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Updated Apr 09, 2020
This policy is applicable to the company’s workers, administrators and contractors.
The company has a contractual agreement with all its Data Processors and it complies with Article 28 and 29 of the GDPR. This means that all of our Data Processors comply with legislation concerned with data protection.
The policy is not applicable to 3rd party services. When 3rd party services are employed, and the 3rd party isn’t a data processor, no key data (as laid out below) will be shared or the key data will have been made anonymous so that the GDPR will not apply. Information gathered by 3rd parties is controlled by their own privacy procedures. We actively promote the fact that you gain the knowledge concerning the privacy procedures of those 3rd parties.
Additionally, an independent agreement oversees access, delivery and use of the products which is referred to as the User Agreement. This policy is applicable to any important data received and managed only.
Capitalized terms used in this Policy and not otherwise defined shall have the meanings provided below:
Relevant Data –This is both personal data and specific categories of data included in this policy which is outlined in Data Protection Legislation.
Personal Data –this is any information relating to a person who has an identity.
Special Categories of Data – This is personal data which exposes ethnic or racial origin, political views, religious and philosophical values, membership of a trade union , genetic and biometric data as well as any data reflecting a person’s health status, sexual preferences or sex life.
Processing/Processed –this is any operation conducted on personal data, either manual or automated.
When you are interacting with our Sites and Products, information is gathered by us that either on its own or added to other data, may be used as a way of identifying you (Personal Data). A certain amount of information collected by us is stored appropriately that there are no links that go back to you (Non-Personal Data).
Example collects, generates and/or receives the following Information:
Specific data related to your own devices which you use to connect to Filincode and how you use the Site and/or our Products are logged automatically into our systems. This includes:
• Your contact details which is normally your email.
• Location data which is the geographical area where you are using your computer and other mobile devices(as defined by an Internet Protocol [IP] address or another similar identifier)when engaging with our Site and/or Products.
• Log data. As happens with most websites and technology service offered via the internet, our servers collect data routinely when you gain access or utilize our Site and/or Products and it is then recorded in log files. This log data could include the unique IP address, type of browser used and settings, the time and date of use, information concerning the browser configuration, the language preferences, and the cookie data.
• Device information. This is data sourced from your computer or mobile device, like the kind of hardware and the software you regularly use such as your operating system and type of browser and any special device identifiers for devices that are using, for example, our product.
• Product and Site Particular Data. This is the information we have discovered about the Site and/or Products you make use of and the way you use them. We could access data from any of our 3rd-party partners and service providers in order to evaluate how users utilize our Site and/or Products. One example of this is that we will obtain knowledge of the number of users who gain access to a particular page on the Site and the links they have clicked on to gain this access. We use any accumulated information in order to get an enhanced understanding so we can optimize the Site.
We may be in receipt of data regarding Site visitors, marketing operations and other relevant matters that are related to our business from both subsidiaries and affiliates, our partners or anyone else we may use to ensure our own information is better or is even more useful. This data could be added to other Information we have collected and may include aggregated data, like what IP addresses are consistent with particular zip codes or countries. Or it could be much more specific such as providing details on the performance of online marketing or email campaigns.
We get more Information when it is presented to our Site or if you are a participant in a focused group, competition, pursuit or special occasion, submit an application for a job, ask for support, interact on any of our social media platforms or communicate in any other way with us.
Paddle.com, as an online reseller, acts as a Merchant of Record for all of our orders. Paddle also addresses inquiries submitted by customers and manages returns.
Paddle and ourselves use any data provided to us to help with product satisfaction, processing of orders, prevention of fraud and product support.
We don’t deliberately collect from children any personal information if the child is under 13 years. If we discover that we do have personal information about a child below the age of 13 years we will make sure take sufficient measures to eliminate that data from within our own systems. If you’re below 13 years please refrain from submitting any of your personal information via the Site or Products. We ask that parents and, if applicable, any legal guardians to monitor what their children are accessing on the Internet and assist in enforcing this Policy by telling their children not to provide any personal data through the Sites or Products without first asking their permission.
