Privacy Policy

Effective Date: May 25, 2018

INTRODUCTION

File Keepers, LLC and its affiliates, including Raleigh Creative Services, LLC (collectively “File Keepers”, “us”, “we” or “our”), created this privacy policy (“Privacy Policy”) to advise you about File Keepers’ information practices, such as the types of information we collect and how we may use that information, and to inform you about your privacy rights and how the law protects you. We urge you to read this Privacy Policy carefully. Please also review our Terms of Use, which govern your use of the Site (as defined below).

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below.

Individuals in the European Union (“EU”) should be sure to read the important information provided here [LINK], in addition to the other provisions in this Privacy Policy.

I. IMPORTANT INFORMATION AND WHO WE ARE Click Here

II. THE INFORMATION WE COLLECT ABOUT YOU Click Here

III. HOW IS YOUR PERSONAL INFORMATION COLLECTED Click Here

IV. THIRD PARTY INTERACTIONS Click Here

V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING Click Here

VI. HOW WE USE YOUR PERSONAL INFORMATION Click Here

VII. DISCLOSURES OF YOUR PERSONAL INFORMATION Click Here

VIII. YOUR CHOICES Click Here

IX. DATA SECURITY Click Here

X. USERS OUTSIDE OF THE UNITED STATES AND INTERNATIONAL TRANSFERS Click Here

XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS Click Here

XII. QUESTIONS Click Here

XIII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION Click Here

I. IMPORTANT INFORMATION AND WHO WE ARE

A. APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to all information collected by or submitted to File Keepers via our website, www.filekeepers.com, including the “Client Connect” portion of the website accessible via link from the home page, and all other websites, mobile applications, features, or online services that are owned or controlled by File Keepers and that post or include a link to this Privacy Policy (collectively, the “Site”), whether accessed via computer, mobile device, or otherwise. Note, however, this Privacy Policy does not apply to your use of unaffiliated websites that link to our Site. Once you enter another website (whether through an advertisement, service, or content link), be aware that we are not responsible for the privacy practices of such other websites. Furthermore, this Privacy Policy only covers information collected on the Site or via e-mail and does not cover any information collected by us through other means, such as direct mail, paper applications, in person communications, or other offline methods (unless specifically stated).

B. PURPOSE OF THIS PRIVACY POLICY

This Privacy Policy aims to give you information on how File Keepers collects and uses your personal information through your use of the Site, including any information you may provide through the Site when you sign up to receive our newsletter(s), purchase a product or service, or make a reservation at one of our properties.

It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or using personal information about you so that you are fully aware of how and why we are using your information. This Privacy Policy supplements the other notices and is not intended to override them.

C. CHILDREN

The Site is not intended for children and we do not knowingly collect information relating to children. If File Keepers discovers that it has inadvertently collected Personal Information from anyone younger than the age of 13, it will delete that information.

D. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on [DATE] and historic versions can be obtained by contacting us at Privacy@filekeepers.com or EUprivacy@filekeepers.com.

We reserve the right, at any time and without notice, to add to, change, update or modify this Privacy Policy, simply by posting such change, update or modification on the Site. Any such change, update or modification will be effective immediately upon posting on the Site. However, unless you consent, File Keepers will not use your Personal Information in a manner materially different than what was stated in our posted Privacy Policy at the time your Personal Information was collected.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

E. THIRD PARTY CONTENT, LINKS TO OTHER WEBSITES, AND FILE KEEPERS CONTENT FOUND OUTSIDE THE SITE

The Site may include links to third-party websites and certain content on the Site may be hosted and served by third parties that File Keepers does not control.Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave the Site, we encourage you to read the privacy policy of every website you visit.

In addition, File Keepers content may be included on web pages and websites that are not associated with File Keepers and over which we have no control. These third parties may collect data through the use of their own cookies, web beacons or other technology, independently collect information or solicit Personal Information, and may have the ability to track your use of their websites and services. File Keepers is not responsible for the privacy practices or the content of any third party.

II. THE INFORMATION WE COLLECT ABOUT YOU

Personal information or personal data means any information about an individual from which that person can be identified. It does not include information where the identity has been removed (anonymous data).

