Privacy policy

This data protection information applies to data processing by:

fileee GmbH,
represented by Marius Gerwinn, Arne Osthues
Windthorststraße 68
48143 Münster
(hereinafter: "fileee" or "we")

E-mail: hello@fileee.com
Phone: +49 (0) 251 323 683 09 (no support)
Please send support requests by e-mail to support@fileee.com.

The data protection officer of fileee can be contacted at the above address, for the attention of Mr. Peter Macherey, or at datenschutz@fileee.com.

DISCLOSURE OF DATA

Your personal data will not be transferred to third parties for purposes other than those listed below. We will only disclose your personal data to third parties if:

you have given your express consent in accordance with Art. 6 para. 1 p. 1 lit. a DS-GVO,
the disclosure is necessary in accordance with Art. 6 (1) p. 1 lit. f DS-GVO for the assertion, exercise or defence of legal claims and there is no reason to assume that you have an overriding interest worthy of protection in the non-disclosure of your data,
in the event that there is a legal obligation for the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c DS-GVO, as well as
this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DS-GVO for the processing of contractual relationships with you.

You can view a list of subcontractors here: Data processing subcontractors

COLLECTION AND STORAGE OF PERSONAL DATA AND THE NATURE AND PURPOSE OF ITS USE - HOW FILEEE COLLECTS AND USES INFORMATION

1) USE OF THE FILEEE.COM WEBSITE

Server protocols

If you access this Internet offer of fileee or also fileee services via a browser, an application or other client software, data is automatically stored and processed by fileee for the time of the communication process. These server logs may contain the following information: Web request, interaction with a service, IP address (Internet Protocol address), browser type, browser language, date and time of the request as well as one or more cookies that uniquely identify the user's browser or user account. After the end of the communication process, the IP address is anonymised. The anonymised data is evaluated for statistical purposes.

The above data will be processed by us for the following purposes:

Ensuring a smooth connection of the website,
Ensuring a comfortable use of our website,
Evaluation of system security and stability, and
for other administrative purposes.

The legal basis for data processing is Art. 6 para. 1 p. 1 lit. f DS-GVO. Our legitimate interest follows from the purposes for data collection listed above. In no case do we use the collected data for the purpose of drawing conclusions about your person.

In addition, we use cookies and analysis services when you visit our website.

Cookies

We use cookies on our site. These are small files that are automatically created by your browser and stored on your end device (laptop, tablet, smartphone or similar) when you visit our site. Information is stored in the cookie that is related to the specific end device used. However, this does not mean that we gain direct knowledge of your identity. The use of cookies serves, on the one hand, to make the use of our offer more pleasant for you. We use so-called session cookies to recognise that you have already visited individual pages of our website. These are automatically deleted after you leave our site.

In addition, we also use temporary cookies to optimise user-friendliness, which are stored on your end device for a certain fixed period of time. If you visit our site again to use our services, it is automatically recognised that you have already been with us and which entries and settings you have made so that you do not have to enter them again.

On the other hand, we use cookies to statistically record the use of our website and to evaluate it for the purpose of optimising our offer for you (see point 5). These cookies enable us to automatically recognise that you have already been to our site when you visit it again. These cookies are automatically deleted after a certain set period of time after your last visit to our site.

The data processed by cookies is necessary for the aforementioned purposes to protect our legitimate interests and those of third parties in accordance with Art. 6 (1) p. 1 lit. f DS-GVO. Most browsers accept cookies automatically. However, you can configure your browser so that no cookies are stored on your computer or a notice always appears before a new cookie is created. However, the complete deactivation of cookies may mean that you cannot use all the functions of our website.

Newsletter & Contact fileee

If you have expressly consented in accordance with Art. 6 (1) sentence 1 lit. a DS-GVO, we will use your e-mail address to send you our newsletter on a regular basis. To receive the newsletter, it is sufficient to provide an email address. The registration for our newsletter takes place in a so-called double opt-in procedure. This means that after registration you will receive an e-mail in which you are asked to confirm your registration. The subsequent confirmation will be logged by us for verification purposes; the time of registration and confirmation will be saved together with your IP address.

Our newsletter is sent via "Mailjet", a platform of Mailgun Technologies, an email service provider, Mailjet GmbH, Alt-Moabit 2, 10557 Berlin, Germany. The email addresses of our newsletter recipients, as well as their other data described in this notice, are stored on Mailjet's servers with Google Cloud Platform in Frankfurt (Germany) and Saint-Ghislain (Belgium). Mailjet uses this information to send and evaluate the newsletters on our behalf. Furthermore, according to its own information, Mailjet may use this data to optimise or improve its own services, e.g. for the technical optimisation of the dispatch and presentation of the newsletters or for economic purposes to determine from which countries the recipients come. However, Mailjet does not use the data of our newsletter recipients to write to them itself or to pass it on to third parties.

