Privacy Policy

SCOPE OF THIS POLICY

This Privacy Policy (the "Policy”) sets out how Personal Data is handled in connection with SOS Files. SOS Files includes the SOS Files website and application, or other SOS Files digital channel through which it is made available or may be accessed (collectively, "SOS Files"). This Policy applies when you download, install, activate, access, or use SOS Files, including when you interact with the SOS Files website and application.

SOS Files is not intended to collect or process Sensitive Data and, to our knowledge, does not do so. For purposes of this Policy, "Sensitive Data" means data regarded as sensitive under applicable law, including special category data, sensitive personal information, highly sensitive information, and comparable legal concepts. Please do not provide, upload, transmit, or otherwise make Sensitive Data available through SOS Files. Depending on the applicable law, Sensitive Data may include information concerning racial or ethnic origin, religious or philosophical beliefs, sexual orientation, health, or certain financial information.

This Policy describes the types of Personal Data that may be involved in operating SOS Files, the purposes for which we handle that information, the circumstances in which it may be used or disclosed, the safeguards we maintain, and the rights and choices that may be available to you. "Personal Data" means information that, under applicable law, identifies, relates to, describes, or may reasonably be linked, directly or indirectly, with a particular individual. This term includes comparable concepts, including personally identifiable information and personal information. Information that does not independently identify a person may nonetheless constitute Personal Data if, when combined with other information, it remains linked or reasonably linkable to that person. In this Policy, "you," "your," and "user" refer to the individual using SOS Files and, where applicable, the company, law firm, client, or other organization for which that individual uses SOS Files.

SOS Files is not directed to children under 16, and we do not knowingly collect or process Personal Data relating to children. If we become aware that a child has provided Personal Data to us, we will delete it as soon as reasonably practicable. Please contact us promptly if you believe a child has shared Personal Data with us.

You are not legally required to provide Personal Data to us. However, if you do not provide certain information, some features of SOS Files may not operate as intended, and we may be unable to fully address your questions, requests, or support requirements.

For the purposes of applicable privacy and data protection laws, we determine the purposes and means of processing Personal Data in connection with SOS Files. Accordingly, we act as the data controller, or in an equivalent capacity recognized under applicable law, in relation to that processing.

If you reside in certain U.S. states, the supplemental U.S. state privacy disclosures below may provide additional information and rights. Where applicable, that section is intended to serve as a Notice at Collection and Privacy Notice under the CCPA.

For questions about this Policy, our privacy practices, or SOS Files, please contact us at: [email protected].

PRIVACY RIGHTS AND REQUEST OPTIONS

Privacy and data protection laws that apply in your place of residence may provide you with certain rights in relation to the Personal Data we process. The availability and scope of those rights depend on the relevant law and the processing concerned. Where a right applies, we will process your request in accordance with applicable legal requirements.

Access to Personal Data. You may be entitled to ask whether we process Personal Data relating to you and, if so, to request access to that information or receive a copy of the Personal Data we hold about you.

Correction, Erasure, and Restriction of Processing. Where permitted by law, you may request that we correct Personal Data that is inaccurate or incomplete, erase or delete certain Personal Data, or restrict our processing of your Personal Data where those rights apply.

Objection and Portability. If these rights are available under applicable law, you may object to certain processing activities and request that your Personal Data be provided in a portable format or transmitted to another recipient, where technically feasible.

Complaints and Appeals. Where available under applicable law, you may appeal our response to a privacy request and submit a complaint to a regulator, supervisory authority, or other competent authority.

Submitting a Privacy Request. To exercise an applicable privacy right or submit a privacy-related inquiry, please contact us at: [email protected].

CIRCUMSTANCES IN WHICH WE MAY PROCESS PERSONAL DATA

The types of information involved may vary depending on how you use SOS Files, whether you contact us, and whether technical, operational, or security events arise during use of the product. Accordingly, not every category described below will apply in every case.

Personal Data may be processed in different operational contexts relating to SOS Files. You may provide certain information directly to us, Personal Data may appear in materials that you choose to process through the product, and certain information may result from product use, support communications, or technical operations. The following categories describe the main circumstances in which Personal Data may be handled and the related purposes. We disclose Personal Data to third parties only as described in this Policy or where otherwise required or permitted by applicable law. By downloading, installing, accessing, or using SOS Files, you acknowledge the practices described in this Policy. If you do not agree with them, you should not download, install, access, or use SOS Files.

