Privacy Policy

We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the pCloud Transfer website located at https://transfer.pcloud.com (referred to as "Site").

pCloud Transfer is powered by pCloud and as such is operated by pCloud International AG, Switzerland (hereinafter referred to as "pCloud", "we", "us" and "our"). For the purposes of applicable European Union data protection legislation, we are the data controller.

Personal Data provided by you

When you create a transfer, you provide your email address and the email addresses of the recipients, you want to share files with. You can add an optional message to your file transfer.

Personal Data as you use our Site

We will collect information about you as you use the Site such as your IP address, browser type and version, operating system, referral source and device information.

Through tracking services, we will collect information about you such as length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service usage, operating system, device information, behavior, visited pages. This anonymous information can not be identified directly with you.

Other information we collect related to your use of our Sites or Services

We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law.

We may Process your Personal Data for a variety of reasons that are justified under data protection laws in the European Economic Area (EEA) and Switzerland.

To operate the Sites, including to:

• send files to the email contacts, provided by you;
• to notify you and the recipients of the transfer status;
• to identify you as the sender to the recipients

For our legitimate interests, including to:

• enforce the terms of our Site
• manage our everyday business needs, such as monitoring, analyzing;
• to manage our business needs, such as monitoring, analyzing, and improving the Site's performance and functionality.
• to manage risk and protect the Site and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Site.
• to comply with our obligations and to enforce the terms of our Site, including to comply with all applicable laws and regulations.

With your consent, including to:

• enforce the terms of our Site
• manage our everyday business needs, such as monitoring, analyzing;
• to manage our business needs, such as monitoring, analyzing, and improving the Site's performance and functionality.
• to manage risk and protect the Site and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Site.
• to comply with our obligations and to enforce the terms of our Site, including to comply with all applicable laws and regulations.

With your consent, including to:

• to market to you by delivering marketing materials about pCloud products and online Services. We may also Process your Personal Data to tailor certain Services or Site experiences to better match our understanding of your interests.
• to respond to your requests, for example to contact you about a question you submitted to our customer service team.

You can withdraw your consent at any time and free of charge. Let us know at privacy@pcloud.com

We may share your Personal Data or other information about you with others in a variety of ways as described in this of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

• with third party services monitoring the proper functioning of the service - Anonymous data and performance analytics to help us enhance Users' experiences.

We may share information about you with other parties for pCloud's business purposes or as permitted or required by law, including:

• if we need to do so to comply with a law, legal process or regulations;
• to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to pCloud;
• if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• to protect the vital interests of a person;
• to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of pCloud's business;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.

Profile Information You Make Available to Others:

• By using the Site or the Services you may make certain of your Personal Information available to others. For example, your email address will be visible when you share a file or a folder with another user of the Site or Services. You should therefore ensure that any person who you share a file or folder with is someone who you are happy to share your email address with.

With your consent:

• We share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
• We share your Personal Data with advertising and analytical companies to deliver information relevant to you about new features and offers.

In addition, pCloud may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services

We do not share your Personal Data with third parties for their marketing purposes.

We use the information about you and your usage of the service:

• to send you automated messages or notifications relevant to your user experience.
• to run usability and A/B tests to help us improve our service.

Please be aware that your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province or country. Please be advised that we process and store all information on secure servers in the United States and/or the European Union. This is necessary in order to process your Personal Information. The laws in the United States or the European Union may not be as protective of your privacy as those in your location. By using our Site or Services and submitting Personal Information via the Site, you agree to this collection, use, transfer, and disclosure of your Personal Information and that such collection, use, transfer, and disclosure shall be governed by applicable laws in the United States and the European Union.

We use cookies (a small text file placed on your computer to identify your computer and browser) on the Site. We use cookies to improve the experience of the Site and Services, such as pre-populating your username for easier login and preserving your user session. We do not use cookies to collect Personal Information. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. pCloud's cookies are automatically deleted after 1 year.

pCloud does not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

In this section, we have summarized the rights that you have under data protection law. For a more detailed explanation of your rights, please refer to the relevant laws and guidance from the regulatory authorities.

Note that filing multiple claims might be subject to a fee, not exceeding 10 GBP.

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.

In the unlikely event that a security breach which affects individuals' rights and freedoms is discovered, according to our risk assesment policy, pCloud will inform those individuals without undue delay.

The Site is intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

We keep this Privacy Policy under regular review and we will place any updates on this web page https://transfer.pcloud.com/privacy. This Privacy Policy was last updated on 23.05.2018.

In other circumstances, if we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will become effective on the revision date, shown in the revised Privacy Policy. Your continued use of our Site or Services constitutes your consent to the revised Privacy Policy.

You may contact us if you have general questions or concerns about this Privacy Policy and supplemental notices or the way in which we handle your Personal Data.

Our Data Protection Officer can be contacted at privacy@pcloud.com