Last Modified: October 24, 2019
This Privacy Policy describes CMV Technologies, LLC dba Flatter Files practices regarding the collection, use and disclosure of the information we collect from and about you when you use Flatter Files’ web, desktop and mobile applications and Flatter Files’ website (the “Services”). By accessing or using the Services, you agree to this Privacy Policy and our Terms of Service.
IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.
This Privacy Policy contains the following sections:
Flatter Files collects a variety of information that you provide directly to us. We process your information when necessary to provide you with the Services that you have requested when accepting our Terms of Service, or where we have obtained your prior consent, or where we have a legitimate interest to do so. For example, we may have a legitimate interest to process your information for security, testing, maintenance, and enhancement purposes of the Services we provide to you, or for analytics, research, and reporting purposes. Without your information, we cannot provide you with the Services you have requested or you may be limited in your use of the Services.
Flatter Files collects information from you through:
Information from and about you: The types of data we collect directly from you include name, address, telephone number and email address. Log-in details and password for your Flatter Files account will be collect and any email requests or questions you submit to us will be collected.
Content: In using the Services, you will upload or input various types of content, including but not limited to: files, tasks, attachments, project names, team names, and conversations (together, the “Content”). If you are using the Services in connection with an account created by an Flatter Files Customer (e.g., employer, organization, or an individual), we collect and process the Content you submit on behalf of the Customer. As described more throughout this Policy, our Customers, and not Flatter Files, determine their own policies regarding storage, access, modification, deletion, sharing, and retention of Content which may apply to your use of the Services. For example, a Customer may provide or remove access to the Services, enable or disable third party integrations, manage permissions, retention and export settings, transfer or assign teams, or share content. Please check with the Customer about the policies and settings that they have instituted with respect to the Content that you provide when using the Services.
Payment Information: If you purchase the services using a Credit Card, we utilize a third party credit card payment processing company to collect payment information, including your credit card number, billing address and phone number. The third party services provider, and not Flatter Files, stores your payment information on our behalf.
Information about others: If you choose to use our referral service to invite a contact to the Services, we will ask you for that person’s contact information, which will include their email address and automatically send an invitation. Flatter Files stores the information you provide to send the invitation, to register your contact if your invitation is accepted, and to track the success of our referral service.
When you use our Services that connect to the Internet, including, but not limited to, when you access the Services via our websites, your mobile devices, and Flatter Files software/applications, we automatically collect certain information as described in this Section. As discussed further below, we and our service providers (which are third party companies that work on our behalf to provide and enhance the Services) use a variety of technologies, including cookies and similar tools, to assist in collecting this information.
Log Files: When you use the Services, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (“IP”) address, browser type and settings, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, metadata associated with uploaded Content, domain names, landing pages, pages viewed, mobile carrier, date and time stamp information and other such information.
Device Identifiers: When you access the Services using a mobile device, we collect specific device information, including your MAC address and other unique device identifiers. We also collect information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your account and will use data associated with your device identifier to customize our Services to your device and to analyze any device-related issues.
Location Information: We collect and process general information about the location of the device from which you are accessing the Services (e.g., approximate geographic location inferred from an IP address).
If you choose to use third-party integrations (e.g., Office 365, G Suite) through the Services or are required to do so by a Customer, such providers may allow us and our service providers to have access to and store additional information about your interaction with those services and platforms as it related to use of the Services. If you do not wish to have this information shared, do not initiate these connections.
Sometimes, we may use the information we collect — for instance, usernames, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Services. If you wish to opt out of our ability to track you across devices, you may install the Google Analytics Opt-out Browser Add-on.
To collect the information in the “Information We Automatically Collect” section above, we and our service providers use Internet server logs, cookies, tags, SDKs, tracking pixels, and other similar tracking technologies. A web server log is a file where website activity is stored. An SDK is a section of code that we embed in our applications and software to allow third parties to collect information about how users interact with the Services. A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer and login session; (ii) store your preferences and settings; (iii) understand which web pages of the Services you have visited; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform analytics; and (vi) assist with security and administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email, and that are designed to provide usage information like ad impressions or clicks, email open rates, measure popularity of the Services and associated advertising, and to access user cookies. As we adopt additional technologies, we may also gather information through other methods.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).