• Communications and Support Inquiries. If you contact us about SOS Files, including to request assistance, report an issue, ask a question, or otherwise communicate with us, we may process your contact information, the content of your communication, and any other information or materials that you choose to provide. We use this information to respond to you, provide support, follow up on the relevant matter, and maintain records of support-related activity. We may also retain communications to improve our services and support training. Where support is provided in connection with the delivery of SOS Files, we process this information to perform our contract with you. In other circumstances, we rely on our legitimate interests in maintaining support records and improving support operations.
• Usage, Performance, and Diagnostic Data. We may process information about the operation and use of SOS Files, whether we obtain it directly or through service providers acting on our behalf. This information may include features used, timestamps, session duration, clickstream data, technical events, and records of errors, malfunctions, or troubleshooting activity. We use this information to assess performance, identify and investigate issues, support internal development, improve functionality, and protect SOS Files. This processing is based on our legitimate interests in operating, supporting, securing, and improving SOS Files.
• Content and Materials You Choose to Provide. SOS Files may process materials that you choose to submit through the product. We do not store user content on our own servers or upload that content to our systems for storage. Once processing is completed and the applicable output has been generated, the output is made available to you and remains stored locally on your device. If you submit materials containing Personal Data relating to other individuals, you are responsible for ensuring that you are authorized to do so and have obtained any required permissions or consents. To the extent Personal Data relating to others is processed in this way, we rely on our legitimate interests in providing a functional and available SOS Files product to users.
• Device, Browser, and Connection Details. We may process technical and online identifiers associated with your device or your interactions with SOS Files, including your IP address, device identifiers, browser-based identifiers, Google advertising ID (GAID), and comparable identifiers. We use this information to operate SOS Files, provide its functionality, protect the product and associated services, and detect or help prevent fraud, relying on our legitimate interests. If these identifiers are used for marketing, targeted advertising, or tracking-related purposes, we rely on your consent as further described in this Policy.

HOW WE USE PERSONAL DATA

The categories described above may support a number of related uses of SOS Files. Depending on the circumstances, we may use Personal Data and related information to provide, operate, and improve the product; communicate with users; support personalization, outreach, and promotional activities; protect SOS Files and its associated infrastructure; and comply with legal or regulatory obligations, including for the following purposes:

• Security, Integrity, and Prevention of Misuse. We use information to help maintain the security, integrity, and reliability of SOS Files, our systems, and our users. This includes identifying, investigating, and helping to prevent fraud, misuse, unauthorized activity, and conduct that may violate our terms or applicable law, as well as protecting our services and infrastructure.
• Product Features and Functionality. We process information where necessary to make SOS Files and its features available and to support the functions and capabilities that users may reasonably expect from the product.
• Operations, Support, and Product Development. We use information to operate, administer, maintain, analyze, support, and improve SOS Files and its features. This may include monitoring product performance, addressing technical issues, evaluating usability and compatibility, understanding interactions with the product, and developing fixes, enhancements, and additional features consistent with our operational and business requirements.
• Personalization, Promotions, and Marketing. We may use Personal Data for personalization, promotional communications, advertising, and related marketing activities, including to make content, messages, and advertisements more relevant to your interests and interactions with SOS Files.

COOKIES AND SIMILAR TECHNOLOGIES

Depending on the manner in which you access SOS Files, we may use cookies and comparable technologies in connection with your browsing, access to, or use of the product. These technologies may be placed on, stored on, or otherwise linked to your device when you use relevant SOS Files functions.

Cookies are generally small text files that are widely used in online environments.

We use these technologies to facilitate the operation and usability of SOS Files.

For example, they may help users navigate relevant interfaces, enable certain functions, retain preferences and settings, and improve the responsiveness and effectiveness of interactions with our services.

RETENTION OF PERSONAL DATA

We retain Personal Data for as long as reasonably necessary to fulfill the purposes described in this Policy, except where another retention period is specified or applicable law permits or requires longer retention. We may retain Personal Data for an extended period when needed to comply with legal, regulatory, tax, or accounting requirements; preserve business records; resolve disputes or complaints; or establish, exercise, or defend legal claims.

DISCLOSURE OF PERSONAL DATA AND CROSS-BORDER TRANSFERS

We may share Personal Data relating to SOS Files with recipients outside our organization. Any such sharing will occur where it is consistent with the purposes described in this Policy, supports the operation of SOS Files or our business, or is otherwise required or permitted under applicable law.

Legal Requirements, Claims, and Safety. We may disclose Personal Data where we consider disclosure necessary or appropriate to comply with applicable law, legal process, subpoenas, warrants, court orders, or other binding requests. We may also disclose information to investigate, prevent, or address unlawful conduct, misuse of SOS Files, security incidents, or threats to the rights, property, or safety of any person or organization.

Vendors, Affiliates, and Business Support Providers. We may disclose Personal Data to affiliates, subsidiaries, vendors, advertisers, and other third parties that assist us with hosting, operating, supporting, maintaining, administering, marketing, analyzing, or improving SOS Files.

Corporate Transactions. Personal Data may be shared or transferred in connection with a proposed or completed merger, acquisition, financing, reorganization, restructuring, asset sale, consolidation, or other corporate transaction or business transition involving our company.

Analytics and Product Insights. We may share information with analytics providers and similar partners that help us assess use of SOS Files, measure effectiveness, evaluate performance trends, and generate aggregated or statistical insights.

Recipients that process Personal Data in connection with SOS Files may be located outside your country of residence, including, where relevant, outside the EEA. When Personal Data is transferred internationally, we take measures intended to ensure that it remains protected in accordance with applicable privacy and data protection laws. Where required, these measures may include contractual safeguards and other recognized transfer mechanisms.

