Welcome to the privacy policy of Filently. This policy will help you understand what data we collect, why we collect it, and what your rights are in relation to it.
Among the types of Personal Data that Filently collects, by itself or through third parties, there are:
Usage Data
email address
Trackers
Data communicated while using the service
IP address
first name
last name
answers to questions
payment info
purchase history
billing address
User ID
financial information
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Filently. Unless specified otherwise, all Data requested by Filently is mandatory and failure to provide this Data may make it impossible for Filently to provide its services. In cases where Filently specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools — by Filently or by the owners of third-party services used by Filently serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through Filently.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Filently (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Traffic optimization and distribution
Contacting the User
Managing contacts and sending messages
User database management
Heat mapping and session recording
Analytics
Collection of privacy-related preferences
Access to third-party accounts
Interaction with support and feedback platforms
Registration and authentication
Infrastructure monitoring
Hosting and backend infrastructure
Information collection
Interaction with data collection platforms and other third parties
Handling payments
Detailed information on the processing of Personal Data
Access to third-party accounts
This type of service allows Filently to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Google Drive account access
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Data communicated while using the service +5
This service allows Filently to connect with the User's account on Google Drive, provided by Google Ireland Limited.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Betterlytics
This service provides website analytics to help us understand how visitors use our website.
Data collected: - Page views and navigation paths - Referrer and traffic sources - Device type, browser, and geographic region - Performance metrics (Web Vitals)
Privacy: Betterlytics is a cookieless, privacy-first analytics platform. IP addresses are immediately anonymized through hashing and never stored in their original form. No personally identifiable information is collected. There is no cross-site tracking.
Provider: Betterlytics (betterlytics.io)
ProfitWell Metrics
Company: 200 OK LLC
Place of processing: United States
Personal Data processed: Data communicated while using the service
ProfitWell Metrics is an analytics service provided by 200 OK LLC, that allows the Owner to analyze revenue and Users’ (commercial) activity on Filently.
Category of Personal Information collected according to the CCPA
personal information
internet or other electronic network activity information
Collection of privacy-related preferences
This type of service allows Filently to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Database
Company: iubenda srl
Place of processing: Italy
Personal Data processed: Data communicated while using the service +2
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
iubenda Privacy Controls and Cookie Solution
Company: iubenda srl
Place of processing: Italy
Personal Data processed: IP address +1
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on Filently.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Contacting the User
Mailing list or newsletter
Personal Data processed: email address
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Filently. Your email address might also be added to this list as a result of signing up to Filently or after making a purchase.
Personal Data processed:
email address
Category of Personal Information collected according to the CCPA
identifiers
Handling payments
Unless otherwise specified, Filently processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Filently isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Paddle
Company: Paddle Payments Limited
Place of processing: Ireland
Personal Data processed: billing address +6
Paddle is a payment management service provided by Paddle Payments Limited, which allows Users to make online payments. Paddle also allows Filently to measure the performance of their checkout and subscriptions model, and to re-engage and message Users who have shown signs of abandonment.
Category of Personal Information collected according to the CCPA
identifiers
commercial information
internet or other electronic network activity information
Heat mapping and session recording
Heat mapping services are used to display the areas of Filently that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Betterlytics Session Replay
Personal Data processed: Trackers
This service allows us to record and replay user interactions on our website to improve usability.
Data collected: - Page structure and visual changes - Mouse movements, clicks, and scroll behavior - Form interactions (values are masked)
Privacy: All text content, form values, and sensitive information are automatically masked before transmission. Personal data never leaves the browser in readable form.
Provider: Betterlytics (betterlytics.io)
Retention: 60 days, after which recordings are permanently deleted.
Personal Data processed:
Trackers
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Filently to run and be distributed or to provide a ready-made infrastructure to run specific features or parts of Filently.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
MongoDB Cloud
Company: MongoDB, Inc.
Place of processing: Switzerland
Personal Data processed: Usage Data
MongoDB Cloud is a hosting and backend service provided by MongoDB, Inc.
Category of Personal Information collected according to the CCPA
identifiers
Azure Document Intelligence
Azure Document Intelligence is an optical character recognition (OCR) service provided by Microsoft Ireland Operations Limited. Filently uses it to extract text from uploaded documents such as PDFs and images, enabling automatic classification and filing. Document content is sent to Azure for processing and is not stored by the service. All processing takes place in Switzerland.