Mailjet is ISO 27001 certified and DSGVO compliant. Further information on the purpose and scope of data collection and its processing within the scope of the newsletter using Mailjet can be found in Mailjet's privacy policy, which is communicated below. There you will also find further information on the rights of users and the settings options for protecting privacy:

https://www.mailjet.de/privacy-policy/

You can unsubscribe at any time, for example via a link at the end of each newsletter. Alternatively, you can also unsubscribe at any time in the account settings https://my.fileee.com/account/settings.

Blog

We maintain a blog on our website where we provide information about our services and new offers from fileee.

Webinars

We use the software Webinargeek of the provider WebinarGeek B.V. (contract processor) to conduct customer webinars. During the registration process, personal data is collected and stored in the infrastructure of Webinargeek (Chroomstraat 12 in Zoetermeer, The Netherlands). This includes last name, first name, company name and email address. This is done on the basis of Art. 6 para. 1 lit. f of the DSGVO (Basic Data Protection Regulation). The processing of data by Webinargeek is based on Art. 28 of the DSGVO. In this context, we refer to the privacy policy of Webinargeek: https://webinargeek.com/en/privacy/.

2) USE OF THE MOBILE FILEEE APPS

In addition to the website www.fileee.com, you can also use the fileee services via mobile applications. These are offered in the corresponding shops and download portals for iOS and Android systems.

Personal data (e.g. name, e-mail address, etc.) is only transmitted when using these applications if the user himself expressly and knowingly provides it for specific purposes (e.g. by using a contact form; see below).

We expressly point out that by using mobile applications, personal data may be transmitted to their manufacturers (Apple Inc./Google Inc.) in accordance with the data protection regulations of the respective download platform (iOS/Android). fileee has no influence on the transmission of this personal data and its use by the manufacturers of the download platforms. This notice is therefore provided for your information only.

We would also like to point out that the use of mobile terminals may be subject to storage by the service provider and requests for information by the security authorities in accordance with the provisions of the Telecommunications Act (TKG) to the extent specified therein.

For "cookies" in connection with the use of our mobile applications, see the preceding passage of this data protection notice.

3) ANALYSIS SERVICES

The tracking measures listed below and used by us are carried out on the basis of Art. 6 (1) sentence 1 lit. f DS-GVO. With the tracking measures used, we want to ensure a needs-based design and the ongoing optimisation of our website and the mobile fileee app. On the other hand, we use the tracking measures to statistically record the use of our website or the mobile fileee app and to evaluate it for the purpose of optimising our offer for you. This is based on legitimate interests that justify the processing of your data. The respective data processing purposes and data categories can be found in the corresponding tracking tools.

Google Analytics

fileee uses the web analysis service Google Analytics, which uses "cookies" (see above) to evaluate the use of www.fileee.com (e.g. through reports). This serves exclusively to analyse the offers of fileee and is intended to help fileee to continuously improve the design of the website and the offers.

The information generated in this way, such as

Browser type/version,
Operating system used,
Referrer URL (the previously visited page),
Host name of the accessing computer (IP address),
Time of the server request,

are regularly transmitted to a Google server in the USA and stored there. Since anonymisation of IP information is activated for www.fileee.com, the IP address is shortened by Google beforehand within the EU or in a member state of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and only shortened there. The data collected in this way will not be merged with other personal data stored by Google.

The storage of cookies can be prevented at any time by making the appropriate settings in the browser software (e.g. MS Internet Explorer, Mozilla Firefox, Google Chrome etc.). In this case, however, it is possible that not all functions of www.fileee.com will be fully available.
Irrespective of this, users of www.fileee.com may at any time object to the collection, storage and use of personal data by Google to the extent described above, or prevent such collection, storage and use.

On the one hand, this is possible by installing a so-called plug-in, which can be downloaded from the link https://tools.google.com/dlpage/gaoptout?hl=de. On the other hand, you can configure your browser as described above so that a cookie is never stored. On the other hand, you can configure your browser as described above so that a cookie is never saved.
Further information on the terms of use and data protection of Google Analytics can be found under the following links: https://www.google.com/analytics/terms/de.html, or https://www.google.de/intl/de/policies/.

GOOGLE ADWORDS CONVERSION TRACKING

In order to statistically record the use of this online offer and to evaluate it for the purpose of optimising the online offer for users, we also use Google Conversion Tracking. These tracking measures are carried out on the basis of Art. 6 para. 1 p. 1 lit. a DS-GVO, i.e. exclusively on the basis of your previously given consent. Google Adwords sets a cookie (see above) on your end device if you have accessed our online offers via a Google ad. These cookies lose their validity after 30 days and are not used for personal identification.

If you visit certain pages of our online offers and the cookie has not yet expired, Google and we can recognise that you clicked on the ad and were redirected to our page. Each Adwords customer - including us - receives a different cookie. Cookies can therefore not be tracked via the websites of Adwords customers.