We process, use and store data you provide to us in order to facilitate the contract we have with you and to support our genuine business interests, while maintaining our Sites, Services, Products and business which includes:
• to assist with managing our Sites and/or Products, endorse users due to security reasons, offer personalized user characteristics and access, the processing of transactions, taking part in research, developing novel features, and improving the features, of our Sites or Products and finally managing algorithms, and site and product usability.
• what is demanded by the law, any legal process and current regulations.
• calculating accumulated statistics from the numbers of different devices which use our Sites or Products;
• we might send to you technical, service and other important administrative emails, messaging and any other kind of communication. We might contact you in order to let you know about any changes to any Product, any additional Product offerings, and key product notices, like those related to fraud and security matters. These types of communications are taken to be a necessary feature of our Products and you are not permitted to exclude yourself from seeing them. Additionally, we on occasions dispatch emails about features of new products, any promotional communication or useful news about us. We will generally only send marketing data if you give us your consent;
• for billing you, account managing and other key administrative matters. We might have to make contact with you in relation to an invoice, managing your account and any other specific reasons and we may use account information in order to manage accounts and track bills and payments.
• to conduct investigation and assist if there are any security breaches, abuse or fraud taking place.
If information is combined or no longer can be identified or associated with a known real person, we might use it for any purpose related to business that it may choose.
• we make use of service providers which assist us in meeting the needs of business operations including delivering, hosting and improving our Products. We commonly use service providers for specific services and functions, which includes communication by email, customer support services, and analytics. These service providers are only able to access, process, or store Personal Data according to our instructions and to also perform the duties for us.
• we have your clear consent which allows us to share your Personal Data (if and when required).
• when we think it is necessary to investigate likely violations of the Terms of Products, to enable us to enforce those Terms of Products, or if we think it’s necessary to conduct an investigation to prevent, or enable action in relation to illegal activities, alleged fraud, or likely threats against people, property, or the systems we operate for our Site and/or Products.
• we decide if any access, disclosure or the preservation of your Personal Data is required by law which enables us to protect the property, personal safety and those who use our Site and/or Products, or if we are required to address any lawful requests filed by public authorities, which includes requests from national security or law enforcement agencies.
• we may also disclose any Non-Personal Data publicly and to 3rd parties – for example, in public reports concerning word use, any partners who we have an agreement with, or as a component in progress reports we might give to users.
Some 3rd party services and applications that typically work with us might ask permission to get access to your information. These applications will give you notice and ask for your consent before asking to access your unique information. Please do consider carefully when selecting these services and applications before giving permission.
Some 3rd parties which have plugins or embedded content on our Sites and/or Products, like Facebook’s “Like” buttons, might permit their operator to learn you have paid visits to the Sites, and they might combine any of this knowledge together with any other data they may have accumulated about the visits you have made to any other websites or even online services which are able to identify you.
Any data that has been collected by 3rd parties using these plugins and apps is subject to all the parties’ precise policies. We suggest you read these policies and get to know how your data is used by other companies.
Now and again we might like to make contact with you because we wish to provide information in relation to product announcements, any updates to software, and any special offer which are now available. We may also want to make contact with information concerning services and products provided by business partners.
We only dispatch to users marketing communications after you have given your consent.
You will receive from time to time transactional messages related to the Products we provide, even when you have unsubscribed from receiving promotional emails.
Any information that is submitted to us will be instantly processed and transferred and placed in storage in the U.S.A. We process any Personal Data belonging to you in the United Kingdom. Any data kept in storage and then processed by us could on occasions be moved securely between any of these zones. If you make use of the Product using the device you use for computing the user content which you decide to save will end up being stored on that unique device locally and it will be synced within our servers. When you post something or go about transferring any type of information to our site or product, you will be agreeing that this information, including both your user content and Personal Data, being accessed and hosted and in the United Kingdom, United States.