Personal Data processed: document content (temporarily, during text extraction). No personally identifiable information is extracted or stored by the service.
Service provided by: Microsoft Ireland Operations Limited (data processed in Switzerland) – Privacy Policy
Azure OpenAI Service
Azure OpenAI Service is an AI platform provided by Microsoft Ireland Operations Limited. Filently uses it to automatically classify documents, suggest filenames, and match documents to the appropriate folder in your cloud storage. Only extracted document text and folder structure information are sent to the service. No data is stored by the service beyond the processing request. All processing takes place primarily in Switzerland, with a fallback in the EU.
Personal Data processed: extracted document text and folder metadata (temporarily, during classification). No personally identifiable information is stored by the service.
Service provided by: Microsoft Ireland Operations Limited (data processed in Switzerland / EU) – Privacy Policy
Railway
Railway is a cloud hosting platform provided by Railway Corp. used to run Filently's application servers and background processing services. As the infrastructure provider, Railway hosts the servers through which application data is processed. Filently's deployment runs in the Amsterdam (EU) region.
Personal Data processed: various types of Data as necessary for hosting the application.
Service provided by: Railway Corp. (United States, data processed in Amsterdam, EU) – Privacy Policy
Information collection
Document Processing Pipeline
Company: Filently
When a document reaches Filently – whether through upload, email, or automatic inbox detection – it is processed through an automated pipeline. The document's text content is temporarily extracted, analyzed by an AI service to determine the best filename and folder, and then filed to the appropriate location in your cloud storage. After successful filing, the extracted text is permanently deleted from our systems. Your original documents are never stored on Filently's servers, and the AI does not learn from or retain your data after the request is complete. For more details, visit our Help Center.
Field-Level Encryption
Company: Filently
Filently encrypts all sensitive data at rest using AES-256-GCM – the same encryption standard used by banks and government agencies. Encryption happens before data is written to the database, ensuring that even in the event of a breach, your data would be unreadable without the encryption keys.
Encrypted fields include: document filenames, folder paths, AI-generated classifications and suggestions, custom filing instructions, and temporarily extracted text.
Encryption keys are stored separately from the database and are never exposed. Filently staff cannot access your encrypted personal data through any admin interface. All connections between services use HTTPS/TLS encryption in transit.
Data Residency
Company: Filently
All document processing – including text extraction (OCR) and AI analysis – takes place in Switzerland (primary) or the European Union (fallback). Your document content never leaves European or Swiss infrastructure for processing.
Your encrypted metadata is stored in a MongoDB database hosted in Switzerland. All connections between Filently and third-party services (Google Drive, Azure, MongoDB) use encrypted HTTPS/TLS connections.
Filently is CASA Tier 2 certified – a security assessment developed by Google for applications that access Google user data. An independent auditor has verified Filently's data encryption, access controls, secure storage practices, vulnerability management, and incident response procedures.
Infrastructure monitoring
This type of service allows Filently to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Filently.
AppSignal
AppSignal is an application performance monitoring and error tracking service provided by AppSignal B.V. It helps us detect errors, monitor performance, and ensure the reliability of Filently. No personally identifiable information is sent to AppSignal. The Data collected is limited to technical and behavioral information such as error logs, page interactions, and performance metrics, which allow us to identify and resolve issues.
Personal Data processed: usage data, error logs, and performance metrics. No personally identifiable information is collected.
Service provided by: AppSignal B.V. (Amsterdam, Netherlands, European Union) – Privacy Policy
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of Filently for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Tally
Company: Tally BV
Place of processing: Belgium
Personal Data processed: answers to questions +6
Tally is a form builder and data collection platform provided by Tally BV.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
inferences drawn from other personal information
Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Filently.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Featurebase
Personal Data processed: Trackers
This service provides customer support, feedback collection, and product communication through an embedded messenger widget and a web portal.