The information collected using the conversion cookie is used to create conversion statistics for Adwords customers who have opted in to conversion tracking. The Adwords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information that can be used to personally identify users.

If you do not wish to participate in the tracking procedure, you can also refuse the setting of a cookie required for this - for example, via a browser setting that generally deactivates the automatic setting of cookies. You can also deactivate cookies for conversion tracking by setting your browser so that cookies from the domain "www.googleadservices.com" are blocked.

Google's privacy policy on conversion tracking is available here: https://services.google.com/sitestats/de.html.

GOOGLE TAG MANAGER

Our website uses the Google Tag Manager, a solution with which marketers can manage website tags via an interface. The tool itself (which implements the tags) is a cookie-less domain and does not collect any personal data. The tool triggers other tags, which in turn may collect data. Google Tag Manager does not access this data. If a deactivation has been made at the domain or cookie level, this remains in place for all tracking tags implemented with Google Tag Manager.

MIXPANEL

Our website, e-mails/SMS messages sent by us, the fileee web app and also the mobile fileee versions for iOS and Android use the "Mixpanel" service of Mixpanel Inc, 405 Howard St., 2nd Floor, San Francisco, CA 94105, USA. Mixpanel makes it possible to track certain user activities (e.g. scanning or archiving documents). Only the usage processes themselves are recorded - we do not collect personal data in this way. We use the information gained in this way about the usage behaviour within the fileee applications to further improve the fileee offers. Mixpanel's privacy policy is available at the following link: https://mixpanel.com/privacy/.

ADJUST

The emails/SMS messages sent by us as well as the mobile fileee versions for iOS and Android use "adjust.io" - a tool for evaluating and analysing the usage behaviour of fileee users, which comes from Adjust GmbH, Saarbrücker Str. 37A, 10405 Berlin, Germany. adjust.io provides information on the installation of the app when it is started and also records other so-called event data (e.g. scanning or archiving documents). The information gathered in this way is processed exclusively in German data centres and should help us to better understand how users actually use fileee's mobile apps and what effects mobile ad campaigns have. With this help, we want to further improve fileee's offers. For the analyses by adjust.io, personal data (namely IDFA or Android ID, IP and MAC address of the mobile device on which the mobile fileee app is installed) are only processed in anonymised form. An identification of the individual fileee user is thus excluded.

HUBSPOT

We use HubSpot on our website. HubSpot is a software solution for controlling and implementing inbound marketing. The stored information is saved on servers of HubSpot and, if applicable, companies associated with HubSpot. This information may be used by us to contact visitors to our website and to determine which of our company's services are of interest to them. All information we collect is subject to this Privacy Policy. We use all information collected solely to optimise our marketing. HubSpot is a software company based in the USA with a branch in Ireland. Contact: HubSpot, 2nd Floor 30 North Wall Quay, Dublin 1, Ireland, Phone: +353 1 5187500 HubSpot is subject to TRUSTe's Privacy Seal and the U.S. - Swiss Safe Harbor Framework.
You can find out more aboutHupSpot's privacy policy here. More information from HubSpotregarding the EU Privacy Policy can be found here. More information about thecookies used by HubSpot can be found hereand alsoat this link.

HOTJAR

We use Hotjar on our website. This is a web analytics service provided by Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, hereinafter referred to as "Hotjar". Hotjar is used by us to analyse the usage behaviour of our website. The legal basis is Art. 6 para. 1 lit. f) DSGVO. Our legitimate interest lies in the analysis, optimisation and economic operation of our website. Hotjar enables us to log and evaluate your usage behaviour on our website, such as your mouse movements or mouse clicks. However, your visit to our website is anonymised. In addition, Hotjar evaluates information about your operating system, your Internet browser, incoming or outgoing links, the geographical origin as well as the type and trigger of the terminal device you are using and processes this information for statistical purposes. Hotjar can also obtain direct feedback from you. In addition, Hotjar offers further data protection information at https://www.hotjar.com/privacy. In addition, you have the option of opting out of the analysis of your usage behaviour. By confirming the link https://www.hotjar.com/opt-out, a cookie is saved on your end device via your internet browser, which prevents further analysis. Please note, however, that you will have to click on the above link again if you delete the cookies stored on your end device.

ROLLBAR

In our website and our webapp, we use the error analysis service of RollBar Inc. (665 Third Street, Suite 150, San Francisco, CA 94107, USA). This error analysis service is used to report any technical errors that occur in the system in order to ensure that they can be rectified as quickly as possible. As soon as a technical error occurs in our system, it is localised and immediately passed on to RollBar. Personal data such as IP address, operating system information, browser versions, etc. are transferred to RollBar's servers in the USA. You can find more information on the handling of your user data in the privacy policy of RollBar Inc. at https://docs.rollbar.com/docs/privacy-policy.

