Privacy & Cookie Statement
20240301_rev01 · COMPARED WITH 20240117_rev01 · ARCHIVE SNAPSHOT, DATE APPROXIMATE
Full text changes — 20240117_rev01 to 20240301_rev01
| 1 | 1 | - [Terms of Service](https://wetransfer.com/explore/legal/terms) |
| 2 | 2 | - [Privacy & Cookie Statement](https://wetransfer.com/explore/legal/privacy) |
| 3 | 3 | - [Your Privacy Choices](https://wetransfer.com/explore/legal/manage-cookies) |
| 4 | 4 | - [Notice and Takedown Policy](https://wetransfer.com/explore/legal/takedown) |
| 5 | 5 | - [Responsible Disclosure](https://wetransfer.com/explore/legal/disclosure) |
| 6 | - [Content Moderation Policy](https://wetransfer.com/explore/legal/content-moderation-policy) | |
| 6 | 7 | - [Advertising Terms & Conditions](https://wetransfer.com/explore/legal/advertising) |
| 7 | 8 | |
| 8 | Version: 14.7.2021 - [Download PDF](https://wetransfer.com/documents/WeTransfer_Website_Privacy_Cookie_statement_ENG_July_2021.pdf) | |
| 9 | ### Introduction | |
| 9 | 10 | |
| 10 | Since day one, WeTransfer has cared about privacy and respecting our users. Protecting the data of our users is of the highest importance to us, and we go to great lengths to make sure we keep it safe. | |
| 11 | This Policy covers the processing activities of the WeTransfer 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. | |
| 11 | 12 | |
| 12 | We take your trust and right to privacy seriously and work continuously to keep your digital footprint small and in your control. Nevertheless, to enable you in your flow and to improve and secure our service, we need to process some personal information. For privacy-related questions, please reach out to our Data Protection Officer via [dpo@wetransfer.com](mailto:dpo@wetransfer.com). | |
| 13 | WeTransfer B.V. (a company vested in The Netherlands) is the data controller of your personal information. | |
| 13 | 14 | |
| 14 | This statement covers the processing activities of the WeTransfer services, software, websites (including browser extensions) and/or applications (together: "Services"). The Services allow you to create, share, collect, capture and/or visualize your ideas, texts, graphics, videos, data, information, files, decks or other content (together: "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 and Cookie Statement as below. | |
| 15 | If you have any questions, or complaints, or if you want to exercise your privacy rights: please contact [legal@wetransfer.com](mailto:legal@wetransfer.com). | |
| 15 | 16 | |
| 16 | To make sure this Statement is easy to read, each question has a drop down with a short explanation, followed by a more formal statement. | |
| 17 | ||
| 18 | 17 | - What information do we collect? |
| 19 | 18 | |
| 20 | We store some personal information to make your use of our Services possible. There are several ways in which we may collect personal information from you: you may submit it or we will collect it automatically through our Services. Different types of personal information may be collected depending on the way you use our Services and which Services you use. Please check the section "What are your rights as a user" to find out how you can change, access or delete your personal information. | |
| 19 | We collect information in three ways: | |
| 21 | 20 | |
| 22 | **Personal information you submit** | |
| 21 | - Information you provide | |
| 23 | 22 | |
| 24 | WeTransfer collects, processes or hosts personal information you provide. | |
| 23 | - Information we collect automatically | |
| 25 | 24 | |
| 26 | 1. **Contact information**: your name and your email address or the email address of the recipient(s). | |
| 25 | - Information we receive from other sources | |
| 27 | 26 | |
| 28 | 2. **Information about yourself**: age, gender, city. | |
| 27 | Different types of personal information may be collected depending on the way you use our Services as well as on which Services you use. | |
| 29 | 28 | |
| 30 | 3. **Preferences**: for example language settings or interests. | |
| 29 | ### Information you provide | |
| 31 | 30 | |
| 32 | 4. **Content and metadata**: you may choose to upload or create Content which contains all sorts of personal information about you and others. Such Content also contains a filename, size and filetype. | |
| 31 | 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. | |
| 33 | 32 | |
| 34 | 5. **Personal messages**: the ones you send to people along with sharing your files. | |
| 33 | <table><tbody><tr><td><p><b>Category</b></p></td><td><p><b>Description</b></p></td></tr><tr><td><p>User information </p></td><td><p>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. </p><p>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. </p></td></tr><tr><td><p>User Content</p></td><td><p>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.</p></td></tr><tr><td><p>User Contacts</p></td><td><p>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. </p></td></tr><tr><td><p>Information related to Communication, Surveys, Events</p></td><td><p>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. </p><p>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.</p></td></tr></tbody></table> | |
| 35 | 34 | |
| 36 | The uploader or creator(s) is responsible for the legitimacy of the Content and needs to follow our [Terms of Service](https://wetransfer.com/legal/terms), WeTransfer only processes it to provide its Services. If you upload, send or create personal information via one of our Services, you may ask for a Data Processing Agreement by sending an email to [legal@wetransfer.com](mailto:legal@wetransfer.com). | |
