Privacy Policy
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Privacy & Cookie Policy
Introduction
This Policy covers the processing activities of the OnlyLockbox
services, software, websites (including browser extensions), applications, and
advertisements (together: “Services”). The Services allow you to create, share,
collect, capture and/or visualize your ideas, texts, graphics, videos, audio,
data, information, files, decks or other content (together: “User Content”).
The Services may be provided to you online, in the form of a mobile and/or
desktop application(s) and/or may be integrated in a third party service. By
using any of the Services you agree to have read and understood our Privacy
Policy as below.
Kelbix Technology Group (Pty) Ltd (KTG) (a company registered
in the Republic of South Africa) is the data controller of your personal
information.
If you have any questions, or complaints, or if you want to
exercise your privacy rights: please contact [email protected].
Information you provide
This section describes the information that you typically
provide when you sign-up for our Services (with or without account), when you
create or update your account or subscription. This information may also be
collected when you reach out to us with questions, complaints, or reports of
possible violations of our Terms.
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Category
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Description
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User information
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We collect this information
when you use our Services, or when you sign-up for or update your account. We
may also collect this information when you participate in surveys, research,
promotional activities, or events. Examples include your name, email address,
home or billing address, company name, phone number, password, profile photo,
branding, and your profession.
This may also include your billing and payment information
in case you decide to purchase a subscription or to make a purchase on our
Services.
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User Content
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We collect the content you create, upload, or share
through the use of our Services. This includes files, photos, videos, audio,
metadata, messages, comments, reviews, and descriptions.
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User Contacts
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We collect the information of the people and organizations
you connect and interact with when using our Services. For example, the email
addresses of the recipients of your files.
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Information related to Communication, Surveys, Events
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If you participate in our surveys, research, or
promotions, such as lotteries or events we organize, we collect information
such as the answers you provide or your contact information.
When you reach out to us for customer support, or when you
report possible violations of our Terms, we collect information about your
message or report as well as your contact information.
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Information we collect automatically when you use our
Services
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Category
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Description
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Technical Information
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Technical information, including approximate location
We collect certain device and network connection information when you access
the Services. This information includes your device model, OS, IP address,
system language, device ID, and other technical data. We automatically assign
you a user ID. Furthermore, we collect service-related, diagnostic, and
performance information, such as crash reports. Based on your Technical
Information, such as your IP-address or device settings, we determine your
approximate (geo)location, such as the city or country you reside in at that
moment.
Cookie information We make use of cookies and other
technologies to operate and secure our Services, for preference management,
and for marketing and advertising purposes. Read the section “Why and how we
use cookies” to learn more.
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Usage Information
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We collect information about how you engage with our
Services, including information about the Transfers you download, the time,
duration, and frequency of your use, your engagement with other users, and
your settings.
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Inferred information
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We infer information such as attributes (e.g. age-range)
and interests based on your data.
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Payment & Purchase Information
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When you make purchases or payments on our Services, we
collect information such as purchased items, transaction information,
transaction ID, product details, and price.
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Information we receive from Other Sources
In certain cases we may receive the Information described
above from Other sources, such as partners or other users. The table below
offers you more insight into what information we receive and from whom.
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Other Sources
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Description
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Information categories
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Information from Advertising, marketing, and measurement
partners
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We receive inferences from certain advertising or
marketing partners. These inferences are the partners’ understanding of your
interests and preferences. We may also receive information such as your
device or mobile identifiers and other cookie information.
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Technical Information
Usage Information
Inferred Information
Purchase & Payment Information
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Information from Payment and Transaction Fulfillment
Providers
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We receive information about you from payment and
transaction fulfillment providers, such as payment confirmation details, and
information about the delivery of products you have purchased through
shopping features, such as Paid Transfers.
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Technical Information
Payment & Purchase Information
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Information from Technical and Security Partners
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We collaborate with Technical and Security partners to
operate and secure our platforms. For example, We may look-up your
non-precise geolocation through IP-address lookup tooling.
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Any of the data described under:
Information we collect automatically
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Information from Third Party Platforms and (Integration)
Partners
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Third party platforms provide us with information (such as
your email address, user ID, and public profile, User Content) when you
decide to sign up for or login to our Services by using their login services.
