Revision Date: 04/17/2020
Filestack, Inc. provides online services used by application service providers to upload, transform and deliver files within their applications. Most of our customers are business entities or other organizations. Filestack’s main office is in San Antonio, Texas and it offers its services to customers worldwide.
This Privacy Statement describes our policies for personal data that we collect and use for our own general business purposes.
We also receive and transmit personal data that is controlled by those of our customers who use our services to process files that include personal data. We use this customer-controlled personal data only as permitted by our customers in our agreements with them and not for our own general business purposes. We have included information below to describe our commitments to you if we have access to your data in our role as a file processor, but you should review the privacy statement of our customer that controls your personal data to understand its privacy practices.
How to Contact Us
Email: firstname.lastname@example.org or via mail: Filestack – 122 East Houston St, San Antonio TX 78205.
Please contact us if you have any questions about the information in this Privacy Statement or our handling of your personal data, or would like to access, amend, delete or take other action with regard to your personal data. We ask, however, that if we are in possession of your data solely as a service provider for our customer you first contact our customer with your request.
Changes to Privacy Statement
We may change this Privacy Statement from time to time. We will manage your personal data in accordance with the Privacy Statement version that was published on the date that we collected the data about you. Prior versions of our Privacy Statement may be found at https://github.com/filestack/filestack-privacy-policy.
We collect personal data for the following purposes:
- to operate our website;
- to improve our website and product offerings;
- to market our services;
- to manage our relationship with our customers and provide customer support;
- to manage our vendors.
We allow third party advertisers, such as Google and Facebook to collect personal data on our site for the purpose of selling targeted advertisement services. See Advertising Ecosystem below.
We have included details of how we use data we collect for these purposes in the section below captioned Data Use.
Data Collection Methods
Automated data collection on our website
When you visit our site, our web server captures data that may be used to identify you or your device, such as your IP address, device identifier, and information about your device such as the operating system, time zone setting, language setting, browser settings, and browser plug ins. Our server also captures information about your visit to our site, such as the time and duration of your visit on each page on the site, and your navigation path from page to page (i.e., what you click on). We use third-party service providers such as Google Analytics, Segment, and Full Story to capture other information about your site visit, such as recordings of you scrolling activity on each page of our site.
We and our third-party analytics providers may place a cookie on your browser so that we may identify you as a return visitor if you visit our site more than once. Please see How to Opt Out of Online Data Collection below for information on how to block cookies.
Data provided by advertisers
If you arrive at our site by clicking on a link that is part of an advertisement on another site (including an advertisement on a social media platform), the advertising service will identify the link, enabling us to associate you with the advertising parameters we provided to the advertising service. For example, we may ask an advertising service to target our ad to individuals that the ad service has identified as having a high interest in file upload management. If you arrive at our site by means of the link in that ad, we will be able to identify you as having a high interest in file upload management. Advertising services are responsible for the collection, use and disclosure of the data they provide to us in accordance with their published privacy policies.
Data provided by you as part of your communications with us
We collect personal data that you submit to us as part of a communication with us as a visitor or account user, such as via chat on our site, email, submission of a web form, telephone, or in person (such as at a meeting, trade show or other event). For example, you may communicate with us as a visitor to obtain more information about our services, or as an account user to request technical support. The communication may include information that can be used to identify you such as your name, job title, job function, the organization you represent, email address, phone number as well as information about your interest in our company or our services. We do not solicit information from you as part of these communications other than information that is useful to us in light of the purposes described above, but if you choose to volunteer more personal information than we ask for we will collect that as part of the communication.
Data provided by you or your organization to establish and maintain the Filestack account and authorize service users
Our customers are required to name a contact for billing, administrative, technical and other account related communications. We collect the name and business contact information of each account representative. Our customers also authorize service users. We require each individual account representative and service user to establish their own set of account credentials (user name and password). If the customer wishes to integrate their social media accounts with our services, we will require the customer to provide the account credentials used by their representatives on those platforms.
Marketing Partners and Resellers
We have relationships with other companies that help us market, sell and deliver our services. They may collect personal data of the type described above using the methods described above and provide that data to us. For example, we have relationships with companies who refer customers to us and resellers who offer our services under the reseller’s own brand name. We will treat personal information we receive from our marketing partners and resellers the same as the personal information we collect directly.
Combinations of data collected using different methods
We use service providers such as Google Analytics, Segment, and HubSpot to help us associate the personal data we capture about you as part of each visitor interaction as part of a single profile with personal data we collect about you as an account user.