We and our third-party service providers may collect, use, store and transfer different kinds of personal information about you that we have grouped together follows:

Identity Information includes name, username or similar identifier, title, date of birth, and gender.
Demographic Information includes zip code, age and/or income.
Contact Information includes billing address, delivery address, email address and telephone numbers.
Financial Information includes bank account and payment card details.
Transaction Information includes details about payments to and from you and other details of products and services you have purchased from us.
Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access the Site.
Profile Information includesyour username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
Usage Data includes information about how you use our website, products and services, including all of the areas within our Site that you visit or use, and the time of day you visited the Site, among other information.
Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Information includes information about your location using a variety of technologies, such as GPS, IP address, and connected or nearby Wi-Fi networks.
User Content Information includes text (including questions, comments, and suggestions), pictures, audio, videos, or other content (collectively, “User Content”) you share by participating and posting content publicly through chat rooms, forums, interactive features, or other communication functionality (“Community Features”).

We do not collect any Special Categories of Personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

III. HOW IS YOUR PERSONAL INFORMATION COLLECTED?

We use different methods to collect information from and about you including through:

Direct interactions.You may give us your Identity, Demographic, Contact, Financial, Profile, or Marketing and Communications Information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes personal information you provide when you:

o purchase our products or services;

o create an account on our website;

o subscribe to our service or publications;

o request marketing to be sent to you;

o enter a competition, promotion or survey; or

o give us feedback.

Automated technologies or interactions.As you interact with our website, we may automatically collect Technical, Usage, and Location Information about your equipment, browsing actions and patterns. We collect this personal information by using cookies, web beacons, embedded scripts and other similar technologies. [We may also receive Technical Information about you if you visit other websites employing our cookies.] Please see our cookie policy cookie policy for further details. Note that our mobile applications may use similar technologies.

Cookies – Cookies are data files sent to and stored on the Device you use to view a website. Cookies can be used for many purposes, including to monitor use of our Site, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly and to store your user name and password so you do not have to re-enter it each time you visit the Site. If you choose to disable cookies on your Device, some features of the Site or our content may not function properly.

Web Beacons – Web Beacons are small graphic images or other web programming code (also known as “1×1 GIFs” or “clear GIFs”) that may be included on the Site and in our e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
Embedded Scripts – Embedded scripts are programming code designed to collect information about your interactions with the Site, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site.
Third parties or publicly available sources. We may receive personal information about you from various third parties. For example, if you are on another website and you opt-in to receive information from us, the other website will forward your contact and other information to us so that we may contact you as requested. If your company has provided you with access to the Site, we may receive information about you from your company. We also may supplement the information we collect with outside records from third parties in order to provide you with information, services or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Site. In those cases, we will apply this Privacy Policy to the combined information. Examples of third party sources include:

o Technical Information from the following parties:

analytics providers;
advertising networks; and
search information.

o Contact, Financial and Transaction Information from providers of technical, payment and delivery services.

o Contact and Financial Information from companies that facilitate making reservations.

o Identity and Contact Information from publicly availably sources.

o If your company has provided you with access to the site, information your company provides about you.

Send to a Friend Features. If you send a friend a communication from the Site, we may use the Identity and Contact Information you provide (e.g., name and e-mail address) to contact that friend.

IV. THIRD PARTY INTERACTIONS

Certain functionality on the Site may permit interactions that you initiate between the Site and a third party website or service (“Third Party Interactions”). Examples of Third Party Interactions may include technology that enables you to “like” or “share” content from the Site on or to other websites or services; to transmit content to the Site from your account on a third party website or service; and to otherwise connect the Site to a third party website or service,such as through an application programming interface (API) made available by File Keepers or a third party.

If you choose to use Third Party Interactions, information you post or provide access to may be publicly displayed on the Site or by the provider of the Social Feature that you use. Similarly, if you post information on a third party platform that references the Site (e.g., by mentioning one of the Site or using a hashtag associated with one of the Site in a tweet or status update), your post may be published on our Site in accordance with the terms of the third party website or service. In addition, both File Keepers and the third party may have access to certain information about you and your use of the Site and the third party site or service. In addition, we may receive information about you in connection with other users’ use of Third Party Interactions (e.g., we may learn that you are a “friend” or “connection” of the third party or receive other information about you that the other user enables us to receive).

The information we collect in connection with Third Party Interactions is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices with regard to what is visible to others on that third party website or service.

V. THIRD PARTY ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING

File Keepers works with certain third parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Site, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to one of the Site, our service provider(s) may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These third parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. These technologies, including those set by third party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may share Device Identifier and Usage Data about visitors with third party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising.