We could also receive this information when you decide to connect or
integrate a third-party service or app with our Services. This could allow
you to import your data or files from a third-party service to our Services.
Furthermore, we may receive such information when you
decide to sign-up via a promotion we offer in collaboration with the third
party. For instance, when you participate in a student promotion
campaign.
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Any of the data described under:
Information you provide
Information we collect automatically
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Information from Others, including Law Enforcement.
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We may receive information about you from others, for
example, where you are included or mentioned in User Content, in a complaint,
appeal, request or feedback submitted by a user or third party, including law
enforcement agency, or if your contact information is provided to us by
another user.
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Any of the data mentioned under:
Information you provide
Information we collect automatically
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Acquired Companies
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In case of mergers or acquisitions, we may receive any of
the aforementioned information.
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Any of the data mentioned under:
Information you provide
Information we collect automatically
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How we use your Information, and our legal bases for
using it
This section describes why and how we collect, process, and
share your personal information. We provide a description of each reason or
“purpose”. We also describe on which legal bases we rely to justify the
processing of your information. Each reason or purpose is linked to a legal
basis as well as to one or more of the information categories described in the
previous section.
- Here’s a brief overview of the different legal bases the GDPR provides:
Performance
of our Contract with You: When you use our Services, you're entering into
an agreement with us (our Terms of Services). We use your information to
deliver our services, support you, and make our platform function
effectively for you.
Legitimate
Interests: We sometimes use your information in ways that are beneficial
for both of us. This could include things like improving our software,
preventing fraud, and marketing activities. We always balance our
interests with your rights and won't use your information if it overly
infringes on your privacy.
Consent:
in certain situations we might ask you for consent (opt-in) to process
your information. When we do, we’ll make it very clear what it is we’re
asking consent for. You’ll always have the right to withdraw your consent
at any moment.
To
fulfill our Legal Obligations: Just like any other company, we're bound by
laws and regulations. Sometimes, we have to use your personal information
to comply with these legal requirements.
To
protect the Vital Interests of Others: On rare occasions, we might use or
share your information to protect someone's life or to handle emergency
situations.
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Purpose for processing your information
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Legal Basis
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Information categories
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Provide and administer our Services to you, such as
allowing you to:
upload, create or distribute User Content;
sign-up for an account and login;
subscribe to and pay for our Services.
We also send you Service emails and messages. For example,
when your Transfer has been downloaded, or that your client has commented on
your Review.
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Performance of a contract
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
As it relates to offering you our Services under our
Terms.
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Provide our distribution and payment collection features
as well as to facilitate & process orders. This includes sharing Purchase
Information with Uploaders, Payment and Transaction Fulfillment Providers,
and Service Providers.
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Performance of a contract insofar you are bound by our
Terms.
Legitimate interests, such as:
Facilitating the sale and purchase of User Content. This
includes payment collection.
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Any of the data described under:
Information you provide
Information we collect automatically, in particular
Payment & Purchase Information.
Information we receive from Other sources
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Offer additional core elements of our Services, such as
sending recipients an email with a link to download or review User Content;
or when you integrate our Services with third-party services.
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Legitimate interests, such as:
Keeping our Services running; and
Allowing people to access and use our Services.
Facilitating the connection and integration with
third-party services on your request and with your permission.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Serve and measure the effectiveness of both non-personalised
and personalised advertisements on both our Services and third-party
services. This includes serving you ads from our advertising clients as well
as OnlyLockbox on our Services and measuring them to understand the
effectiveness. It also includes OnlyLockbox’s own marketing and advertising
activities on third-party services, such as social media platforms.
In case of non-personalised advertisements, we use very
limited information to serve you the ads, such as your non-precise
geolocation (typically country) and your browser language.
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When offering non-personalised ads: Legitimate Interests,
such as:
Being able to offer a Free version of our Services
When offering personalised ads, and where required by law:
Consent.
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Non-personal ads
Geolocation (based on IP-address)
Browser language
Personalised ads
Any of the data described under:
Information you provide (but not User Content)
Information we collect automatically
Information we receive from Other sources
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Review our Services and user base to inform the planning,
improvement, and development of our Services (including advertising), our
business activities (including marketing), and our technology.