Visitors: We use data collected about visitors:
- to operate our website – web servers, by their nature, must capture your IP address and information about your browser and device to display our site to you;
- to develop our website and help us develop of product offerings – we use the information to help us understand what part of our website and products offerings is of interest to different kinds of visitors so that we can modify and improve our site content and other marketing materials to be more appealing to prospective customers; we may also use the information about your site visits and other visitor interactions to help us measure interest in our services or various features of our services;
- to measure the success of our marketing efforts – we use visitor information to verify whether the ad services we purchase from third parties are actually resulting in visits to our site or other visitor interactions;
- to communicate with you as part of our marketing efforts – if you provide us with contact information we may use it to send you communications about our products or services, or related topics that we think you may find interesting;
Account Users: we use data collected about accounts users (alone or as combined with data collected as part of an account user’s visits (such as pre-login activity on the Site):
- to provide our services – we use login credential to authenticate an individual as an authorized user of our services; we use contact information to send invoices and other account communications, and authenticate individuals who use the services or request information or support on the customer’s behalf;
- to help us develop our service offerings – we use information about your use of our services to measure interest in various features and plan enhancements or new features, and to improve user experience;
- to communicate with you as part of our marketing efforts – we use contract information and information about your use of our services to send you communications about our products or services, or related topics that we think you may find of interest
Choices and Means to Limit Use and Disclosure of Your Data
You may limit our use and disclosure of your personal data. Please send us a request at email@example.com if you would like to know what personal data we have about you and how we use and disclose that data. You may also submit requests to firstname.lastname@example.org if you want to correct, delete or restrict the use of your personal data, or if you object to our processing of your data on the grounds that we do not have a lawful basis for that processing.
On receipt of your notice that the data we have about you is inaccurate or incomplete, we will promptly correct any inaccurate data and ensure it is complete in light of the purposes for which we process the data.
If you wish to revoke any consent you have previously given, we will honor the revocation and will no longer rely on that consent to process your personal data. For example, if you no longer consent to our use of your data for marketing purposes, we will stop using the data for that purpose and notify any third party with whom we have shared that data that they must also stop using it for that purpose.
On your request, we will promptly restrict processing of your personal data or delete your personal data except to the extent the restriction or deletion will prevent us from complying with our legal obligations to our customer or interfere with our reasonable record keeping as necessary to demonstrate compliance with our contracts and applicable law.
Additional Information for California Visitors, Account Users for Limiting Use and Disclosure of Your Data
In addition to our commitments stated above, if our collection of personal information about you for our business purposes is covered by the California Consumer Privacy Act you have the have certain rights under that law.
You may request disclosure of the following specific information:
- the categories of personal information as well as the specific pieces of personal information that we have collected about you for our business purposes over the prior 12 months,
- the categories of sources from which we have collected that personal information,
- our purpose(s) for collecting that personal information,
- the categories of third parties with whom we have shared the personal information, such as our service providers, and
- whether we have sold the personal information to third parties or disclosed the information to third parties for a business purpose, and if so the categories of personal information and third parties.
In addition, you have the right to ask Filestack to delete your personal information. We will comply with your deletion request and require our service providers to do the same, unless we plan to retain the personal information on a legally permitted basis and we give you notice of this fact and the legal basis on which we rely.
You may make a request by calling our toll-free number 833-307-0220 or submitting the request to https://share.hsforms.com/13ieeEy2mQ0yMyeE2kHMbQgfc0j or by sending an email or physical mail request to the addresses above.
Before responding to your request we may ask you to provide information needed to verify that you are the consumer (or have authorization from the consumer) whose personal information is covered by the request.
We may not discriminate against you because you make a request described in this Section by denying you our services or providing a different quality or price for our services, unless the different service or price is reasonably related to the value provided to you by your data.
We do not use file embedded personal data for any purpose except as incident to processing the files in which the data is embedded as part of providing our services to our customer. Some of our customers are subject to special data privacy laws, such as the European Union’s General Data Protection Regulation. Our commitments as a processor of data covered by these types of regulations are stated in our Data Processing Addendum to our services agreement with our customers who are subject to those laws.
Please contact us at the address above if you have questions or concerns regarding our processing of the data described in this Section. We ask, however, that your first contact our customer if you have a request to access, block, erase or take other action with respect to data that we have solely as a data processor for our customer.