| 35 | ### Information we collect automatically when you use our Services | |
| 37 | 36 | |
| 38 | **Personal information we collect by automated means** | |
| 37 | <table><tbody><tr><td><p><b>Category</b></p></td><td><p><b>Description</b></p></td></tr><tr><td><p>Technical Information</p></td><td><p><u>Technical information, including approximate location</u> 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. </p><p><u>Cookie information </u>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. </p></td></tr><tr><td><p>Usage Information</p></td><td><p>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.</p></td></tr><tr><td><p>Inferred information </p></td><td><p>We infer information such as attributes (e.g. age-range) and interests based on your data.</p></td></tr><tr><td><p>Payment & Purchase Information</p></td><td><p>When you make purchases or payments on our Services, we collect information such as purchased items, transaction information, transaction ID, product details, and price.</p></td></tr></tbody></table> | |
| 39 | 38 | |
| 40 | WeTransfer also collects and uses personal information by automated means while you use our Services. | |
| 39 | ### Information we receive from Other Sources | |
| 41 | 40 | |
| 42 | 1. **Browser information**: type of browser, language settings, country and timezone. | |
| 41 | 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. | |
| 43 | 42 | |
| 44 | 2. **Cookie or web beacon information**: cookie IDs and settings and other personal information received through cookies, web beacons or pixel tags. Learn more about under section "Why and how are cookies used". | |
| 43 | <table><tbody><tr><td><p><b>Other Sources</b></p></td><td><p><b>Description </b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p>Information from Advertising, marketing, and measurement partners</p></td><td><p>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. </p></td><td><p>Technical Information</p><p>Usage Information</p><p>Inferred Information</p><p>Purchase & Payment Information</p></td></tr><tr><td><p>Information from Payment and Transaction Fulfillment Providers</p></td><td><p>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. </p></td><td><p>Technical Information</p><p>Payment & Purchase Information</p></td></tr><tr><td><p>Information from Technical and Security Partners</p></td><td><p>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.</p></td><td><p>Any of the data described under:</p><p>Information we collect automatically</p></td></tr><tr><td><p>Information from Third Party Platforms and (Integration) Partners</p></td><td><p>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.</p><p>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. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p></td></tr><tr><td><p>Information from Others, including Law Enforcement. </p></td><td><p>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. </p></td><td><p>Any of the data mentioned under:</p><p>Information you provide</p><p>Information we collect automatically</p></td></tr><tr><td><p>Acquired Companies</p></td><td><p>In case of mergers or acquisitions, we may receive any of the aforementioned information. </p></td><td><p>Any of the data mentioned under:</p><p>Information you provide</p><p>Information we collect automatically</p></td></tr></tbody></table> | |
| 45 | 44 | |
| 46 | 3. **Device information**: the type of device, hardware model and operating system. | |
| 45 | - How we use your Information, and our legal bases for using it | |
| 47 | 46 | |
| 48 | 4. **Identification details**: unique identifiers such as an IDFA (for iOS), MAC address or a UserID. | |
| 47 | 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. | |
| 49 | 48 | |
| 50 | 5. **Network information**: IP-addresses and mobile network information. | |
| 49 | Here's a brief overview of the different legal bases the GDPR provides: | |
| 51 | 50 | |
| 52 | 6. **Location data**: data on your geo-location. If we use your device based, precise GPS-location, we will make sure we only do so after receiving your consent. | |
| 51 | - **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. | |
| 53 | 52 | |
| 54 | 7. **Service usage**: information regarding the way you interact with our Services, websites and mobile apps. | |
| 53 | - **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. | |
| 55 | 54 | |
| 56 | **Personal information we receive from partner** | |
| 55 | - **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. | |
| 57 | 56 | |
| 58 | In some cases we receive personal information from third parties, such as: | |
| 57 | - **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. | |
| 59 | 58 | |
| 60 | 1. **Integration information**: you can choose to integrate some of our Services with your (social media or messaging services) account, such as Slack, in order to provide you with a rich messaging functionality. | |
| 59 | - **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. | |
| 61 | 60 | |
| 62 | 2. **Marketing information**: some partners may provide additional (aggregated) information, for instance through their Software Developer Kits (SDKs). This may contain demographic or behavioural information in order for us to personalize content, advertisements and offers and to find the right audience for our advertisements. | |