For instance, we monitor and analyse how users are using
and interacting with the Services, each other, and across their devices. This
helps us with gaining an understanding of:
how our Services, including new features, are being used,
how we might further develop our Services,
what type of people or entities our user base exists of,
and
which type of potential users to focus on in our marketing
& advertising activities - both on our Services and on third-party
services, such as social media platforms. This purpose relates to broad user
segments, and not individual targeting.
In certain cases, and where allowed by law, we could
receive Information from third-parties to help improve the understanding of
our user base.
Moreover, we train and improve our software and
technology, such as our machine learning models and algorithms.
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Legitimate interests, such as:
Developing & improving our Services
Enhancing user experience
Making informed strategic and business decisions
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Conduct surveys and research. We might ask you for
feedback about our Services or about features that are in development. In
some cases, we might ask you to participate in lengthier research, including
as part of a panel or an Early Access Program (EAP). We might also conduct
independent research to gain further user insights.
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Legitimate interests, such as:
Understanding how our users and others think of our
Services
Making informed strategic and business decisions
Where required, we sometimes also ask for your
Consent.
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Information you provide
Information we collect automatically
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Enforce our Terms, guidelines, and policies. We use your
information to enforce our Terms and policies. If we determine that you’ve
violated our Terms, we could remove your content or suspend your account.
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Performance of a contract
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Any of the data described under:
Information you provide, in particular User Content
Information we collect automatically
Information we receive from Other sources
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Maintain and enhance the safety, integrity, security, and
stability of our Services as well as to protect (the rights of) and serve the
safety and wellbeing of our users, our community, and third parties.
For instance, we implement security measures, perform
diagnostics, troubleshoot and fix issues with the Services.
We also use automated means as well as human moderation to
investigate, detect, and act against (suspicions of) illegal or unwanted
activity or User Content. Examples include of illegal activity or content,
but are not limited to, Child Sexual Abuse Material (CSAM), malware, fraud,
and copyright infringement.
Next to automated means, we rely on reports of users and
third parties to become aware of suspicious or illegal content and
activity.
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Legitimate interests, such as:
Ensure ongoing security, stability, and availability of
our Services
Ensure the safety of our Users and community
Protect the rights & reputation of OnlyLockbox and
others.
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Any of the data described under:
Information you provide, including User Content
Information we collect automatically
Information we receive from Other sources
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Communicate and Promote OnlyLockbox, our Services, our
events & promotions both on- and off-OnlyLockbox.
We may send you direct marketing messages, including
email, about OnlyLockbox, features of the Services, and third-party services.
We may also send or offer you promotions, contests, or marketing campaigns or
event information.
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Legitimate interests, such as:
Direct marketing
Consent, where required by law. For instance, when we send
you email marketing.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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To establish, exercise, or defend legal claims. In case of
negotiations, disputes, or (potential) litigation we may need to process your
information or possibly share it with our lawyers.
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Legitimate interests, such as:
Defending ourselves, our users, or others in specific
legal matters
Seeking legal advice
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Comply with legal obligations As a business we are
sometimes obliged to process your information in relation to laws, such as:
Dutch law (as our headquarters are based in The
Netherlands), including civil law, tax laws, law enforcement laws
EU law, including laws regarding consumer protection, law
enforcement, illegal content, hosting services.
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Complying with Legal Obligations
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Share your information with others
There are limited instances in which we will share your
information with others. These are described in more detail in section “How
& when we share your information with others”, but here’s a brief
overview: You might request us to share the information, for instance, when
you integrate our Services with another third–party service of your choice.
In certain cases we might need to share your information with law
enforcement, public authorities, or other third-parties. For example, when we
have a legal obligation to do so, when there are valid legal grounds for
further investigation, or when there’s an emergency or life-threatening
situation.
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Complying with Legal obligations, such as:
EU laws, such as the EU Digital Services Act
Dutch law (as our headquarters are based in The
Netherlands)
Legitimate Interests, such as:
Complying with regulatory requests, court orders, search
warrants, or subpoenas when not specifically dictated by applicable law
Complying with laws from countries where our local
entities reside, such as France, The UK, and the USA.