FACEBOOK PIXEL

We use the Facebook pixel from Facebook on our website. We have implemented a code for this on our website. The Facebook pixel is a snippet of JavaScript code that loads a collection of functions that allow Facebook to track your user actions if you have come to our website via Facebook ads. For example, when you purchase a product on our website, the Facebook pixel is triggered and stores your actions on our website in one or more cookies. These cookies allow Facebook to match your user data (customer data such as IP address, user ID) with your Facebook account data. Facebook then deletes this data again. The collected data is anonymous and not visible to us and can only be used in the context of ad placements. If you yourself are a Facebook user and are logged in, your visit to our website is automatically assigned to your Facebook user account.

We only want to show our products to people who are really interested in them. With the help of the Facebook pixel, our advertising measures can be better tailored to your wishes and interests. In this way, Facebook users (provided you have allowed personalised advertising) see suitable advertising. Furthermore, Facebook uses the collected data for analysis purposes and its own advertisements.

Below we show you those cookies that were set by embedding Facebook Pixel on a test page. Please note that these are only sample cookies. Different cookies are set depending on the interaction on our website.

If you are logged in to Facebook, you can change your settings for advertisements yourself at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen. If you are not a Facebook user, you can generally manage your usage-based online advertising at http://www.youronlinechoices.com/de/praferenzmanagement/. There you can deactivate or activate providers. There you have the option to deactivate or activate providers.

At the beginning of each visit to our website, tracking can also be deactivated via the data protection banner.

If you want to learn more about Facebook's privacy policy, check out the company's own data policy at https://www.facebook.com/policy.php.

Facebook Automatic Advanced Matching Privacy Policy

We have also enabled Automatic Advanced Matching as part of the Facebook Pixel feature. This feature of the pixel allows us to send hashed emails, name, gender, city, state, postcode and date of birth or phone number as additional information to Facebook if you have provided us with this data. This activation allows us to tailor advertising campaigns on Facebook even more precisely to people who are interested in our services or products.

BELBOON

We use the Belboon service on our website and in the fileee shop. Belboon is a German affiliate network that offers affiliate marketing. Affiliate marketing is an internet-based form of distribution that enables commercial operators of websites, so-called merchants or advertisers, to display advertisements, which are usually remunerated via click or sale commissions, on websites of third parties, i.e. distribution partners, also called affiliates or publishers. The merchant provides an advertising medium via the affiliate network, i.e. an advertising banner or other suitable means of Internet advertising, which is subsequently integrated by an affiliate on its own Internet pages or advertised via other channels, such as keyword advertising or e-mail marketing. The operating company of Belboon is belboon GmbH, Weinmeisterstr. 12-14, 10178 Berlin.

MICROSOFT ADVERTISING

We use the advertising program Microsoft Advertising ("Bing Ads") of the American company Microsoft Corporation for our online marketing measures. This advertising program is based on a pay-per-click system and allows advertisers to place ads via the search engines Bing and Yahoo! We use this tool to place advertisements designed to draw people's attention to our product. To check the success of these measures, we use Microsoft's conversion tracking tool on our website, which stores data. Among other things, this gives us insight into user behavior and which ad a user came to our website via and which content and subpages on the website are of particular interest to this user. For this purpose, we have integrated a code snippet, the so-called conversion tracking tag, from Microsoft Advertising on our website. This is the so-called Universal Event Tracking (UET) tag. The data collected is analyzed anonymously so that no conclusions can be drawn about individual behavior. We therefore only receive data and evaluations of user behavior on our website, but no personal information. Microsoft uses the collected data to optimize its own advertising and services. For users with a Microsoft account, user data such as IP address can be linked to the account.

4) REGISTRATION

User accounts can be created on the website www.fileee.com as well as in our mobile applications in order to use the services of fileee. When creating a fileee account, the fields provided in the registration form must be filled in correctly. The personal data collected in this way will be used by fileee exclusively for the purpose of implementing the user contract for the fileee services on the basis of Art. 6 para. 1 lit. b DS-GVO.

In particular, passwords of the user are never automatically stored by fileee, but only at your request and with your express consent.
If information is subsequently removed from the user profile, the data previously collected for this purpose will be deleted immediately.

5) USE OF THE FILEEE SERVICES

ORGANISE DOCUMENTS WITH THE FILEEE APPS

The principle of fileee is a new kind of document management. With fileee, you can digitally archive and organise your documents in a central location and access them from anywhere. You can also remove your documents from our platform at any time or export them in a common file format and save them elsewhere.

fileee makes it possible to structure documents and recognises all important information. With the help of fileee, documents can be found easily and quickly thanks to intelligent organisation and search functions. Through synchronisation, users can access and work with your documents and information from all connected devices.

Within the scope of document storage and analysis, fileee also processes personal data. If the documents transmitted to fileee contain personal data of third parties, the user is responsible for obtaining the corresponding consents, or to transmit personal data only if a legal basis for permission exists.