| 61 | <table><tbody><tr><td><p><b>Purpose for processing your information</b></p></td><td><p><b>Legal Basis</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Provide and administer our Services to you</b>, such as allowing you to:</p><p>upload, create or distribute User Content;</p><p>sign-up for an account and login;</p><p>subscribe to and pay for our Services.</p><p>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. </p></td><td><p>Performance of a contract </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Provide our distribution and payment collection features as well as to facilitate & process orders.</b> This includes sharing Purchase Information with Uploaders, Payment and Transaction Fulfillment Providers, and Service Providers. </p></td><td><p>Performance of a contract insofar you are bound by our Terms. </p><p>Legitimate interests, such as:</p><p>Facilitating the sale and purchase of User Content. This includes payment collection. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically,<u> in particular Payment & Purchase Information.</u></p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Offer additional core elements of our Services</b>, 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.</p></td><td><p>Legitimate interests, such as:</p><p>Keeping our Services running; and</p><p>Allowing people to access and use our Services.</p><p>Facilitating the connection and integration with third-party services on your request and with your permission.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Serve and measure the effectiveness of both non-personalised and personalised advertisements on both our Services and third-party services. </b>This includes serving you ads from our advertising clients as well as WeTransfer on our Services and measuring them to understand the effectiveness. It also includes WeTransfer's own marketing and advertising activities on third-party services, such as social media platforms. </p><p>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. </p></td><td><p>When offering non-personalised ads: Legitimate Interests, such as:</p><p>Being able to offer a Free version of our Services</p><p>When offering personalised ads, and where required by law: Consent. </p></td><td><p><u>Non-personal ads</u></p><p>Geolocation (based on IP-address)</p><p>Browser language</p><p><u>Personalised ads</u></p><p>Any of the data described under:</p><p>Information you provide (<b>but not User Content)</b></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>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. </b></p><p>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:</p><p>how our Services, including new features, are being used,</p><p>how we might further develop our Services,</p><p>what type of people or entities our user base exists of, and</p><p>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. </p><p>In certain cases, and where allowed by law, we could receive Information from third-parties to help improve the understanding of our user base. </p><p>Moreover, we train and improve our software and technology, such as our machine learning models and algorithms. </p></td><td><p>Legitimate interests, such as:</p><p>Developing & improving our Services </p><p>Enhancing user experience</p><p>Making informed strategic and business decisions</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Conduct surveys and research</b>. 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.</p></td><td><p>Legitimate interests, such as:</p><p>Understanding how our users and others think of our Services</p><p>Making informed strategic and business decisions</p><p>Where required, we sometimes also ask for your Consent. </p></td><td><p>Information you provide</p><p>Information we collect automatically</p></td></tr><tr><td><p><b>Enforce our Terms, guidelines, and policies</b>. 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.</p></td><td><p>Performance of a contract</p></td><td><p>Any of the data described under:</p><p>Information you provide, in particular <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>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.</b></p><p>For instance, we implement security measures, perform diagnostics, troubleshoot and fix issues with the Services. </p><p>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. </p><p>Next to automated means, we rely on reports of users and third parties to become aware of suspicious or illegal content and activity. </p></td><td><p>Legitimate interests, such as:</p><p>Ensure ongoing security, stability, and availability of our Services</p><p>Ensure the safety of our Users and community</p><p>Protect the rights & reputation of WeTransfer and others.</p></td><td><p>Any of the data described under:</p><p>Information you provide, including <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Communicate and Promote WeTransfer, our Services, our events & promotions both on- and off-WeTransfer. </b></p><p>We may send you direct marketing messages, including email, about WeTransfer, features of the Services, and third party services. We may also send or offer you promotions, contests, or marketing campaigns or event information. </p></td><td><p>Legitimate interests, such as:</p><p>Direct marketing</p><p>Consent, where required by law. For instance, when we send you email marketing. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>To establish, exercise, or defend legal claims. </b>In case of negotiations, disputes, or (potential) litigation we may need to process your information or possibly share it with our lawyers. </p></td><td><p>Legitimate interests, such as: </p><p>Defending ourselves, our users, or others in specific legal matters</p><p>Seeking legal advice</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Comply with legal obligations </b>As a business we are sometimes obliged to process your information in relation to laws, such as:</p><p>Dutch law (as our headquarters are based in The Netherlands), including civil law, tax laws, law enforcement laws</p><p>EU law, including laws regarding consumer protection, law enforcement, illegal content, hosting services. </p></td><td><p>Complying with Legal Obligations</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Share your information with others</b></p><p>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.