Privacy policy

Introduction

Welcome to  “File Transfer” privacy notice.

“File Transfer” respects your privacy and is committed to protecting your data. This privacy notice will inform you as to how we look after your data when you use our app and tell you about your privacy rights and how the law protects you.

Іmportant information and who we are. Purpose of this privacy notice

This privacy notice aims to give you information on how “File Transfer” collects and processes your data through your use of this app, including any data you may provide through this “File Transfer” when you sign up to our “File Transfer”.

Accepting this Data Processing Policy, you confirm that you have a complete capacity and legal capacity and have reached the age required by Bulgarian law or by another country of which you are a citizen to accept this privacy policy.

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

You will be required to read and accept this Privacy Policy before using the application. By using the "File Transfer" application YOU MESSAGE TO US that: (i) YOU READ, UNDERSTAND, AND AGREE TO THIS CONFIDENTIALITY POLICY, AND (ii) YOU ARE MORE than 14 years old (or EXCEED THAT YOUR PTA or guardian reads and AGREE TO THIS CONFIDENTIALITY POLICY FOR YOU). If you do not accept and agree to this Privacy Policy, you must immediately stop using our app.

Controller

Netpeak EOOD (address 43 Cherni Vrah Blvd, Sofia registered under Bulgarian law) is the controller and responsible for your data (collectively referred to as "File Transfer", "we", "us" or "our" in this privacy notice).

We have appointed a data privacy manager who is responsible for overseeing questions about this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Netpeak EOOD

Email address: meatpiemeet@gmail.com

Postal address: 43 Cherni Vrah Blvd, Sofia, Bulgaria

Changes to the privacy notice

This version was last updated on 04.10.2021

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you through the “File Transfer”, or by presenting you with a new version of this Privacy Policy for you to accept, if we, for example, add new processing activities or collect some additional personal data from you.

Your continued use of the app after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. In some cases, you will have to accept changes to the Privacy Policy explicitly.

Personal data you provide to us and the data we collect about you

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

When you use the "File Transfer", you may provide us with any image and contact that is stored on your device. Please do not provide us any pictures of yourself or of any other information that may be identified as Personal Data. Nevertheless, we would treat all received photos/images and contacts in the same manner as Personal Data in this Privacy Policy. We use this information and store it locally on your device.

We may automatically collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

  1. Device Data. Includes model, OS version, language, and time zone;
  2. Location dataю. Includes internet protocol (IP) address, language, and location;
  3. Usage Data. Includes information about how you use our app, user activity within the application;
  4. Files and folders are placed on your device. Access to the gallery, photos, audio recording videos, documents, contacts.
  5. Data on subscription fees. This is the information we get from the Apple store when you buy our subscription.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific File Transfer feature. However, if we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this privacy policy.

We do not collect any Special Categories of Personal Data 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 offenses.

How we use your personal data

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

  1. Where we need to perform the contract, we are about to enter into or have entered into with you.
  2. 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.
  3. Where we need to comply with a legal or regulatory obligation.
  4. We may process your data if you have given us specific consent to use your personal information for a specific purpose.

If you share with us the personal data of a third party, you confirm that such a third party gave you consent on the collection and processing of his/her data by us. We in our turn will take the same measures and procedures to ensure the safety of such information as we do in the relation to your data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all 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 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 data where more than one ground has been set out in the table below.

Purpose

Type of data

Lawful basis for processing including basis of legitimate interest

For marketing and analytical purposes. To provide, improve and develop the application.

Device Data.Includes model, OS version, language, and time zone

Performance of a contract with you.

Your agreement.

For marketing and analytical purposes. To provide, improve and develop the application.

Location data includes internet protocol (IP) address, language, and location/

Performance of a contract with you.

Your agreement.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).

For marketing and analytical purposes. To provide, improve and develop the app.

Usage Data includes. Information about how you use our app, user activity within the application.

Performance of a contract with you.

Your agreement.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).

To configure content within the application. Allows you to transfer photos, audio recording videos, documents, contacts. to other users.

Files and folders are placed on your device. Access to the gallery, photos, audio recording videos, documents, contacts.

Performance of a contract with you.