Laws from the country you reside in
Following case law related to the disclosure of user
information. For instance, in relation to illegal content
Vital interests of an individual (emergency or
life-threatening situation)
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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How & when we share your information with others
There are limited instances in which we will share your
information with others. This section describes with whom we might share your
personal information, why, and which categories of information.
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Categories of recipients
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Reason(s) for sharing
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Information categories
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Service Providers These could be parties that provide
services, such as cloud hosting, content delivery, security, survey &
research, and customer support.
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We have to rely on service providers to offer our Services
to you, and to ensure that our Services remain secure. Our employees also use
a wide variety of tools of Service providers to conduct planning, research,
and execution of projects.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
As it relates to offering you our Services under our
Terms.
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Advertising Partners, including our Advertising Clients
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We share your information to deliver our advertisements to
you. We also share aggregated information with our advertising partners to
measure the effectiveness of our advertising services.
In case we have your permission, we might also share
certain personal information to deliver more relevant
advertising.
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Your hashed email address
Technical information
Usage information
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Marketing Partners Examples are partners that promote OnlyLockbox,
or platforms, apps, websites that allow OnlyLockbox to advertise its Services
to you.
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We do this to promote through communication and
advertisements OnlyLockbox, our Services, and other activities, events
or campaigns we host. These partners also enable us to allow you to sign-up
for events and campaigns. Moreover, we measure the effectiveness of our
marketing activities and campaigns.
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User Information
Information related to Communication, Surveys, Events
Technical Information
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Payment & Transaction Fulfillment Platforms
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We share the information related to the transaction with
payment and transaction fulfilment providers, and other service providers,
when you make a purchase or collect a payment on our Services. This could be
when you pay for a subscription or when you pay for User Content from another
user; or when you request a payment before enabling a download. We share this
information so they can fulfill the order, and in some cases for security
reasons.
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User Information
Technical Information
Payment & Purchase Information
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Law enforcement and other authorities, or other parties to
legal review or litigation
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We may access, preserve, and share your information,
including User Content, with law enforcement agencies, public authorities, IP
rights holders, or other third parties if we have good faith belief that it
is necessary to:
comply with applicable law, legal process, search warrant,
subpoena or government requests,
protect the rights, property, and safety of our users,
copyright holders, and others, including to protect life or prevent imminent
bodily harm
detect, investigate, prevent, or address unwanted
activity, copyright infringement, or other illegal activity.
investigate (suspicions of) violations of our Terms,
Guidelines, or Policies - as well as to enforce them; or
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Other users
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You may choose to interact with other users by sharing
files or reviews with them; or by downloading or purchasing their User
Content. In these instances, we could (have to) share or display some of your
personal information with them to ensure that our Services work
properly.
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User Information
User Content
Payment & Purchase information
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Other OnlyLockbox companies, or companies we acquire
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As a global company we have entities and colleagues in
several countries around the world. These entities -and the colleagues who
work there- may process your information for us. For instance, to review,
develop & improve features, for security and content moderation, for
analytics, technical & customer support.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Parties in relation to Corporate Transactions
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Your information may be disclosed to third parties in
connection with a corporate transaction, such as a merger, sale of assets or
shares, reorganisation, financing, change of control, or acquisition of all
or a portion of our business.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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How & when we share your information with others
There are limited instances in which we will share your
information with others. This section describes with whom we might share your
personal information, why, and which categories of information.
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Categories of recipients
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Reason(s) for sharing
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Information categories
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Service Providers These could be parties that
provide services, such as cloud hosting, content delivery, security, survey
& research, and customer support.
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We have to rely on service providers to offer our Services
to you, and to ensure that our Services remain secure. Our employees also use
a wide variety of tools of Service providers to conduct planning, research,
and execution of projects.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
As it relates to offering you our Services under our
Terms.
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Advertising Partners, including our Advertising Clients
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We share your information to deliver our advertisements to
you. We also share aggregated information with our advertising partners to
measure the effectiveness of our advertising services.
In case we have your permission, we might also share
certain personal information to deliver more relevant
advertising.