</p></td><td><p>Complying with Legal obligations, such as:</p><p>EU laws, such as the EU Digital Services Act</p><p>Dutch law (as our headquarters are based in The Netherlands)</p><p>Legitimate Interests, such as: </p><p>Complying with regulatory requests, court orders, search warrants, or subpoenas when not specifically dictated by applicable law</p><p>Complying with laws from countries where our local entities reside, such as France, The UK, and the USA. </p><p>Laws from the country you reside in </p><p>Following case law related to the disclosure of user information. For instance, in relation to illegal content</p><p>Vital interests of an individual (emergency or life-threatening situation)</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table> | |
| 63 | 62 | |
| 64 | 3. **Legal Information**: when law enforcement agencies or courts order us to take down Content, we may initially receive personal information about you and your behaviour. | |
| 63 | ## How & when we share your information with others | |
| 65 | 64 | |
| 66 | - Why do we use your personal information | |
| 65 | 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. | |
| 67 | 66 | |
| 68 | We use your personal information in order to provide and improve our Services, to comply with legal obligations and to advertise our Services and to keep our Services safe and secure. Please find below how we use your personal information specifically and on what legal grounds we base the use of your personal information. | |
| 67 | <table><tbody><tr><td><p><b>Categories of recipients</b></p></td><td><p><b>Reason(s) for sharing</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Service Providers</b> These could be parties that provide services, such as cloud hosting, content delivery, security, survey & research, and customer support. </p></td><td><p>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. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Advertising Partners, including our Advertising Clients</b></p></td><td><p>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. </p><p>In case we have your permission, we might also share certain personal information to deliver more relevant advertising. </p></td><td><p>Your hashed email address</p><p>Technical information</p><p>Usage information</p></td></tr><tr><td><p><b>Marketing Partners </b>Examples are partners that promote WeTransfer, or platforms, apps, websites that allow WeTransfer to advertise its Services to you. </p></td><td><p>We do this to promote through communication and advertisements WeTransfer, 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.</p></td><td><p>User Information</p><p>Information related to Communication, Surveys, Events</p><p>Technical Information</p></td></tr><tr><td><p><b>Payment & Transaction Fulfillment Platforms</b></p></td><td><p>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. </p></td><td><p>User Information</p><p>Technical Information</p><p>Payment & Purchase Information</p></td></tr><tr><td><p><b>Law enforcement and other authorities, or other parties to legal review or litigation</b></p></td><td><p>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: </p><p>comply with applicable law, legal process, search warrant, subpoena or government requests, </p><p>protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm</p><p>detect, investigate, prevent, or address unwanted activity, copyright infringement, or other illegal activity.</p><p>investigate (suspicions of) violations of our Terms, Guidelines, or Policies - as well as to enforce them; or </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Other users</b></p></td><td><p>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. </p></td><td><p>User Information</p><p>User Content</p><p>Payment & Purchase information </p></td></tr><tr><td><p><b>Other WeTransfer companies, or companies we acquire</b></p></td><td><p>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. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Parties in relation to Corporate Transactions</b></p></td><td><p>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.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table> | |
| 69 | 68 | |
| 70 | **Activities & purposes** | |
| 69 | - How & when we share your information with others | |
| 71 | 70 | |
| 72 | 1. **Service**: the most important reason for using your personal information is, of course, to offer you our Services as mentioned in our [Terms of Service](https://wetransfer.com/legal/terms), for example to create or visualize your Content or share your ideas and to let you access and use your Content across different devices. | |
| 71 | 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. | |
| 73 | 72 | |
| 74 | 2. **Support**: we provide a wide range of support services to help you out whenever you're in need, for instance when you need technical assistance. If it's needed to offer support, the Support-team can, on your request, access your Content in order to help you out. | |
