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FileCloud Privacy Policy Review Date: April 13, 2026 Your privacy is important to us. This Privacy Policy covers what we collect and how we use, disclose, transfer, and store your personal data. Depending on each situation at hand, further information and action may be provided and concluded prior to any personal data processing activity. I. INTRODUCTION This Privacy Policy discloses the privacy practices for the FileCloud Products, the http://www.filecloud.com website, and various related services (together referred to as the “Site“). CodeLathe Technologies, Inc. dba FileCloud (“FileCloud”, “we,” “us,” or “our”) is committed to protecting your privacy. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Policy as we undertake new personal data practices or adopt new privacy regulations. Please read the information below to learn the following regarding your use of our Site. You acknowledge that this Privacy Policy is part of our Site Terms of Use. 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, Limerick, Ireland Company registration number IE 3991657RH. Email: You may submit inquiries regarding personal data protection, privacy and security matters to: dpo@filecloud.com III. WHAT IS FILECLOUD AND WHAT PRODUCTS DOES IT OFFER? FileCloud makes computer software, services and offers relevant support for computer software (FileCloud Enterprise Server and FileCloud Enterprise Online). Further information is available at FileCloud Server Terms of Use or FileCloud Online Terms of Use. The products and services FileCloud provides are referred to as “Services” and/or “Products”. IV. GENERAL INFORMATION ABOUT THE COLLECTION AND PROCESSING OF YOUR PERSONAL DATA 1. What categories of persona data does FileCloud collect? The types of personal data we receive and collect depend on how you use our Services. We require certain information in accordance with our Terms of Use to deliver and/or provide our Services and without this we will not be able to provide and/or deliver our Services to you. 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; b. details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings. If the customer service is not provided by us, but is provided by INTERCOM, more information related to the personal data processing activity will be available in the privacy policy of the customer service provider. 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; e. information collected via the use of cookies, web beacons and other technologies, including ad information (such as information on the availability and delivery of ads, the site URL, as well as the date and time). C. Information from other sources: We also obtain information from other sources. We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the information. These sources vary over time, but could include: a. service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Policy; 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. d. Logging of Consents and Disclosures: FileCloud maintains auditable logs of all user consents obtained for the collection, processing, and disclosure of personal data, including consent for optional features, marketing communications, and data transfers. These logs capture the nature of the consent, the data subject’s identity, timestamp, method of consent, and the purpose of processing. In addition, FileCloud maintains records of all disclosures of personal data to third parties, whether for legal compliance, service delivery, or other authorized purposes. These logs include the date, recipient, nature of the information disclosed, and the legal basis or user consent underpinning the disclosure. 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: comply with our contractual obligations concluded with you. This includes FileCloud’s obligations under the Terms of Use to provide the Services and/or Products, or 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: Set up an account for you and to future verify your identity; Personalize your account; Process or deliver orders made via our websites, invoice you or notify you of the status of your order; Provide you with customer support and to help troubleshoot problems; Inform you about FileCloud software updates and issues. Performance of a Contract User Data; Usage Data; Payment and Purchase Data. To provide certain additional voluntary features of our Services. When this is the case, we will clearly ask for your consent. Consent User Data; Usage Data; Survey and Research Data; Payment and Purchase Data. To evaluate and develop new features, technologies, and improvements to our Site. For example: We use personal data to develop and improve our personalized recommendation algorithms; We analyse how our users react to a particular new feature and see whether we should make any changes. Legitimate Interest Our legitimate interests here include developing and improving Products/Services and features for our users. User Data Usage Data Survey and Research Data For marketing or advertising where the law requires us to collect your consent. For example, when we use cookies to understand your interests, or the law requires consent for email marketing. Consent User Data; Usage Data. 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. Legitimate Interest User Data; Usage Data. To comply with a legal obligation that we are subject to. This might be: An obligation under the law of the country / region you are in or Any EU or other law that applies to us. Compliance with Legal Obligations User Data; Usage Data; Payment and Purchase Data; Survey and Research Data. 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. User Data; Usage Data; Payment and Purchase Data. To fulfil contractual obligations with third parties. Performance of a Contract User Data; Usage Data; Payment and Purchase Data. To take appropriate action with reports of intellectual property infringement and inappropriate content. Legitimate Interest Our legitimate interests here include protecting intellectual property and original content. User Data; Usage Data; Payment and Purchase Data. 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. Legitimate Interest Our legitimate interests here include: seeking legal advice protecting ourselves, our users or others in legal proceedings User Data; Usage Data; Payment and Purchase Data. 