For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:

NAI Opt-Out Tool (for website users): http://www.networkadvertising.org/managing/opt_out.asp
DAA Consumer Choice (for website users): http://www.aboutads.info/choices/
DAA AppChoices (for mobile app users): http://youradchoices.com/appchoices

Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Site and elsewhere online. Some third parties may collect Personal Information about your online activities over time and across different websites.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, the Site currently do not alter their practices when they receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.

VI. HOW WE USE YOUR PERSONAL INFORMATION

We may use the information we collect about you, including Personal Information and Usage Data:

to provide you with our products and services and related customer service;
to communicate with you information about the Site, our products or services, or promotional material from some of our advertisers or third-party business partners,
to process a transaction you initiate;
to provide you with information, products or services that you have requested or agreed to receive;
to verify your contact information is valid;
to customize and tailor your experience on the Site, for example, by displaying content that we think you might be interested in;
to send you offers or information on behalf of our business partners or affiliates;
to improve the Site, our products and services and for internal business purposes;
for compliance fraud prevention and safety, including enforcing our terms of service and this Privacy Policy, protecting our rights privacy, safety, or property and/or that of you or others, and protecting against, investigating or deterring fraudulent, harmful, unauthorized, unethical or illegal activity;
comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
contact you with regard to your use of the Site and, in our discretion, changes to the Site policies or functionality; and

for purposes as disclosed at the time you provide us with your information, with your consent, or as further described in this Privacy Policy.

A. PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from, purchased goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

B. THIRD-PARTY MARKETING

We do not share your Personal Information with unaffiliated third parties for those unaffiliated third parties’ marketing purposes unless you consent to such sharing.

C. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Site may become inaccessible or not function properly. For more information about the cookies we use, please see [LINK TO COOKIE POLICY.]]

VII. DISCLOSURES OF YOUR PERSONAL INFORMATION

We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.

We may disclose the information we have collected about you, including personal information, as disclosed at the time you provide your information, with your consent, as described in this Privacy Policy, or in the following circumstances:

A. INTERNAL THIRD PARTIES

File Keepers is a member of the Raleigh Enterprises group of companies, which includes Raleigh Enterprises and its subsidiaries and affiliates (collectively, “Raleigh Companies”). The Raleigh Companies include the Sunset Marquis, Raleigh Studios, and Rosenthal – The Malibu Estate.

File Keepers may disclose information including personal information with the Raleigh Companies for a variety of purposes, including for business, operational, and marketing purposes. File Keepers may, and reserves the right to, share your information with any other company that is not presently, but becomes, a File Keepers parent, subsidiary, or affiliate.

B. EXTERNAL THIRD PARTIES

Third Party Service Providers

We may share personal information with third party service providers in connection with the service providers’ performance of services to, or on behalf of, the Site or File Keepers. These service providers may store or use your information outside of the EU or United States.

Corporate Users

If your company has provided you with access to the Site, we may share information about your use of the Site, including your Personal Information and Usage Information, with your company or its agents.

When You Agree to Receive Information From Third Partiesor Request That We Share Your Information

You may be presented with an opportunity to receive information and/or marketing offers from one or more third parties or that we share your information with a third party. If you agree at that time to have your personal information shared, your personal information will be disclosed to that third party (or parties) and will be subject to the privacy policy and practices of that third party.

You also may request, sometimes through your use of an interactive feature or third party application, that we share information about you with a third party and we will typically do so under those circumstances.

Administrative & Legal Reasons

We may transfer and disclose information, including personal information, to third parties to:

comply with a valid legal inquiry or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
protect the safety, interests, rights, property or security of File Keepers, you, or any third party;
respond to a breach or attempted breach of the security of our Site;
defend or assert our legal rights pursuant to any of the Site’ Terms of Use, any policies applicable to the Site, or any other agreement you may have with File Keepers; or
at the request of governmental authorities conducting an investigation.

We may also use Technical Information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion. File Keepers may also disclose and transfer your Personal Information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if File Keepers (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of File Keeper’s ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.

Sweepstakes, Contests & Promotions

We may offer sweepstakes, contests, and other promotions (any, a “Promotion“) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.

C. SHARING BETWEEN RALEIGH COMPANIES; BUSINESS TRANSFERS

File Keepers may also disclose and transfer your personal information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if File Keepers (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to a third party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of File Keepers’ ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.

We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to use your personal information for specified purposes and in accordance with our instructions.