| 73 | <table><tbody><tr><td><p><b>Categories of recipients</b></p></td><td><p><b>Reason(s) for sharing</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Service Providers</b> These could be parties that provide services, such as cloud hosting, content delivery, security, survey & research, and customer support. </p></td><td><p>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. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Advertising Partners, including our Advertising Clients</b></p></td><td><p>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. </p><p>In case we have your permission, we might also share certain personal information to deliver more relevant advertising. </p></td><td><p>Your hashed email address</p><p>Technical information</p><p>Usage information</p></td></tr><tr><td><p><b>Marketing Partners </b>Examples are partners that promote WeTransfer, or platforms, apps, websites that allow WeTransfer to advertise its Services to you. </p></td><td><p>We do this to promote through communication and advertisements WeTransfer, 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.</p></td><td><p>User Information</p><p>Information related to Communication, Surveys, Events</p><p>Technical Information</p></td></tr><tr><td><p><b>Payment & Transaction Fulfillment Platforms</b></p></td><td><p>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. </p></td><td><p>User Information</p><p>Technical Information</p><p>Payment & Purchase Information</p></td></tr><tr><td><p><b>Law enforcement and other authorities, or other parties to legal review or litigation</b></p></td><td><p>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: </p><p>comply with applicable law, legal process, search warrant, subpoena or government requests, </p><p>protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm</p><p>detect, investigate, prevent, or address unwanted activity, copyright infringement, or other illegal activity.</p><p>investigate (suspicions of) violations of our Terms, Guidelines, or Policies - as well as to enforce them; or </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Other users</b></p></td><td><p>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. </p></td><td><p>User Information</p><p>User Content</p><p>Payment & Purchase information </p></td></tr><tr><td><p><b>Other WeTransfer companies, or companies we acquire</b></p></td><td><p>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. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Parties in relation to Corporate Transactions</b></p></td><td><p>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.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table> | |
| 75 | 74 | |
| 76 | 3. **Account & billing**: creating and upholding your personal account for example to facilitate your address book and to enable you to access your Content across different devices, facilitating payment of your subscription fee and perform accounting, auditing & billing activities. | |
| 75 | - Why and how are cookies used? | |
| 77 | 76 | |
| 78 | 4. **Safety, integrity & security**: WeTransfer follows up on abuse reports, NTD/DMCA reports, fraud investigations and could investigate your compliance with our of our [Terms of Services](https://wetransfer.com/legal/terms) and/or API Terms of Use. Furthermore, we detect & block Child Sexual Abuse Imagery (CSAI). Detection of CSAI leads to automated decisions whether such Content is potential CSAI. Cases of potential CSAI will be reported directly to law enforcement agencies. Furthermore, we protect ourselves against fraud and other illegal activities. In all these cases we withhold the right to preserve your Content and share it, together with other identifying information, with law enforcement agencies. Finally, we could use your personal information for internal control to safeguard our and your safety, integrity and security. For instance, in case of any suspicion of violations of our Terms of Services or the API Terms of Use. | |
| 77 | We place cookies with the intention of making WeTransfer 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. | |
| 79 | 78 | |
| 80 | 5. **Improvement & development**: we evaluate the use of our Services to improve our Services, fix bugs, develop new products and services. We do this either by market research (for instance by sending out surveys) or by performing analyses (for example by tracking and bringing together your personal information across our Services or across your mobile devices). We do this in order to understand how our user base as a whole interacts with our Services, but also to review the effect of our advertisements and to improve those Services and advertisements accordingly. | |
| 79 | 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. | |
| 81 | 80 | |
| 82 | 6. **Marketing, advertisement & communication**: we use your personal information for marketing and (interest based) advertising for instance by using SDKs or cookies, as well as communication. Think updates on new Services, but also personalised advertisements of WeTransfer or our partners, which we can serve on our or third party websites. In order to find the right audience for these advertisements we will look at certain segments of people. For instance, people who use similar Services as ours, people who share the same characteristics as our current users or people within a certain geo-location, such as the Amsterdam area. In order to connect with our target audience, we might use sequential messaging, which is basically a form of storytelling: each time you interact with our Services on a different device, you may receive a slightly different ad in a different form, but the ads are part of the same story. Moreover, based on the way you interact with our Services through your devices, we might promote one of our (other) Services or features. Furthermore, we enable you to engage in any (personalised) actions, promotions or events we offer. Finally, we make use of email marketing to send you relevant stories about creativity or WeTransfer news. Where necessary, we'll always ask for your consent before sending you email marketing. Of course, you can always simply opt-out in each email you receive. | |
