Posted and effective: 1^st October 2023

Thank you for using Privatlocker. Here we describe how we collect, use, and handle your personal data when you use our websites, software, and services (“Services”).

What & Why

We collect and use the following information to provide, improve, protect, and promote our Services.

Account information: We collect, and associate with your account, the information you provide to us when you do things such as sign up for your account and set up two-factor authentication (like your name, email address, phone number, payment information, and physical address).

Your Data: Our Services are designed as a simple and personalised way for you to store your files, records, documents, photos, recordings, messages, and so on (“Your Data”), collaborate with others, and work across multiple devices and services. To make that possible, we store, process, and transmit Your Data as well as information related to it. This related information includes your profile information that makes it possible to collaborate and share Your Data with others, as well as things like the size of  the file, the time it was uploaded, collaborators, and usage activity.

Contacts: You may choose to give us access to your contacts to enable you and your Privatlocker team (collectively, “Privatlocker Team”), if you’re a Privatlocker user, to do things like collaborate on Your Data, send messages, and invite others to use the Services. If you do, we’ll store those contacts on our servers.

Usage information: We collect information related to how you use the Services, including actions you take in your account (like viewing, adding and moving files or folders). We use this information to provide, improve, and promote our Services, and protect Privatlocker users.

Device information: We also collect information from and about the devices you use to access the Services. This includes things like IP addresses, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices. Your devices (depending on their settings) may also transmit location information to the Services. For example, we use device information to detect abuse and identify and troubleshoot bugs.

Cookies and other technologies: We use technologies like cookies and pixel tags to provide, improve, protect, and promote our Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with our Services, and improving them based on that information. You can set your browser to not accept cookies, but this may limit your ability to use the Services. If our systems receive a DNT:1 signal from your browser, we’ll respond to that signal as outlined here.

Marketing: We give users the option to use our Services free of charge. These free Services are made possible by the fact that some users upgrade to one of our paid Services. If you register for our Services, we will, from time to time, send you information about upgrades when permissible. Users who receive these marketing materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails, or update your preferences in the notifications section of your personal account. We sometimes contact people who don’t have a Privatlocker account. For recipients in the EU, we or a third party will obtain consent before reaching out. If you receive an email and no longer wish to be contacted by Privatlocker, you can unsubscribe and remove yourself from our contact list via the message itself.

Basis for processing your data: We collect and use the personal data described above in order to provide you with the Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.

With Whom

We may share information as discussed below, but we won’t sell it to advertisers or other third parties.

Others working for and with Privatlocker: Privatlocker uses certain trusted third parties (for example, providers of customer support and IT services) for the business purposes of helping us provide, improve, protect, and promote our Services. These third parties will access your information to perform tasks on our behalf, and we remain responsible for their handling of your information per our instructions.

Other Privatlocker Companies: Privatlocker shares infrastructure, systems, and technology with other Privatlocker companies to provide, improve, protect, and promote Privatlocker Services. We process your information across the Privatlocker companies for these purposes, as permitted by applicable law and in accordance with their terms and policies.

Other users: Our Services are sometimes designed to help you collaborate with others. If you register your Privatlocker account with an email address on a domain owned by your employer or organisation or collaborate with other Privatlocker users, we may suggest you or your team as a potential collaborator to other users or teams. For example, if you interact with a person at a company, and that person frequently works with one of their co-workers, we may suggest you as a potential collaborator for that co-worker. Collaborators and potential collaborators may see some of your basic information, like your name, Privatlocker name, profile picture, device, email address, and usage information.

Other applications: Certain features let you make additional information available to others. You can choose to connect your Privatlocker account with third-party services, for example via Privatlocker APIs. By doing so, you’re enabling Privatlocker and those third parties to exchange information about you and data in your account so that Privatlocker and those third parties can provide, improve, protect, and promote their services. Please remember that third parties’ use of your information will be governed by their own privacy policies and terms of service.

Administrators: If you are a user of a Privatlocker BUSINESS or PROFESSIONS, your administrator  with full permissions (“Administrator”) may have the ability to access and control your Privatlocker account. Please refer to your organisation’s internal policies if you have questions about this. If you are not a Privatlocker BUSINESS or PROFESSIONS user but interact with such Privatlocker users (for example, by joining a shared folder or accessing Data shared by that user) members of that organisation may be able to view information about you (such as your name, email address, and profile picture) and your interaction with the Privatlocker  BUSINESS or PROFESSIONS  user (such as your IP address). If you share your Data the Administrator of the team account may have the ability to access and edit what you share.

Law & Order and the Public Interest: While we are unable to access Your Data, we may disclose information about you to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of Privatlocker or our users; (d) protect Privatlocker’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest. Stewardship of your data is critical to us and a responsibility that we embrace. We believe that Your Data should receive the same legal protections regardless of whether it’s stored on our Services or on your computer’s hard drive. We will abide by the following government request principles when receiving, scrutinising, and responding to government requests (including national security requests) for your data: Be transparent, fight blanket requests, protect all users and provide trusted services.

How

Security: We have a team dedicated to keeping your information secure and testing for vulnerabilities. We continue to work on features to keep your information safe in addition to things like two-factor authentication, encryption of files and alerts when new devices and apps are linked to your account. We deploy automated technologies to detect abusive behaviour and content that may harm our Services, you, or other users.

User Controls: You can access, amend, download, and delete your personal information by logging into your Privatlocker account.

Retention: When you sign up for an account with us, we’ll retain information you store on our Services for as long as your account exists or as long as we need it to provide you the Services. If you delete your account, we will initiate deletion of this information after 30 days. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; and (2) we may retain certain information if necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.

Where

To provide you with the Services, we may store, process, and transmit data in the United Kingdom and other locations around the world including those outside your country. Data may also be stored locally on the devices you use to access the Services.

Data Transfers: When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, Privatlocker relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, standard contractual clauses, and the European Commission’s adequacy decisions about certain countries, as applicable.

Your Control and Access of Your Data

Only you have control over your personal data and how it’s collected, used, and shared. For example, you can:

Delete Your Data in your Privatlocker account.

Change or correct personal data. You can manage your account and the content contained in it, as well as edit some of your personal data, through your account settings page.

Access and take your data elsewhere.

You can access your personal data from your Privatlocker account. You can also ask us for a copy of personal data you provided to us or that we’ve collected, the business or commercial purpose for collecting it, the types of sources we got it from, and types of third parties we’ve shared it with.

You can object to the processing of your personal data. Depending on the processing activity, you can request that we stop or limit processing of your personal data.

If you would like to submit a data access request or object to the processing of your personal data, please email us at privacy@privatlocker.com. To request that your personal data be deleted, please email us at privacy@privatlocker.com.

Changes

If we are involved in a reorganisation, merger, acquisition, or sale of our assets, your data may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event. We may revise this Privacy Policy from time to time and will post the most current version on our website. If a revision meaningfully reduces your rights, we will notify you.

Contact

If you have questions or concerns about Privatlocker, our Services, and privacy contact our Data Protection Officer at privacy@privatlocker.com. If they cannot answer your question, you have the right to contact your local data protection supervisory authority.