This data processing in fileee takes place on the basis of Art. 6 para. 1 lit. b DS-GVO for the execution of the user contract for the services of fileee as well as on the basis of Art. 6 para. 1 lit. f DS-GVO, whereby our legitimate interest is to achieve an improvement of our services (for example, through a faster allocation of documents and the improvement of findability) for all users via the document analysis and, if applicable, to send you service messages if companies offer fileee as a communication channel for their customers and you have uploaded documents of this company to fileee.

FILEEE AS A COMMUNICATION PLATFORM WITH OUR PARTNERS

With fileee Conversations, a solution for companies, fileee also includes an open communication platform. With this, you and participating companies can communicate directly, easily and securely with each other within fileee. In particular, documents can be exchanged between you and the participating companies in this way (e.g. insurance documents, bank documents or similar).

If you use fileee in this way, fileee has no influence on the further processing of the documents you send to the participating partner companies. fileee is in this respect only the means of communication. What the participating companies do with your data, how they process it and to whom it may be passed on, is the sole responsibility of the participating companies. Please refer to the data protection notices of the participating companies and their contractual conditions. Always pay particular attention to which documents you are allowed to send to the participating companies via fileee and which you are not! Always bear in mind that the documents transmitted may also contain health-related information and thus particularly sensitive personal data.

The same applies in reverse in the event that you allow the participating companies to legally deliver documents to you via fileee. fileee will notify you of the receipt of such documents. However, you are responsible for their timely retrieval on fileee. For further details, please refer to the agreements concluded between you and the participating company on the use of fileee as a communication channel.

ANALYSIS IMPROVEMENT

In addition, it is possible to provide more detailed information that fileee may use to provide a better service to fileee users.

Within the scope of this "analysis improvement", you have the opportunity to complain about errors within the scope of document recognition (e.g. an incorrectly recognised sender in a document, an unrecognised date, an incorrect assignment of a document as an invoice) and at the same time contribute to the elimination of this error in the interest of all fileee users. By sending in the affected document, you can help us to improve our analysis. A fileee staff member will then look at the submitted document and try to identify and fix the error. If you also leave a comment, this will make it even easier for us to "improve the analysis".

We treat your documents with the utmost confidentiality and never pass them on to third parties. With each new fileee update, we try to include as many submitted documents as possible so that they are soon correctly recognised by the analysis. Afterwards, the document remains in a training set, which we can use to further validate, test and automatically improve our analysis.

This information is provided voluntarily and is transparent at all times. Of course, users can also use it to decide at any time how much they would like to contribute to improving the service. No documents are automatically shared with fileee for the purpose of analysis improvement, but exclusively on the basis of your consent with regard to each individual document (Art. 6 para. 1 lit. a DS-GVO).

ELECTRONIC SIGNATURE

Within the scope of the electronic signature, the writing speed, writing direction, writing pauses and, if applicable, pressure strength are recorded and stored in encrypted form. This is done to prove that you have signed the form. You have the right to revoke your consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.

PERSONAL FILEEE EMAIL ADDRESS

fileee users receive a personal upload email address(https://fileee.thinkowl.com/portal/fileee/knowledgebase/file/19646/Pers%C3%B6nliche-fileee-E-Mail-Adresse-zum-Hochladen-von-Dokumenten). If the fileee user uses this functionality, incoming e-mails are sent to the personal upload e-mail address using the "MailChimp" service.

"MailChimp" is a platform of Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA.Your email addresses as well as the content of the mail traffic with fileee are stored on MailChimp's servers in the USA. MailChimp uses this information to send reciprocal messages on our behalf. Furthermore, according to its own information, MailChimp may use this data to optimise or improve its own services, e.g. to technically optimise the dispatch. However, MailChimp does not use the data to write to them itself or to pass it on to third parties.

We have concluded a "Data Processing Agreement" with MailChimp. Further information on the purpose and scope of data collection and its processing in the context of mail traffic using "MailChimp" is contained in the privacy policy of "MailChimp" communicated below. Further information on the rights of users and the setting options for protecting privacy can also be found there: https://mailchimp.com/legal/privacy/

6) CONTACT WITH FILEEE

GENERAL INFORMATION

Mail traffic with fileee takes place via the Mailjet service listed under Newsletter.

WHEN USING OUR CONTACT FORM

For questions of any kind, we offer you the possibility to contact us via the forms provided. In doing so, it is necessary to provide a valid e-mail address so that we know who the enquiry is from and so that we can answer it. Further information can be provided voluntarily.
Data processing for the purpose of contacting us is based on your voluntarily given consent in accordance with Art. 6 para. 1 p. 1 lit. a DS-GVO.
The personal data collected by us for the use of the contact form will be automatically deleted after completion of your request. We will store e-mails in accordance with the statutory retention periods and delete them thereafter.