| 81 | 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: | |
| 83 | 82 | |
| 84 | 7. **Legal**: in so far as necessary, we might use your personal information to defend WeTransfer in legal proceedings in relation to or as a result of your use of our Services, following a court order, abiding by any law, regulation or governmental request, cooperating with law enforcement, cooperating in fraud investigations of third parties, safeguarding national security, defense, public security, and to uphold our Terms of Services. | |
| 83 | 1. **Functional cookies** are used to provide functionalities when using our Service, such as the possibility to set preferences or to remember your previous settings. | |
| 85 | 84 | |
| 86 | **Legal grounds** | |
| 85 | 2. **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. | |
| 87 | 86 | |
| 88 | Each processing activity has a valid legal ground, which is described below. | |
| 87 | 3. **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. WeTransfer 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. WeTransfer 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](https://wetransfer.com/explore/legal/cookie-list). | |
| 89 | 88 | |
| 90 | 1. **Contractual obligations with you**: regarding the activities and purposes mentioned under 1, 2 and 3. We need to process personal information to offer our Services through our websites and mobile apps, to provide (technical) support and to bill your subscription fee. | |
| 89 | 4. **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. | |
| 91 | 90 | |
| 92 | 2. **Legal obligations**: regarding the activities and purposes under 3, 4 and 7. We're legally obliged to process your personal information for accounting purposes, to respond to legal requests and NTD- or DMCA-requests. | |
| 91 | We have an extensive cookie list available [here](https://wetransfer.com/explore/legal/cookie-list), 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 WeTransfer cookies, the Service might not function in optimal form. | |
| 93 | 92 | |
| 94 | 3. **Consent**: (partially) regarding activities and purposes mentioned under 2 (e.g. accessing your Content for support) and 6, except when we communicate direct marketing in relation to our own and similar Services to you as a paid user. | |
| 93 | - How we operate as a global business | |
| 95 | 94 | |
| 96 | 4. **Legitimate interests**: (partially) regarding activities and purposes under 1 & 3 (e.g. to provide cross device access). For the purposes mentioned under 4 in order to provide safe Services, to prevent fraud and react against illegal use of our Services. For our innovative interests as mentioned under 5. And finally for our (direct) marketing, brand interests under 6 and legal & compliance interests as stated under 7. When we use your personal information based on our or a third party's legitimate interest, we will make sure to balance your rights and freedoms against said legitimate interest. If, to the extent applicable, you wish to object to the activities based on our legitimate interest and there's no opt-out available in your account settings or received communication, please contact [legal@wetransfer.com](mailto:legal@wetransfer.com) | |
| 95 | All Personal Information, including User Content, that is uploaded within Europe (including the United Kingdom) is in principle hosted on servers in Dublin, Ireland. | |
| 97 | 96 | |
| 98 | - What parties do we share personal information with? | |
| 97 | We are a business with a global footprint. Therefore we work together with WeTransfer entities and partners outside the European Economic Area ("EEA"). This means that we might share or store certain personal information with them. | |
| 99 | 98 | |
| 100 | WeTransfer has several partners to operate and improve its Services. Furthermore, we may share or allow you to share your information as part of some of the Services. | |
| 99 | 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. | |
| 101 | 100 | |
| 102 | 1. **People and (social) media of your choice**: you may choose to share your Content with others, such as teammates, within our Services or on (social) media like Twitter. | |
| 101 | When sharing personal information with other WeTransfer entities, or with third parties, such as service providers and marketing partners, who are located outside the EEA, we ensure that either: | |
| 103 | 102 | |
| 104 | 2. **Law enforcement agencies or regulators**: we are obliged to share your personal information in case of a legal request. In case we run across CSAI or when we're notified on other illegal Content we'll also share your personal information with law enforcement agencies. | |
| 103 | - The European Commission has issued a so-called "[Adequacy Decision](https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en)" regarding the country where the WeTransfer entity or third-party is located. This is the case for: | |
| 105 | 104 | |
| 106 | 3. **Business partners**: we collaborate with advertising partners, marketing and communication agencies. We do this for (interest based) advertising, branding and reaching out to you. Our advertising partners implement their own tracking cookies which fall under their terms of services and privacy & cookie statement. Please find a list of all third party cookies and their privacy policies [here](https://we.tl/cookielist) | |