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Your hashed email address
Technical information
Usage information
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Marketing Partners Examples are partners that
promote OnlyLockbox, or platforms, apps, websites that allow OnlyLockbox to
advertise its Services to you.
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We do this to promote through communication and
advertisements OnlyLockbox, our Services, and other activities, events or
campaigns we host. These partners also enable us to allow you to sign-up for
events and campaigns. Moreover, we measure the effectiveness of our marketing
activities and campaigns.
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User Information
Information related to Communication, Surveys, Events
Technical Information
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Payment & Transaction Fulfillment Platforms
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We share the information related to the transaction with
payment and transaction fulfilment providers, and other service providers,
when you make a purchase or collect a payment on our Services. This could be
when you pay for a subscription or when you pay for User Content from another
user; or when you request a payment before enabling a download. We share this
information so they can fulfill the order, and in some cases for security
reasons.
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User Information
Technical Information
Payment & Purchase Information
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Law enforcement and other authorities, or other parties
to legal review or litigation
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We may access, preserve, and share your information,
including User Content, with law enforcement agencies, public
authorities, IP rights holders, or other third parties if we have good faith
belief that it is necessary to:
comply with applicable law, legal process, search warrant,
subpoena or government requests,
protect the rights, property, and safety of our users,
copyright holders, and others, including to protect life or prevent imminent
bodily harm
detect, investigate, prevent, or address unwanted
activity, copyright infringement, or other illegal activity.
investigate (suspicions of) violations of our Terms,
Guidelines, or Policies - as well as to enforce them; or
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Other users
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You may choose to interact with other users by sharing
files or reviews with them; or by downloading or purchasing their User
Content. In these instances, we could (have to) share or display some of your
personal information with them to ensure that our Services work
properly.
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User Information
User Content
Payment & Purchase information
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Other OnlyLockbox companies, or companies we acquire
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As a global company we have entities and colleagues in
several countries around the world. These entities -and the colleagues who
work there- may process your information for us. For instance, to review,
develop & improve features, for security and content moderation, for
analytics, technical & customer support.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Parties in relation to Corporate Transactions
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Your information may be disclosed to third parties in
connection with a corporate transaction, such as a merger, sale of assets or
shares, reorganisation, financing, change of control, or acquisition of all
or a portion of our business.
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Any of the data described under:
Information you provide
Information we collect automatically
Information we receive from Other sources
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Why and how are cookies used?
We place cookies with the intention of making OnlyLockbox
even better. We work hard to make our Services safe, beautiful and unobtrusive.
Feel free to block cookies, but this may affect how well our Services work.
We place several cookies (or similar technologies, like
pixels or web beacons) on your device for the purpose of facilitating your use
of the Service and to find out how the Service may be improved. We or our
advertising partners also place cookies on our website(s). Being a global
service, these partners can vary per country. When our advertising partners
place cookies, these cookies can process personal information to measure the
effectiveness of the campaign.
Cookies are small text files that are stored on your
computer by your browser when you visit a website. Examples of cookie purposes
are: your language preferences, logging into an account, remembering login
details, serving you personalised advertisements and acceptance of the Terms of
Service and Privacy & Cookie Statement. Our website can place these cookies
for the following purposes:
Functional cookies
are used to provide functionalities when using our Service, such as the
possibility to set preferences or to remember your previous settings.
Analytical cookies
are used to optimise our Service. For example to optimise the usability of our
website by AB-testing a new feature, to make the website more user-friendly and
to analyse how you use our Service. We also use analytical cookies to stop bots
and malicious behaviour like spam. When we use analytical cookies, this could
include third party cookies, as found in the cookie list. These third party
analytical cookies process personal information, which is detailed in the
cookie list too.
Advertisement
cookies are used for commercial, editorial and promotional purposes. With these
cookies your internet- and surf behaviour can be followed over various domains
and websites. OnlyLockbox only checks the (one) website you visited prior to
your visit to one of our websites. We do not track the website you visit after
you leave our website. Advertisement cookies are often also placed by third
parties to measure the effectiveness of their advertising campaigns and to
follow your internet- and surf behaviour over other domains and websites where
they have placed a cookie. OnlyLockbox does not have access to or control over
personal information collected via these cookies or other features that
advertisers and third parties may use. Our Privacy & Cookie Statement is
therefore not applicable to these third party cookies and we refer you to third
parties’ Privacy Statements to read how they handle personal information. You
can find a list of the limited amount of third party cookies and a link to
their privacy policies here.