Your agreement.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).

Necessary to comply with a legal obligation.

To provide access to the application, identify the user, and track the subscription period.

Data on subscription fees

Performance of a contract with you.

Your agreement.

Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).

Necessary to comply with a legal obligation.

Disclosures of your data

We may have to share your data with the parties set out below for the purposes set out in the table above.

  1. Internal Third Parties: companies inside our Group.
  2. External Third Parties: Google LLC, Facebook, Inc., Apple Inc., Appfigures, Inc., Amplitude Inc., Velia.net. These parties analyze your data and show relevant information about the app to people who might be potentially interested in it or helps us with the storage of all Personal Data when you use the app, to understand how you use the App, engage with particular features and what you like or dislike the most to generate statistical reports.

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

Opt-out options. You can withdraw your consent or opt-out, whatever applies in your case, from sharing your Personal Data under this subsection anytime by using one of the following options:

  1. By contacting us at meatpiemeet@gmail.com;
  2. By adjusting your device settings in iOS.
  3. Stop using our application.

Obtaining data from third parties

When a user buys a subscription, we receive transaction data, ID subscriptions, subscription terms, application statistics from the Apple store.

The collection, processing, and transmission of data on purchase via the Apple store are further regulated by the Apple store data processing policy.

Banking information

When you pay for a subscription to our app, you share your banking information with the Apple store. This relationship is further regulated between the user and Privacy Policy the Apple store.

We do not collect or process your bank information when buying a subscription.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

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

We also use technical data encryption tools such as SSL protocols to keep your data secure.

Data retention

How long will you use my personal data?

We will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy 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 unauthorized use or disclosure of your data, the purposes for which we process your data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

According to GDPR, we store your data while you use our application.

In some circumstances, you can ask us to delete your data. To send an e-mail to our address: meatpiemeet@gmailta.

In some circumstances, we may anonymize your 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.

We can store your data on the servers of our partners, namely Google, Facebook, Apple, Appfigures, Amplitude, Velia.

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

We do not use user data for sale (or any other commercial activity) to other companies. User data is used solely to ensure the functionality of the app.

Your legal rights

Under the legislation of the European Union, you have the right to:

  1. receive information, namely, what personal data we process and why (disclosed by this policy);
  2. Right to Erasure. You have the right to delete data under certain circumstances.
  3. Right to Rectification. You have the right to ask us to correct your inaccurate data, as well as the right to make additions to it.
  4. Right to access. You can request a copy of your data.
  5. Right to restriction of the processing. In certain cases, you have the right to request the termination of data processing by allowing the continued storage of data.
  6. Right to data portability. You can request a copy of your data in a machine-readable form that can be transferred to another person who processes the personal data.
  7. Right to object. Under certain circumstances, including when data is processed for legitimate interests or marketing purposes, you may object to such processing.
  8. Rights related to automated decision-making, including profiling. In this area, there are several rights related to the fact that processing carried out exclusively on an automated basis can lead to a decision that has legal and other significant consequences for a person. In such circumstances, you have the right to human interference in the decision-making process.

If you wish to exercise any of the rights set out above, please contact us.

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 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 about 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 several requests. In this case, we will notify you and keep you updated.

Glossary

In this Policy the following terms shall have the following meanings:

Lawful basis.

Legitimate Interest means the interest of our business in 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 data for our legitimate interests. We do not use your personal data 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 at meatpiemeet@gmail.com.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

California privacy rights

This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. Therefore, this section applies only to residents of California, United States.

For more details about the personal information we have collected, including the categories of sources, please see in section the “Personal data you provide to us and the data we collect about you”. We collect this information for purposes described in section “Purposes for which we will use your personal data” of this Privacy Policy. We may also share your information with certain categories of third parties as indicated in Section “Data retention”

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request under their rights under the CCPA by contacting us at meatpiemeet@gmail.com. We will verify your request and inform you accordingly. You may also designate an authorized agent to exercise these rights on your behalf.

Contacts

Full name of legal entity: Netpeak EOOD

Email address: meatpiemeet@gmail.com

Postal address: 43 Cherni Vrah Blvd, Sofia, Bulgaria