| 105 | - our subsidiary as well as third-parties based in the UK, | |
| 107 | 106 | |
| 108 | 4. **Integrated services**: if you decide to integrate (one of) our Services with another service (such as Slack or your social media account) we will connect that service with ours. In order to provide such service, we will need to share some of your personal information with that service. The terms and privacy & cookie statement of these third parties applies, at least for their part of the connection. | |
| 107 | - third parties based in Canada, Israel, and Switzerland, and | |
| 109 | 108 | |
| 110 | 5. **WeTransfer entities**: we share personal information between entities which are part of the WeTransfer group in order to provide our Services and for all purposes mentioned under "Why do we use your personal information?". | |
| 109 | - certain third parties based in the USA who have certified themselves under the [EU-US Data Privacy Framework](https://www.dataprivacyframework.gov/s/). When this is the case, we conduct a review to ascertain whether their certification is still active. | |
| 111 | 110 | |
| 112 | We're a global business, which means we might share or store personal information in countries outside of the European Economic Area ("EEA"). Those countries have different data protection laws in place. However, when we transfer- and host data globally, we will make sure that appropriate safeguards are in place in order to ensure your personal information enjoys a similar level of protection as it would within the EEA. For example, we will sign EU Standard Contractual Clauses with the receiving partner. | |
| 111 | - We have signed special contracts, called "[Standard Contractual Clauses](https://commission.europa.eu/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en)", with the WeTransfer 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 | |
| 113 | 112 | |
| 114 | - Why and how are cookies used? | |
| 113 | Our WeTransfer entities commit to processing information in compliance with WeTransfer's privacy policy and applicable privacy laws. | |
| 115 | 114 | |
| 116 | We place cookies with the intention of making WeTransfer 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. | |
| 115 | - How we protect your personal information | |
| 117 | 116 | |
| 118 | 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. | |
| 117 | WeTransfer 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. | |
| 119 | 118 | |
| 120 | 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: | |
| 119 | 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. | |
| 121 | 120 | |
| 122 | 1. **Functional cookies** are used to provide functionalities when using our Service, such as the possibility to set preferences or to remember your previous settings. | |
| 121 | WeTransfer 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. | |
| 123 | 122 | |
| 124 | 2. **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. | |
| 123 | - How long we keep your personal information | |
| 125 | 124 | |
| 126 | 3. **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. WeTransfer 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. WeTransfer 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](https://we.tl/cookielist). | |
| 125 | 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. | |
| 127 | 126 | |
| 128 | 4. **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. | |
| 127 | Personal Information | |
| 129 | 128 | |
| 130 | We have an extensive cookie list available [here](https://we.tl/cookielist), 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 WeTransfer cookies, the Service might not function in optimal form. | |
| 129 | WeTransfer 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. | |
| 131 | 130 | |
| 132 | - Can you use WeTransfer for private or sensitive files? | |
| 131 | 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: | |
| 133 | 132 | |
| 134 | We treat your Content with respect. We don't provide any public search function, catalogue or listing to find Content. We trust you understand that in order to fulfill our moral responsibility to reduce the spread of Child Sexual Abuse Imagery (CSAI), we do use automated systems to to detect such Content. Finally, we're obliged to delete your Content when we receive a Notice-and-takedown/DMCA-request or when we receive a legal request. | |
| 133 | - to help maintain and enhance the safety and security of our users, and our platform; | |
| 135 | 134 | |
| 136 | Please be mindful when distributing download/ access links - whoever it is passed on to or has access to a download/access link can access or download the Content. For extra security and confidentiality you might want to use our feature to protect your files with a password (if available). | |
| 135 | - to act on reports of harmful or illegal content or activity; | |
| 137 | 136 | |
| 138 | - What retention procedures are in place? | |
| 137 | - to comply with our obligations under applicable law, such as the EU Digital Services Act. | |
| 139 | 138 | |
| 140 | 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. | |
| 139 | User Content on File Transfer | |
| 141 | 140 | |
| 142 | **Personal information** | |
| 141 | When using WeTransfer 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. | |
| 143 | 142 | |
| 144 | WeTransfer 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) and legal requests and to resolve (legal) disputes. | |