FOR SUPPORT REQUESTS

When users of the fileee Services submit a support request to fileee, data related to these messages is collected and stored by fileee. This data consists of the contact details you provide as well as the time and content of your support request and further communication between you and us in this regard. This is done on the basis of the consent you have given for this, Art. 6 para. 1 lit. a DS-GVO.

The personal data collected by us in the course of such support requests will be automatically deleted after the request you have made has been dealt with. We will retain e-mails in accordance with the statutory retention periods and delete them thereafter.

SERVICE MESSAGES FROM FILEEE

The e-mail address provided during registration may be used by fileee to send you communications about our services (e.g. new GTC or data protection provisions, information on how to use fileee better as part of the onboarding process, information regarding limited use such as maintenance, or similar). However, this possibility only exists within the scope of the implementation of the usage contract itself and is based on Art. 6 para. 1 lit. b DS-GVO.

Due to our legitimate interest in offering you the most comprehensive and convenient use of our digital document management (Art. 6 para. 1 lit. f DS-GVO), fileee will also send you the information that a company from which you have uploaded documents to fileee offers you the use of fileee as a communication channel (see above under "fileee as a communication platform").

Additional information on other fileee services will only be sent to the user with the express prior consent of fileee (Art. 6 para. 1 lit. a DS-GVO); see above under Newsletter.

ERROR REPORTS

We want to constantly improve our services and the platform to enable all users to make the best possible use of fileee. To this end, we have provided functions that send us information in the event of malfunctions of the platform that occur with individual users. We receive this information together with the personal details of the user for whom the error occurred. However, we only process it in anonymised form as long as you do not send us a support request (see above). In such a case, we check whether and, if so, which error report we have already received that relates to your support request. The personal data collected by us in the context of such error reports will be automatically deleted after the error message has been dealt with.

You can switch off the automatic transmission of error reports to us in the fileee settings at any time and thus exercise your right to object.

THINKOWL

We use ThinkOwl software to provide a chat and to handle customer enquiries via our apps and to provide the help centre.

ThinkOwl is provided by ThinkOwl Europe GmbH, Carl-Benz-Straße 10-12, D-56218 Mülheim-Kärlich. The data and contents of the communication are processed and stored via servers at ThinkOwl Europe GmbH. We have concluded a Data Processing Addendum (DPA) with ThinkOwl to ensure that the service is used in accordance with data protection regulations.
For the chat function, the chat function can also be deactivated via the data protection banner at the beginning of each visit to our website.

Microsoft Bookings

To book consulting appointments, we use Microsoft Bookings, a product of Microsoft Corporation, One Microsoft WayRedmond, WA 98052-6399, USA. Necessary data such as name, e-mail address, postal address and telephone number are collected by Microsoft Bookings and transmitted to fileee GmbH.
You can find more detailed information on data processing by Microsoft in the Microsoft data protection declaration at https://privacy.microsoft.com/en-us/privacystatement. If you have any questions, you can also contact Microsoft directly using the contact form.

7) SOCIAL MEDIA

We use social plugins of the social networks Facebook, Twitter and Google in our online offers on the basis of Art. 6 para. 1 p. 1 lit. f DS-GVO in order to make us better known. The underlying promotional purpose corresponds to our legitimate interest. The responsibility for the data protection-compliant operation of the social networks is to be ensured by their respective providers.

These plugins are integrated using the so-called two-click method in order to protect you as best as possible. This means that when you visit our site, initially no personal data is transmitted to the providers of the plugins. You can recognise the respective provider of the plugin by marking it on the box via its initial letter or the respective logo (e.g. for Facebook: white "f" on a blue tile or a "thumbs up" sign). We open up the possibility for you to communicate directly with the provider of the plugin via the button. Only if you click on the marked field and thereby activate it, the plugin provider receives the information that a user has called up the corresponding website of our online offer. In addition, personal data (in particular the IP address) is then transmitted to the provider of the respective plugin. By activating the plugin, your personal data is transmitted to the respective plugin provider and stored there (in the case of US providers, in the USA). In the case of Facebook, according to the provider's own information in Germany, the IP address is anonymised immediately after collection. Since the plug-in providers collect data in particular via cookies (see above), we recommend deleting all cookies via your browser's security settings before clicking on the greyed-out box.

We have no influence on the data collected and data processing procedures, nor are we aware of the full scope of data collection, the purposes of processing or the storage periods at the plug-in providers. We also have no information on the deletion of the collected data by the plug-in provider.

The respective plug-in provider stores the data collected about users of our online offer as usage profiles and uses these for the purposes of advertising, market research and/or demand-oriented design of its own website. Such an evaluation is carried out in particular (also for users who are not logged in) for the display of needs-based advertising and to inform other users of the social network about the activities of users on our website. Users have a right to object to the creation of these user profiles, whereby a user must contact the respective plugin provider directly to exercise this right. Through the plugins, we independently offer users the opportunity to interact with the social networks and other users so that we can improve our offer and make it more interesting for our users.