Features used: - Live chat and email-based support conversations - Help center, product roadmap, and feedback board (with Single Sign-On) - Automated messaging based on user profile data and in-app activity for contextual guidance
Data collected: - Email address, full name, and profile picture - Unique user identifier - Data communicated while using the service - Usage data and trackers
Privacy: User data is transmitted securely via signed JWT tokens. Primary data hosting is in the EU, with sub-processors in the USA under Standard Contractual Clauses (SCCs). The embedded widget sets additional third-party cookies as described in the provider's cookie policy.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Brevo email
Company: SendinBlue SAS
Place of processing: France
Personal Data processed: email address +2
Brevo email is an email address management and message-sending service provided by SendinBlue SAS.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Registration and authentication
By registering or authenticating, Users allow Filently to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Filently will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Google OAuth
Company: Google Ireland Limited
Place of processing: Ireland
Personal Data processed: Trackers +2
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed:
Trackers
Usage Data
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Adherence to the Google API Services User Data Policy and Limited Use Requirements
Company: Filently
Personal Data processed: various types of Data as specified in the privacy policy of the service
Filently‘s use or transfer to other apps of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Service provided by:
Filently
Category of Personal Information collected according to the CCPA
identifiers
Traffic optimization and distribution
This type of service allows Filently to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Filently and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: various types of Data as specified in the privacy policy of the service
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Filently, i.e., communication between Filently and the User's browser, while also allowing analytical data from Filently to be collected.
Personal Data processed:
various types of Data as specified in the privacy policy of the service
Category of Personal Information collected according to the CCPA
identifiers
Cloudflare DNS
Company: Cloudflare, Inc.
Place of processing: United States
Personal Data processed: Usage Data
Cloudflare DNS is a managed domain name system (DNS) service provided by Cloudflare, Inc. Cloudflare DNS manages DNS infrastructure to deliver traffic quickly and securely.
Category of Personal Information collected according to the CCPA
internet or other electronic network activity information
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Filently, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Filently.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Filently.
Brevo marketing automation
Company: SendinBlue SAS
Place of processing: France
Personal Data processed: email address +2
Brevo marketing automation is a User database management service provided by SendinBlue SAS.
Category of Personal Information collected according to the CCPA
identifiers
internet or other electronic network activity information
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
localStorage
localStorage allows Filently to store and access data right in the User's browser with no expiration date.
Cookie Policy
Filently uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users in the European Union
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
Users have given their consent for one or more specific purposes.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
right of access to Personal Data;
right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
right to receive their Personal Data and have it transferred to another controller (data portability);
right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Filently and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
Identifiers
Personal Data processed: Various types of data as specified in the privacy policy of the service; Email address; Trackers; Usage data + 7
Personal Information collected or disclosed:
various types of Data as specified in the privacy policy of the service
email address
Trackers
Usage Data
first name
last name
Data communicated while using the service
answers to questions
purchase history
billing address
User ID
Sensitive Personal Information collected or disclosed
payment info
Purposes:
Traffic optimization and distribution
Contacting the User
Managing contacts and sending messages
User database management
Access to third-party accounts
Registration and authentication
Hosting and backend infrastructure
Interaction with data collection platforms and other third parties
Handling payments
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared:
No
Targeted Advertising:
No
Third-parties:
Cloudflare, Inc., SendinBlue SAS, Google Ireland Limited, Microsoft Corporation, Tally BV, Paddle Payments Limited
Service providers or contractors:
Filently
Internet or other electronic network activity information
Personal Data processed: Usage data; Trackers; Email address; Data communicated while using the service + 8
Personal Information collected or disclosed:
Usage Data
Trackers
email address
Data communicated while using the service
IP address
first name
last name
various types of Data as specified in the privacy policy of the service
answers to questions
purchase history
billing address
User ID
Sensitive Personal Information collected or disclosed
payment info, financial information
Purposes:
Traffic optimization and distribution
Managing contacts and sending messages
User database management
Heat mapping and session recording
Collection of privacy-related preferences
Further information about Personal Data
Access to third-party accounts
Interaction with support and feedback platforms
Registration and authentication
Hosting and backend infrastructure
Interaction with data collection platforms and other third parties
To know more about your rights to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Filently.
For example, you directly provide your Personal Information when you submit requests via any forms on Filently. You also provide Personal Information indirectly when you navigate Filently, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Filently and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
The right to question the results of the profiling;
The right to be informed of the reason that the profiling resulted in the decision; if feasible
The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
The right to review personal data used in the profiling;
If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
The right to opt out of the processing of your Personal Information for Targeted Advertising;
The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Filently.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Filently or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Filently may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Filently and any third-party services may collect files that record interaction with Filently (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Filently and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through Filently (or third-party services employed in Filently), which can include: the IP addresses or domain names of the computers utilized by the Users who use Filently, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using Filently who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Filently. The Data Controller, unless otherwise specified, is the Owner of Filently.
Filently (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Filently as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Filently, if not stated otherwise within this document.