We use your information (including any information that we collect, as described in this Privacy Policy) for various purposes depending on the types of information we have collected from and about you and the specific Flatter Files Service you use, including to:
Content: You can exercise certain control how your Content is used by/shared with others via your settings on the Services. Flatter Files may view and share your Content only as necessary (i) to maintain, provide and improve the Service; (ii) prevent or address technical or security issues and resolve support requests; (iii) if we have a good faith belief, or have received a complaint alleging, that such Content is in violation of our Terms of Service; (iv) as reasonably necessary to allow Flatter Files to comply with or avoid the violation of applicable law or regulation; (v) to comply with a valid legal subpoena, request, or other lawful process that meets the requirements of our Law Enforcement Guidelines; and (vi) as set forth in our Terms of Service with the Customer or as expressly permitted in writing by the Customer. We may also analyze your User Content in aggregate and on an anonymized basis, in order to better understand the manner in which our Service is being used.
Combined Information: You consent that, for the purposes discussed in this Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.
Flatter Files will share your information in the following ways:
Subprocessors: As part of the services we provide, and only to the extent necessary, we may use certain third party processors to process some or all of your personal information. For identification of these processors, and where they are located, please see our Subprocessor listing). We have signed appropriate data processing contracts that comply with GDPR with each processor.
In the context of an onward transfer Flatter Files has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. Flatter Files shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
Third-Party Integrations: When you initiate a connection with a third-party integration through the Services (e.g., Office 365, G Suite), we will share information about you that is required to enable your use of the third-party integration through the Services.
Business Transfers: If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the Services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you. If such transfer is subject to additional mandatory restrictions under applicable laws, Flatter Files will comply with such restrictions.
We provide you with a number of choices with respect to the information we collect and use as discussed throughout this Privacy Policy. For example: - You may instruct us not to use your contact information to contact you by email, postal mail or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us – see the Flatter Files Contact Info section below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational or service-related emails, such as those reflecting our relationship or transactions with you. - Through your account interface, you may opt-out of receiving categories of Services-related notices that are not deemed by Flatter Files to be integral to your use of the Services. - When you use the Services you will have certain choices regarding how to control access to your content.
The Services contain links to third-party websites such as social media sites, and also contain third-party integrations. If you choose to use these sites or integrations, you may disclose your information not just to those third-parties, but also to their users and the public more generally depending on how their services function. Because these third-party websites and services are not operated by Flatter Files, Flatter Files is not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and other information will be subject to the privacy policies of the third party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third-parties.
The Services are intended for general audiences and not for children under the age of 13. If we become aware that we have collected personal information (as defined by the Children’s Online Privacy Protection Act) from children under the age of 13, we will take reasonable steps to delete it as soon as practicable.
Flatter Files complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Flatter Files has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.
In compliance with the Privacy Shield Principles, Flatter Files commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Flatter Files at support@flatterfiles.com.
Flatter Files has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
Flatter Files is also subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Under some circumstances, individuals may invoke binding arbitration to resolve disputes.
We will retain your information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law.
We reserve the right to amend this Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. We will make the revised Policy accessible through the Services, so you should review the Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice and we will seek your consent to the updated Policy in accordance with legal requirements.
Flatter Files takes technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure, and thus we cannot ensure or warrant the security of that information. If you have any questions about security on our Services, you can contact us at support@flatterfiles.com.
All users can access collected information on Flatter Files via the application itself. Additional information not made available directly on Flatter Files can be requested and will be provided in a timely fashion.
If any personal information is shown to be inaccurate users can correct the information via the application or by contacting Flatter Files directly.
If you wish to contact us or have any questions about or complaints in relation to this Privacy Policy, please contact us at support@flatterfiles.com. The mailing address for Flatter Files is PO Box 2965, Fayetteville, AR 72702.