The data transfer takes place regardless of whether you have an account with the plug-in provider and are logged in there. If you are logged in to the plug-in provider, the data we collect is directly assigned to your accounts with the plug-in provider. If you click the activated button and, for example, link to the page, the plug-in provider also saves this information in your respective user account and shares it publicly with your contacts. We therefore recommend logging out regularly after using a social network, but especially before activating the button, as this avoids an assignment to the profile with the plugin provider.

Further information on the purpose and scope of data collection and its processing by the plug-in providers can be found in the data protection declarations of these providers communicated below. Further information on the rights of users and the setting options for protecting privacy within these networks can also be found there.

Facebook Inc, 1601 S California Ave, Palo Alto, California 94304, USA; http://www.facebook.com/policy.php; further information on data collection:
http://www.facebook.com/help/186325668085084,
http://www.facebook.com/about/privacy/your-info-on-other#applications and
http://www.facebook.com/about/privacy/your-info#everyoneinfo.
Google Inc, 1600 Amphitheater Parkway, Mountainview, California 94043, USA; https://www.google.com/policies/privacy/partners/?hl=de.
Twitter, Inc, 1355 Market St, Suite 900, San Francisco, California 94103, USA; https://twitter.com/privacy.

8) WEBSHOP

Certain fileee products and services are available for purchase. When a user of a fileee product or service expresses a desire to purchase and provides personal information for that purpose, certain information is disclosed to or collected by FoxyCart.com LLC, Attn: Privacy, 337 Garden Oaks Blvd, Ste. #56961, Houston, TX 77018 (https://www.foxy.io/) for processing, primarily for the purpose of processing payments. FoxyCart is PCI DSS (Payment Card Industry Data Security Standard) compliant as a Level 1 Service Provider and is listed on both the Visa and MasterCard global registries.

FoxyCart.com LLC acts as a data processor for fileee in this regard and the data shared with or collected by them is transferred to the USA for processing. fileee has entered into a "Data Processing Agreement" with FoxyCart.com LLC.

The personal information shared with or collected by FoxyCart.com LLC may be collected automatically as part of your use of the Site or entered manually by you to enable your use of FoxyCart.com LLC's services. Personal data shared with or manually collected by FoxyCart.com LLC may include:

E-mail address
Company information such as website URL, postcode and country, and other information required to configure an account with FoxyCart.com LLC.
Credit card and billing information

Personal information collected automatically may include information about products that are eligible for purchase or have already been purchased, the status of purchases and payments, any data from your browser's request to FoxyCart.com LLC's servers, such as the website that referred you to FoxyCart.com LLC, your IP address, browser version and operating system, and any cookies that may have been created during previous visits to FoxyCart.com LLC's website. This information is used to measure the use of FoxyCart.com LLC's websites and services.

FoxyCart.com LLC shares your data information for the following services:

Services used to communicate with you. For example, the email address can be imported into a service used to send emails, such as email receipts and payment reminders.
Services to improve the understanding of system usage. For example, FoxyCart.com LLC uses analytics services to identify problems in the system and make improvements.
Services used to process payments in order to bill you for services.

The legal basis for this processing is Art. 6 para. 1.b) DSGVO.

Personal data is processed for the purposes of enabling payment for fileee products and services, customer service, product and service development, responding to enquiries, marketing analysis and use of the FoxyCart.com LLC website.

Data shared with or collected by FoxyCart.com LLC is processed through its services and servers to the extent necessary to complete the transaction and send email receipts, to prevent fraud and abuse, to maintain the contents of your shopping cart, and in an anonymous, aggregated format to calculate statistics about Foxy.io (i.e. average transaction value, average transactions per shop, average transactions per day per shop, etc.), which may be used for both internal purposes (server load analysis, etc.) and external purposes (marketing, etc.). Some of this data is stored on FoxyCart.com LLC's servers to the extent necessary for transaction history reporting and as required by the various laws and regulations related to documentation for tax purposes.

Whenever you are asked to provide personal information, FoxyCart.com LLC will inform you of the purposes for collecting such information, usually at the time the information is collected. Providing information on online forms is always voluntary and you are free to complete them. However, if you choose not to do so, some products and services may not be available to you. FoxyCart.com LLC will notify you when certain information is required to perform the requested service, usually by placing an asterisk or other designation next to the required information (or by notifying you when certain requested information is optional).

If you choose to store your payment information during the checkout process, this information will be stored at FoxyCart. fileee does not have access to your payment information except for the last 4 digits, card type and expiry date.