We have not sold or leased personal data, and will not sell or lease your personal data unless you give us your consent to do so. The California Consumer Privacy Act includes a definition of “sale” that may include permitting third party advertisers to collect data about our Site visitor for use as part of their advertising services generally. During the prior 12 months we have permitted Google Analytics and Facebook to collect data on our site by means of advertising cookies. See the section below captioned Advertising Ecosystem.
We will not disclose your personal data to third parties except as follows:
This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
Sale of Business
As part of a sale of a sales of business assets where the purchaser needs the personal data to use the assets. We may in the future sell all or part of our assets or be involved in a merger.
We may provide the company that is seeking to acquire our business with access to personal data as part of their evaluation of our business, but will require them to maintain the personal data in confidence and use it only to evaluate our business. If we complete a transaction, it is customary to transfer personal data that is related to the purchased business assets to the purchaser.
We use the services of companies like the ones listed below to collect data on our behalf or to help us analyze, store, manage and otherwise process your personal data. Each of these companies commits in its contract with us to use the personal data only according to our contract with them or our other instructions as necessary to support our business. They are not authorized to use your personal data for any other purpose. They are not authorized to disclose your personal data to others except with our permission, and only if they require the others to comply with the same restrictions that apply to them.
- Mailgun- outgoing email
- Zendesk – incoming email, support
- DocuSign, HelloSign – E-signing
- Stripe, Xero, bill.com – payment processing
- Google – organization email and documents management provider
- Google Analytics – analytics
- Google Ads – advertising
- HubSpot marketing, landing pages, analytics
- Salesforce – customer relationship management
- Amazon AWS – Infrastructure provider, applications
We use online advertising services that enable a practice referred to as “online behavior advertising.” These services aggregate data about an individual’s behavior on many different sites and online services, and use that data to sell targeted advertising services. For example, we permit Google’s advertising services to collect data about your behavior on the Filestack site, as do many other website operators who use Google’s ad services. Google combines the data about an individual that it collects from different sources, and uses this aggregate data to sell advertising services that target the display of ads to web users who meet certain behavioral criteria. Google does not disclose this aggregate data to Filestack, but we are able to infer that visitors who interact with our ad meet the advertising criteria we provided. Google collects this data using cookies, web server logs (its own and its advertising customers), clear gifs and other online data collection techniques. See Online Data Collection Techniques and How to Opt Out of Online Data Collection.
Online Data Collection Techniques
A cookie is a unique alphanumeric identifier that is placed by a web server on the web visitor’s browser. Cookies are used to analyse visitors’ use of the website. For example, a website operator can use the cookie to identify the number of unique visitors to the site, whether or not those visitors are repeat visitors, information about the visitor’s activity on the site, and the user’s device and device settings. A tracking pixel, also known as a web bug or web beacon, is a small graphic (usually 1 pixel x 1 pixel) invisible to the eye, that is embedded in web content or email. When content that has an embedded web beacon is viewed, the browser will request content from a web server, which in turn will set a cookie.
How To Opt Out Of Online Data Collection
You can manage browser cookies through your browser settings. The ‘Help’ feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you disable all cookies on your browser, neither we nor third parties will transfer cookies to your browser. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some features and services may not work.
We will recognize and respond to any “do not track” setting you may have in your browser. The third parties who we permit to collect data on our site have features that allow you to block their data collection via cookies. See their privacy policies and cookie policies:
If you do not wish to receive our email or other communications, please send your request to email@example.com. Please note that it may take up to ten days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make your request.
Children are not permitted to use our site or services. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not use or provide any information on our Sites unless you have involved your parent or guardian. If we discover that we have information about a child we will delete that information. If you are the parent or guardian of a child and you believe we have personal data about the child without your consent, please contact us at the address appearing at the top of this page and we will delete that information.
Filestack protects personal data from unauthorized use, disclosure, corruption and destruction using appropriate technical and organizational measures.
We will retain your personal data only for as long as reasonably necessary to fulfill the purpose for which it was collected, and to comply with our legal obligations. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
- Filestack has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. Data subjects in the EU and in Switzerland who do not receive timely acknowledgment of their complaint, or fee that their complaint is not satisfactorily addressed, should visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. The services of the Better Business Bureau are provided at no cost to you.
- Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel. See https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
- The Federal Trade Commission has jurisdiction over Filestack’s compliance with the Privacy Shield.
- As a Privacy Shield organization we remain liable under the Privacy Shield Principles if our agent processes your personal information in a manner inconsistent with the Principles, unless we proves that we are not responsible for the event giving rise to the damage.