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. Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully. User Data; Usage Data; Payment and Purchase Data. To process your payment. For example, when we use your personal data to let you purchase a subscription. Performance of a Contract User Data; Payment and Purchase Data. 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. Legitimate Interest Our legitimate interests here include protecting our Website and our users against fraud and other illegal activity. User Data; Usage Data; Payment and Purchase Data. To conduct research and surveys. For example, when we contact our users to ask for your feedback. Legitimate Interest Our legitimate interests here include to understand more about how users think about and use our Services. User Data; Usage Data; Survey and Research Data. 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. All disclosures of personal data to third parties, including those based on legal demands or contractual necessity, are logged and retained in accordance with applicable privacy regulations to ensure accountability and transparency. 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 We maintain servers in different regions and your information may be processed on servers located outside the country where you live and outside the EEA. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this Privacy Policy. We also comply with certain legal frameworks relating to the transfer of data, such as the frameworks described below. 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 FileCloud websites may contain links that will let you leave FileCloud’s website and access another website. Linked websites are not under the control of FileCloud, and it is possible that these websites have a different privacy policy. This privacy policy applies solely to personal information that is acquired on the websites or through your use of the FileCloud software, FileCloud products and/or your relationship with FileCloud, so FileCloud urges you to be careful when you enter any personal information online. FileCloud accepts no responsibility or liability for these other websites. 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. IX. UPDATES FileCloud reserves the right to modify the provisions of this Privacy Policy if deemed necessary. We will inform you of these changes by publishing the revised Privacy Statement at https://www.filecloud.com/privacy. Such changes, modifications, additions or deletions to the Privacy Policy shall be effective immediately upon notice thereof, which may be given by means including, but not limited to issuing an email/posting in the forums and posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to review this site and this Privacy Policy periodically and to be aware of any modifications. Your continued use of the site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Privacy Policy. 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 Be informed of the personal data we process about you and how we process it Access Request access to the personal data we process about you Rectification Request that we amend or update your personal data where it’s inaccurate or incomplete. Erasure Request that we erase certain of your personal data. For example, you can ask us to erase personal data: that we no longer need for the purpose it was collected for; that we process based on the legal basis of consent, and you withdraw your consent; when you object (see section ‘Object’ below) and you make a justified objection, or you object to direct marketing. There are situations where it is unable to delete your data, for example when: it’s still necessary to process the data for the purpose we collected it for; our interest in using the data overrides your interest in having it deleted. For example, where we need the data to protect our services from fraud; we have a legal obligation to keep the data, or we need the data to establish, exercise or defend legal claims. Restriction Request that we stop processing all or some of your personal data. You can do this if: your personal data is inaccurate; our processing is unlawful; we do not need your information for a specific purpose, or you object to our processing and we are assessing your objection request. See section ‘Object’ below You can request that we stop this processing temporarily or permanently. Object Object to us processing your personal data. You can do this if: FileCloud is processing your personal data on the legal basis of legitimate interests, or FileCloud is processing your personal data for tailored advertising. Data portability 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 dpo@filecloud.com. 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. Logs related to user consents and disclosures of personal data are retained for as long as necessary to meet legal, regulatory, and audit requirements, and are subject to strict access controls and regular reviews. 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 You should also be aware that when information is voluntarily disclosed (i.e. your name, email address, etc.) in the discussion forums or other public areas on this site, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Privacy Policy does not apply to such information. Any submissions to chat rooms or other public areas such as the discussion forums on this site are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you’re online. XIV. COOKIES When you use our site, we may store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a web site stores on your computer’s hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies store authentication information for secure areas of our website and other information necessary for the functioning of the site. The cookies make your use of the site easier, make the site run more smoothly, and help us to maintain a secure site. You are always free to decline our cookies if your browser permits, but some parts of our site may not work properly in that case. To learn more about how we use cookies, visit our Cookie Policy. 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