VIII. YOUR CHOICES

A. ACCESSING, UPDATING, CORRECTING OR DELETING INFORMATION

You may review, update, correct or delete the personal information in your profile by logging into your website account. [LINK TO COOKIE PROFILE] You may also contact us at Privacy@filekeepers.com or EUprivacy@filekeepers.com to accomplish the foregoing or if you have additional requests or questions.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.

B. OPTING OUT

You can ask us to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or [LINK TO COOKIE PROFILE] by contacting us.

Where you opt out of receiving these marketing messages, this will not apply to personal information provided to us as a result of the purchase of a product or service or other transactions.

C. CHOOSING NOT TO SHARE PERSONAL INFORMATION

You may choose not to provide us with any Personal Information. In such an event, you may still be able to access and use some of the Site; however you may not be able to access and use those portions of the Site that require your Personal Information. You may opt out of receiving marketing e-mails by following the opt-out instructions provided to you in those e-mails. Please note that we reserve the right to send you certain communications relating to your account or use of any of the Site (for example, administrative and service announcements, shipping notices, and order or reservation confirmations) and these transactional account messages may be unaffected if you opt-out from marketing communications. You may opt-out of receiving text messages (e.g., SMS or MMS messages) that we may offer by replying “STOP” to one of our messages.

Where we need to collect personal information by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

D. MARKETING COMMUNICATIONS

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising. We have established a portion of our website where you can log in make certain decisions about your personal information. [LINK TO COOKIE PROFILE]

Please note that you may continue to receive service-related and other non-marketing communications.

IX. DATA SECURITY

File Keepers takes commercially reasonable security measures to help protect personal information collected by or submitted to File Keepers via telephone, email, or our website from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only use your personal information on our instructions and they are subject to a duty of confidentiality. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be 100% secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Site and provide us with your information at your own risk.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

X. USERS OUTSIDE OF THE UNITED STATES AND INTERNATIONAL TRANSFERS

The Site are operated in the United States, and File Keepers and third party service providers and partners operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Site, or providing us with any information, you consent to this transfer, processing and storage of your information in countries where the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

XI. CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

Pursuant to California Civil Code Section 1798.83, residents of the State of California have the right to request from companies conducting business in California certain information regarding File Keepers’ disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties (and in some cases, affiliates) for their direct marketing purposes.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request to the following email address: Privacy@filekeepers.com or EUprivacy@filekeepers.com or write to us at the following mailing address File Keepers, 6277 East Slauson Avenue, Los Angeles, CA 90040-3011. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.

XII. QUESTIONS

If you have any questions or concerns regarding our privacy policy or practices, please feel free to contact us via email at Privacy@filekeepers.com or EUprivacy@filekeepers.com. We can also be contacted by mail at:

FILE KEEPERS, LLC
Attention: Customer Relations/Privacy
6277 East Slauson Avenue,
Los Angeles, CA 90040-3011

XIII. ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN UNION

A. PERSONAL INFORMATION

References to “Personal Information” in this Privacy Policy are equivalent to “Personal Data” governed by European data protection legislation.

B. LEGAL BASES FOR PROCESSING PERSONAL DATA

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform obligations relating to a contract to which you are a party or to take steps at your request before entering into such a contract.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include those related to conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal information other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.

We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of Information

Lawful basis for processing including basis of legitimate interest

To register you as a new customer or user

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver products and services including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or Privacy Policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in sweepstakes, contests and promotional activities or complete a survey

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and the Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(d) Usage

(e) Location

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(d) Usage

(e) Marketing and Communications

(f) Technical

(g) Location

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To allow participation in Community Features

(a) Identity

(b) Profile

(b ) User Content

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business, to allow user interaction on the Site)

C. CONTROLLER

File Keepers is made up of different legal entities, including the Raleigh Companies, details of which can be found here [LINK]. This Privacy Policy is issued on behalf of File Keepers, LLC and its subsidiaries and affiliates so when we mention “File Keepers”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company responsible for processing your data.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out below.

D. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

E. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

F. EU RESIDENT PERSONAL DATA RIGHTS

Under certain circumstances, EU Residents may have rights under data protection laws in relation to your personal data as outlined below:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact Privacy@filekeepers.com or EUprivacy@filekeepers.com.

No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What We May Need From You

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit To Respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints to Supervisory Authority

EU Residents may have the right to make a complaint at any time to the supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please first contact us directly to allow us to do so.