Pixel tags or web
beacons are a piece of code embedded on the website that collects personal
information about users' engagement on that web page. The use of a pixel allows
us to record, for example, that a user has visited a particular web page or
clicked on a particular advertisement. The pixel also allows us to see from
which previous website or channel a user arrived at our website.
We have an extensive cookie list available here, which we
will update at least four times a year. Due to the changing nature of our
Service, this may result in the cookie list not being fully up to date at
times. If you would want to remove certain cookies, or block them from being
stored in your browser, it is possible to arrange this through your browser
settings for cookies. You can find these settings under the Privacy tab in the
Preferences section of most browsers. Here you can specify your cookie preferences
or remove cookies. Please note that if you remove or refuse OnlyLockbox
cookies, the Service might not function in optimal form.
How we operate as a global business
All Personal Information, including User Content, that is
uploaded within EMEA, US & Canada (including the United Kingdom) is in
principle hosted on servers in Germany on Contabo datacentres.
We are a business with a global footprint. Therefore we work
together with KTG entities and partners outside the European Economic Area
(“EEA”). This means that we might share or store certain personal information
with them.
Those entities and partners may reside in countries which
have different data protection laws in place - and, in some cases these offer
less protection to your information. To ensure that you and your personal
information enjoy a similar level of protection as under the EU GDPR, we will
make sure that appropriate safeguards are in place, such as technical, legal,
and organizational measures. Examples are pseudonymisation, encryption, and
policies to challenge disproportionate legal access by governments.
When sharing personal information with other OnlyLockbox
entities, or with third parties, such as service providers and marketing
partners, who are located outside the EEA, we ensure that either:
- The European Commission has issued a so-called “Adequacy Decision” regarding the country where the OnlyLockbox entity or third-party is located. This is the case for:
- our subsidiary as well as third-parties based in the UK,
- third parties based in Canada, Israel, and Switzerland, and
- certain third parties based in the USA who have certified themselves under the EU-US Data Privacy Framework. When this is the case, we conduct a review to ascertain whether their certification is still active.
- We have signed special contracts, called “Standard Contractual Clauses”, with the OnlyLockbox entity or third-party. These clauses require the other party to protect your information and to provide you with EU-level rights and protections. You can exercise your rights under the Standard Contractual Clauses by contacting us or the third party who processes your personal information
Our OnlyLockbox entities commit to processing information in
compliance with OnlyLockbox’s privacy policy and applicable privacy laws.
How we protect your personal information
OnlyLockbox takes technical and organisational measures to
protect your personal information against loss or other forms of unlawful
processing. We take these measures against industry standards and
certifications, such as ISO 27001.
We have policies and measures in place to pseudonymise,
encrypt, and anonymise personal information. Moreover, we have safeguards in
place to make personal information only accessible by those who need access to
do their job and that they are properly authorised. We monitor activity on our
servers and on company devices, such as laptops, to ensure the security and
safety of personal information.
OnlyLockbox staff is required to conduct themselves in a
manner consistent with the company’s guidelines regarding confidentiality,
ethics, and appropriate usage of personal information. Staff is required to
sign a confidentiality agreement and undergoes periodic security
training.
How long we keep your personal information
The retention period for your personal information depends
on which Service you use and it depends on which category of personal
information we’re talking about. Always check out the website(s) or app(s) of
the Service(s) for the specific information on retention periods.
Personal Information
OnlyLockbox retains your personal information as long as its
necessary to provide our Services to you (e.g. upholding your user account), to
conduct our business activities and fulfill our legitimate interests, such as
providing safe and secure services, to fix bugs and to reach out to you, to
comply with applicable laws (e.g. retaining financial information for 7 years
for tax purposes; or retaining personal information after receiving government
data preservation orders), to review, challenge, or comply with legal requests,
and to resolve (legal) disputes.