As soon as you provide us with your personal data, we immediately take measures to ensure that it’s securely stored.
Any details that are not sensitive such as your own unique email address are sent through normal means via the Internet, but of course there is no guarantee that this method is 100%secure. Due to this limitation we make every effort to protect all your personal data but we are unable to guarantee that any data you share with us is secure, so what you decide to share with us you take the risk. As soon as we are in receipt of your data, we try our utmost best to ensure that it is secure on our own systems.
We do use what is termed encryption which is industry-standard so as to protect all your data when it is being transferred. This is typically called transport layered security or, sometimes, secure socket layered technology.
As soon as your data is in our hands we seek to protect all of it within our own servers. We combine a number of safeguards which combine physical, logical and technical security. Any information in local storage on our Product which has gone through the installation process on your computer device demands that you use any security features found on your device. We do make the recommendation that the right steps are taken in order to make secure all of the computing devices you use which are linked to our own Site and Products.
The Company is serious when considering your data security and works hard to ensure your data is protected from misuse, loss, and any unauthorized disclosure or access.
Any staff and office administrators who are given the responsibility of handling Relevant Data will be fully aware of our policy and will have been through a training program on how to collect, store, process and eliminate data correctly.
We processes, uses and stockpiles Personal Data, when necessary so that we are able to execute the contract drawn up with you, and which is also relevant to our justifiable interests so that we are able to offer the necessary services linked to the Product while maintaining the Product’s functionality, such as:
• Log data which includes crash info clean-up logs, diagnostic reports, file size and path, system library versions, removal/scan duration and device information in order to identify and fix defects in the Product's functionality. All logs and complete reports are key to analyzing any user problem, application malfunctions and any unfortunate crash. Data is compulsory and frequently comes from the main sources, which assists us understand and choose a way of resolving any application issue.
• Device info. which includes the Operating System (OS) that runs on your own device, the Internet Protocol address (IP), your access times, the type of browser, and language used, localization of OS, Bundle of CMM IDs, version CMM, cid, screen resolution, battery information, info for RAM usage. Information about drive, info about processor, info about GPU, info about disk including the type, space free and backups, metadata of files, data on application preferences, applications installed, names of networks and preferences, hours of computer up-time in order to localize and identify any user issues such as bugs and in order to comprehend and localize user issues, for the right cleaning and scanning logic for the Product function.
• We collect your data as soon as you make contact with our consumer support team using emailing or any other communication device. The reason given for collecting is to help you to resolve any problems you may have when using our services. Legal reasons for collecting are for the fulfillment of the contractual or the pre-contractual obligation we have to you. In addition, we might make a recording of any call. The reason for recording a call is to monitor the quality of the consumer support services we provide for your use and their personnel training. Any legal basis for recording a call is the legitimate interest we have in keeping you as one of our customers while offering you a 1st class customer support service.
We depend on you agreeing for us to process your Personal Data:
• to dispatch promotional emails;
• to put cookies on all of your devices;
• to enable in-app analytic actions and events, which enables us to gain an understanding of user behavior, evaluate it and optimize.
In a few cases, we might process your Personal Data while pursuing its legal obligations so as to ensure protection of your key interests or the interests of someone else.
We might update this Policy in order to keep up the pace with any changes to our Sites, Services and Products and our business, and any laws that may apply to both you and us. In all situations we endeavor to maintain the commitment we have when respecting your privacy. If we need to we will inform you immediately of material changes that may have an impact on your rights regarding this Policy via you most recent email address or post revisions made to this Policy and the date it will take place on an area of the Sites which can easily be found.
Therefore, we do recommend that you check from time to time so you stay informed about changes that have been made. Do make a note that if you continue to use products after a change has been made this means that you are agreeing with and are obligated to accept the new Policy. If you do not agree with changes to this Policy and you don’t want your information to be a part of it, you must refrain using any of the Sites and/or Products.