PROTECTION OF PERSONAL DATA

We maintain technical, administrative, and operational measures intended to protect Personal Data processed in connection with SOS Files and to help maintain the confidentiality, integrity, and availability of our systems and services.

Our safeguards are designed in light of the nature and sensitivity of the information involved. Our personnel follow generally accepted technical, administrative, and organizational practices intended to reduce the risk of unauthorized access, misuse, loss, alteration, or disclosure. However, no method of transmission, storage system, or security measure is entirely secure, and we cannot guarantee absolute security.

CHANGES TO THIS POLICY AND THE PERSONAL DATA LIFECYCLE

We may update this Policy from time to time to reflect changes to SOS Files, our information practices, or applicable legal requirements. Any updated version will be made available through our website and, unless otherwise stated, will take effect when posted. You should review this Policy periodically. Subject to applicable law, you may be entitled to request deletion of your Personal Data in certain circumstances. Unless we are required to retain Personal Data by law or under a specific agreement, we are not required to keep it for a specified period and may securely delete it, anonymize it, or restrict access to it when it is no longer necessary for legitimate business purposes.

ADDITIONAL U.S. STATE PRIVACY DISCLOSURES

This section supplements the other provisions of this Policy for individuals who reside in certain U.S. states. It describes additional disclosures and rights that may apply under relevant U.S. state privacy laws and should be read together with the remainder of this Policy.

Certain U.S. state privacy laws require businesses to provide consumers with specified disclosures, including the categories of Personal Data collected or processed, the purposes for which that information is used, the categories of third parties that receive it, whether Personal Data is sold or used for targeted advertising, the categories of recipients involved in those activities, consumer rights, procedures for submitting and appealing requests, and available contact methods. This Policy and the supplemental information in this section are intended to address those disclosure requirements.

In addition to the rights described elsewhere in this Policy, residents of certain U.S. states may have additional rights under applicable privacy laws, subject to the limitations, exclusions, and exceptions set out in those laws.

PRIVACY RIGHTS AVAILABLE UNDER CERTAIN U.S. STATE LAWS

Residents of certain U.S. states may have rights in addition to those set out in the general privacy-rights section of this Policy. Subject to applicable law and its relevant limitations, exceptions, and exclusions, those rights may include the following.

• Where applicable law provides, you may opt out of certain processing activities, including the sale of Personal Data, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects. We do not conduct profiling in furtherance of decisions that produce legal or similarly significant effects.
• You may have the right to confirm whether we process your Personal Data and, where technically feasible, to obtain access to that Personal Data in a portable and readily usable form.
• You may have the right to request correction of inaccurate Personal Data and deletion of Personal Data that you provided to us or that we collected about you. In certain circumstances, you may also request a list of specific third parties to whom we disclosed Personal Data relating to you or any Personal Data.

If you exercise a privacy right, you may have the right not to be subject to discriminatory treatment as a result. If we deny a request, you may have the right to appeal that decision. For information about California privacy rights, please visit the California Office of the Attorney General website at https://oag.ca.gov/privacy/ccpa.

We will respond to privacy requests within the time periods required by applicable law. Where permitted by law, we may extend the response period if the applicable conditions are met and any required notice is provided. If we cannot fulfill a request, we will explain our decision and, where applicable, provide information about the appeal process. Appeals will be considered and resolved within the period required by applicable law. If an appeal is denied, you may also have the right to raise the matter with, or submit a complaint to, the relevant regulator, supervisory authority, or Attorney General in your jurisdiction.

SALES AND TARGETED ADVERTISING

Under certain U.S. state privacy laws, the term "sale" may be interpreted broadly to include making Personal Data available to a third party in return for monetary or other valuable consideration, including in connection with targeted advertising. We do not sell Personal Data in the conventional sense of receiving direct payment for information about you. However, depending on the applicable legal definition, our use of cookies and similar tracking technologies, third-party advertising services, and certain disclosures to analytics providers may be treated as a sale or as processing for targeted advertising. The Personal Data that may be involved includes unique identifiers, such as device identifiers and IP addresses; internet or other electronic network activity information, such as interactions with our services; and geolocation information inferred from IP address data.

INTERPRETATION OF THE PERSONAL DATA CATEGORIES IN THIS POLICY

The section entitled CIRCUMSTANCES IN WHICH WE MAY PROCESS PERSONAL DATA identifies the categories of Personal Data that we collect or otherwise process in connection with SOS Files and explains the purposes for which that Personal Data may be collected, used, retained, or otherwise handled. We do not process Personal Data for purposes that are materially different from, unrelated to, or incompatible with those described in this Policy. We also do not collect additional categories of Personal Data without providing notice and obtaining any consent required by applicable law, except where applicable law otherwise permits or requires.

To exercise rights available under applicable U.S. state privacy laws, please submit your request using the contact please contact us at: [email protected].