Where your User Content and/or Personal Information has been
reported, detected, blocked, or removed due to suspicious, infringing, or
illegal activity, we may keep limited information in relation to you and that
activity for a limited period of time. This is to:
- to help maintain and enhance the safety and security of our users, and our platform;
- to act on reports of harmful or illegal content or activity;
- to comply with our obligations under applicable law, such as the EU Digital Services Act.
User Content on File Transfer
When using OnlyLockbox File Sharing your Content will be
deleted after 3 days, unless you have a Paid subscription in which case you can
set and adjust the expiry date manually. After this period, a file is
automatically and permanently deleted from our servers.
User Content on Services other than File Transfer
The Content you create, use, store or share on our Services,
other than our File Sharing Service, is, in principle, retained until you stop
interacting with our Service(s), when you delete your Content from the
Service(s), when you delete the Service(s) from your device(s) or when you
delete your account. Always check out the website(s) or app(s) of the
Service(s) you use for specific information.
Your rights and choices
You have certain rights under GDPR, and similar privacy
laws. This section explains the different types of rights, how to exercise
them, and whether they may be subject to certain limitations. After receiving
your request, OnlyLockbox will respond within the time period limits provided
by the relevant law. In the EEA and UK, the time period is one month.
Access your information You have the right to receive
access to your personal information, including a copy thereof. You can request
this by reaching out to us.
Rectify your information If your Personal Information
has changed, or if you believe it’s incorrect, you have the right to correct
the Personal Information. If you have an account, you can adjust most of your
Personal Information via your account settings. Otherwise, you can
request us to rectify it for you.
Delete your information
You can request deletion of your Personal Information by
reaching out to us. In some of our products or apps it’s also possible to
delete your account via your account settings.
There are scenarios where we can't erase your personal
information, such as when:
- The data is still needed for the reason we gathered it.
- OnlyLockbox’s interest in using the information outweighs your wish for its deletion. This might be the case when we require the data to protect our services from fraudulent or illegal activities.
- OnlyLockbox has a legal obligation to retain the data, or
- OnlyLockbox requires the data to establish, exercise, or defend against legal action. For example, when there’s an unresolved matter linked to your account.
Port your information
In certain scenarios, you have the right to request a copy
of your personal data in electronic (“machine-readable”) format. You can
request us to transmit your data when we are processing your personal data on
the legal bases of consent or performance of contract. We will honor this
request to the extent possible.
Object to the processing of your information
When we process your personal information for the legitimate
interests of OnlyLockbox or a third party, you may object to the processing of
your personal information. You can either do this via “Your Privacy Choices” or
account settings, or by contacting us. When you contact us, we ask you to
provide all relevant information. This includes the processing activity you are
objecting to, why you want to object, how the processing activity affects you,
as well as any additional information that you think will help us review your
request. We will stop the particular processing if we don't have compelling
legitimate grounds to continue that processing and if we don’t need it for
legal claims.
Restrict the processing of your information
You can request us to (temporarily) restrict the processing
of your personal information. For instance, if (1) you believe your
personal data is inaccurate, or (2) when the processing is unlawful but you
oppose deletion of the data, or (3) you require the data to be retained in
relation to a legal claim or defense, or (4) you have objected to the
processing and are awaiting our response.
Lodge a complaint
If you’re unhappy with how we’ve handled your request or
your personal information, we encourage you to contact us.
Withdrawal of consent
When you’ve provided your consent for us to process your
personal information, you can withdraw your consent at any time, without
affecting the lawfulness of processing activities based on consent before its
withdrawal. If you withdraw your consent, we will no longer process the
personal information which we’ve received based on your consent. You can
withdraw your consent via “Your Privacy Choices” or by contacting us.
How to exercise your rights
To exercise any of the above rights, please contact us via [email protected].
Before we can respond to a request to exercise one or more of the rights listed
above, you may be required to verify your identity or your account details or
provide additional information so that we can understand your request.
Minors
OnlyLockbox’s Services are not directed towards minors. You
are only allowed to use our Services when aged 16 and over.
How to contact us
You can contact us about this privacy policy or other
related questions via l[email protected].
You can reach out to our Data Protection Officer via email [email protected].