9) IN-APP PURCHASES

The processing of paid in-app orders is additionally subject to the provisions of the operators of the respective app stores. When a user of a fileee product or service, expresses a desire to purchase and provides personal information for this purpose, certain information is disclosed to or collected by RevenueCat, Inc, 237 A St PMB 65402, San Diego, California (https://www.revenuecat.com/) for processing, primarily for the purpose of payment processing:

RevenueCat acts as a data processor for fileee in this regard and the data shared with or collected by them is transferred to the US for processing. RevenueCat has submitted to the EU Standard Contractual Clauses for Third Party Transfers. In addition, fileee has entered into a "Data Processing Agreement" with RevenueCat.

10) SHIPPING OF ORDERED GOODS

We use the full-fillment service provider Lamundi to provide the shipping of goods. The goods ordered by you are therefore shipped directly via this service provider. This service is provided by:
Lumundi Versand GmbH, Einsteinstr. 18, 48683 Ahaus
If you have ordered physical goods from us (e.g. the fileeeBox, fileeeBox set), the necessary data such as the delivery address and contact information such as e-mail are provided to the service provider Lamundi and processed by it. We have concluded a data processing contract with Lamundi to ensure that the service is used in accordance with data protection regulations.

11) DATA SUBJECT RIGHTS

You have the right:

to request information about your personal data processed by us in accordance with Art. 15 DS-GVO. In particular, you can request information about the processing purposes, the category of personal data, the categories of recipients to whom your data have been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of your data if it has not been collected by us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details.

We may only refuse to provide you with information if and insofar as the information would disclose information that must be kept secret according to a legal provision or by its nature, in particular due to the overriding legitimate interests of a third party (Section 29 para. 1 sentence 2 BDSG), the competent public authority has determined to us that disclosure of the data would endanger public security or order or otherwise be detrimental to the welfare of the Federal Government or a Land (Section 34 para. 1 no. 1 BDSG in conjunction with Section 33 para. 1 no. 2 lit. b BDSG), or the data is only stored because it may not be deleted due to legal or statutory storage regulations, or exclusively serves the purpose of data security or data protection control and the provision of information would require disproportionate effort and processing for other purposes is precluded by appropriate technical and organisational measures (Section 34 (1) no. 2 BDSG).
demand the correction of incorrect or incomplete personal data stored by us without delay in accordance with Art. 16 DS-GVO;
pursuant to Art. 17 DS-GVO to request the erasure of your personal data stored by us, unless the processing is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the assertion, exercise or defence of legal claims;
to request the restriction of the processing of your personal data in accordance with Art. 18 DS-GVO, insofar as the accuracy of the data is disputed by you, the processing is unlawful, but you object to its erasure and we no longer require the data, but you need it for the assertion, exercise or defence of legal claims or you have objected to the processing in accordance with Art. 21 DS-GVO;
pursuant to Art. 20 DS-GVO to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request the transfer to another controller;
revoke your consent at any time in accordance with Art. 7 (3) DS-GVO. This has the consequence that we may no longer continue the data processing based on this consent for the future,
if your personal data are processed on the basis of legitimate interests pursuant to Art. 6 (1) p. 1 lit. f DS-GVO, to object to the processing of your personal data pursuant to Art. 21 DS-GVO, insofar as there are grounds for doing so which arise from your particular situation or the objection is directed against direct advertising. In the latter case, you have a general right to object, which will be implemented by us without specifying a particular situation.
In addition, you have a general right of appeal to the data protection supervisory authority responsible for you. The authority responsible for fileee is the "State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia".

If you wish to exercise your right of revocation or objection, simply send an e-mail to support@fileee.com.

12) DATA SECURITY

We use the widespread SSL procedure (Secure Socket Layer) in connection with the highest encryption level supported by your browser when visiting the website. As a rule, this is 256-bit encryption. If your browser does not support 256-bit encryption, we use 128-bit v3 technology instead. You can tell whether an individual page of our website is encrypted by the closed display of the key or lock symbol in the lower status bar of your browser.

We also use appropriate technical and organisational security measures to protect your data against accidental or intentional manipulation, partial or complete loss, destruction or against unauthorised access by third parties. Our security measures are continuously improved in line with technological developments.

Further information on data security can also be found at fileee.com/security.

13) CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be amended from time to time. fileee will not restrict the rights of users under this Privacy Policy without their express consent. The most current version of this Privacy Policy can be found at www.fileee.com. If the changes are material, we will provide more detailed notice. For some services, e-mail notifications of changes to the privacy policy will also be sent to the e-mail address you provided during registration or, if applicable, changed at a later time in the settings of your user account.

Belboon does not receive any personal data from fileee. Only the identification number of the affiliate, i.e. the partner referring the potential customer, and the order number of the fileee customer are processed. The purpose of the data exchange is the processing of commission payments between a merchant and the affiliate, which are processed via the affiliate network, i.e. Belboon. The data subject can prevent the setting of cookies by our website at any time by means of an appropriate setting of the Internet browser used and thus permanently object to the setting of cookies. The applicable data protection provisions of Belboon can be found athttps://www.belboon.com/de/ueber-uns/datenschutz/. 