browser Add-on .

We also partner with third party ad networks to manage our advertising on other sites. Our ad network partners use cookies and web beacons to collect non-personally identifiable information about your activities on this Site and other websites to provide you targeted advertising on other websites based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by visiting Google's Ads Settings at any time, or by visiting the Network Advertising Initiative opt-out page. filess does not have access to or control of any cookies or web beacons that these third party ad networks may store in your browser and this Privacy Policy does not apply to the use of cookies or web beacons by such advertisers. Please note this does not opt you out of being served advertising; you will continue to receive generic ads.

Our Site does not have the capability to respond to "Do Not Track" ("DNT") signals received from various web browsers. For information about DNT, visit https://allaboutdnt.com/ .

The security of your personally identifiable information is important to us.

We follow generally accepted standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. For example, we encrypt the transmission of information using security socket layer technology (SSL) on all the pages where we interact with our users, including registration and login.

No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. You are responsible for maintaining the secrecy of your own passwords and determining whether our Service meets your standards for security.

If you have any questions about security of our Site or Service, you can email us at [email protected] .

Links to Third Party Sites

Our Site includes links to other web sites whose privacy practices may differ from those of filess. If you submit personally identifiable information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any web site you visit.

Testimonials

We display personal testimonials of satisfied customers on our Site in addition to other endorsements. We may repost testimonials that are publicly available on social media networks (like Twitter) without your consent. However, if the testimonial is obtained from any non-public source, we will obtain your consent before posting it on our Site. If you wish to update or delete your testimonial, you can contact us at [email protected] .

Single Sign-On

In the customer support area of our Site, you can log in using the "Sign in With Google" sign-in service. This service will authenticate your identity and provide you the option to share certain personally identifiable information with us such as your name and email address to pre-populate our sign up form. You should understand what Google does with your sign-on information by reviewing the Google Privacy Policy and the Google Terms of Service .

Social Media Features and Widgets

Certain portions of our Site, such as the blog, include Social Media Features, such as the Facebook Like button or Twitter button. These Social Media Features may collect your IP address, which page you are visiting on our Site, and may set a cookie to enable the Social Media Feature to function properly. You acknowledge that we may be able to access any information you make public through such Social Media Features (such as your username, comments, posts and contents) and other information your privacy settings on such Social Media Features permit us to access. Social Media Features and widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Social Media Features are governed by the privacy policy of the company providing it.

Our policy regarding children

Due to the nature of filess's business, our Service, Site and products and services are not marketed to minors. We do not knowingly solicit or collect personally identifiable information from children under the age of 13 (and in certain jurisdictions under the age of 16). If we learn that we have collected personally identifiable information from a child under the age of 13 (and in certain jurisdictions under the age of 16), we will promptly delete that information.

If you are an EU or Swiss citizen and feel that we are not abiding by the terms of this Privacy Policy, or we are not in compliance with the Privacy Shield Principles, please contact us at the contact information provided in the "Contact Us" section below.

In compliance with the Privacy Shield Principles, filess commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at the contact information provided in the "Contact Us" section below.

filess has further committed to refer unresolved Privacy Shield complaints to the JAMS Privacy Shield Dispute Resolution Program an alternate dispute resolution provider located in the United States and the EU.

If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If any request remains unresolved, you may contact the national data protection authority for your EU Member State.

You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see Annex 1 of the Privacy Shield Framework . The FTC has jurisdiction over filess's compliance with the Privacy Shield.

Your personally identifiable information may be transferred to, and maintained on computers or servers, that are located outside of your state, province or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the US and choose to provide your personally identifiable information to us, you agree that we may transfer your personally identifiable information to the United States and process it there and consent to such transfer. We work with our customers and vendors with regard to legal compliance pertaining to data transfers. For a description of our data transfers from the EU and Switzerland, which are handled through the Privacy Shield, please refer to the "Privacy Shield" section.

California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their personally identifiable information for direct marketing purposes during the preceding calendar year and the categories of personally identifiable information shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at [email protected] with "California Privacy Rights" in the subject line.

This Privacy Policy shall be implemented by filess and all its operating divisions, subsidiaries and affiliates. filess has put in place mechanisms to verify ongoing compliance with the Privacy Shield Principles and this Privacy Policy.

We may update this Privacy Policy at any time to reflect changes to our information collection, use or disclosure practices. If we make any material changes we will notify you of those changes by posting them on this Site, and we will update the "Last Updated" date above to indicate when those changes became effective. We encourage you to periodically review this page for the latest information on our privacy practices.

If you have any questions, concerns or comments regarding this Privacy Policy, please do not hesitate to contact us. We're serious about making you feel comfortable about your security and privacy with us.

If after reviewing this Privacy Policy, you would like to submit a request or you have any questions or privacy concerns, please contact us at [email protected] .

We will address your concerns and attempt to resolve any privacy issues in a timely manner.