| 143 | User Content on Services other than File Transfer | |
| 145 | 144 | |
| 146 | **Files you transfer** | |
| 145 | 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. | |
| 147 | 146 | |
| 148 | When using WeTransfer File Sharing your Content will be deleted after 7 days, unless you have a Pro account in which case your transfer data is stored by default for 28 days or until the expiry date you set manually. After this period, a file is automatically deleted from our servers. The personal information that accompanies your transfer is kept for a maximum of 12 months. Such personal information is only accessible to very few people within WeTransfer, those that need it to perform their job, for example to provide you with support. When data is older than 12 months, we scrub it from the database, pseudonymise or anonymise it for analysis. Pseudonomising your personal information means that we do not use your email address or IP address for analytical purposes, but create a random pseudonym for both and use that pseudonym instead. That way we don't have to handle directly identifiable personal information, which is privacy-friendly. | |
| 147 | - Your rights and choices | |
| 149 | 148 | |
| 150 | **Content you create, use, store or share through the Services other than file sharing** | |
| 149 | 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, WeTransfer will respond within the time period limits provided by the relevant law. In the EEA and UK, the time period is one month. | |
| 151 | 150 | |
| 152 | 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. | |
| 151 | **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. | |
| 153 | 152 | |
| 154 | - How safe is it to use our Services? | |
| 153 | **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. | |
| 155 | 154 | |
| 156 | WeTransfer takes technical and organisational measures to protect your personal information against loss or other forms of unlawful processing. | |
| 155 | **Delete your information** | |
| 157 | 156 | |
| 158 | We make sure that personal information is only accessible by those who need access to do their job and that they are properly authorised. That means we keep logs of who has access to personal information, we limit the amount of people that have access and we make sure that personal information can only be read, copied, modified or removed by properly authorised staff. We monitor internal activity to ensure the safety and accuracy of personal information. | |
| 157 | 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. | |
| 159 | 158 | |
| 160 | WeTransfer 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. | |
| 159 | There are scenarios where we can't erase your personal information, such as when: | |
| 161 | 160 | |
| 162 | During an upload, while it's stored on our servers and during a download, Content is encrypted and only sent over a secure connection (https). The servers we use to store your Content for you are GDPR compliant and secure. | |
| 161 | - The data is still needed for the reason we gathered it. | |
| 163 | 162 | |
| 164 | - What are your rights as a user? | |
| 163 | - WeTransfer'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. | |
| 165 | 164 | |
| 166 | If you need more info on your personal information, please let us know. We may ask for proof of identity. If you change your mind and no longer want us to process your personal information, let us know. | |
| 165 | - WeTransfer has a legal obligation to retain the data, or | |
| 167 | 166 | |
| 168 | You can ask WeTransfer to: | |
| 167 | - WeTransfer requires the data to establish, exercise, or defend against legal action. For example, when there's an unresolved matter linked to your account. | |
| 169 | 168 | |
| 170 | - access, receive a copy of or correct your personal information; | |
| 169 | **Port your information** | |
| 171 | 170 | |
| 172 | - in certain cases, erase your personal information or block or restrict our use of it; | |
| 171 | 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. | |
| 173 | 172 | |
| 174 | - in certain cases, send your personal information to other third parties. | |
| 173 | **Object to the processing of your information** | |
| 175 | 174 | |
| 176 | You can do this by sending an email to [legal@wetransfer.com](mailto:legal@wetransfer.com) Please state clearly in the subject that your request concerns a privacy matter and more specific whether it is a request to access, correction or deletion. Bear in mind that under circumstances WeTransfer requests for additional information to determine your identity. | |
| 175 | When we process your personal information for the legitimate interests of WeTransfer 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. | |
| 177 | 176 | |
| 178 | **Right to object** | |
| 177 | **Restrict the processing of your information** | |
| 179 | 178 | |
| 180 | You have a right to object to our use of your personal information, for instance when the legal base for processing is based on one of our legitimate interests (see subsection "Legal grounds"). If you inform us that you do not longer wish us to process your personal information or to be approached, WeTransfer will move your personal information to a separate file. Your personal information will no longer be used for the above mentioned purposes, unless our legitimate interest, for example safety & security, outweighs your right to objection. You can request this via [legal@wetransfer.com](mailto:legal@wetransfer.com). Please state clearly that your request concerns a privacy matter and more specifically that you exercise your right to object. | |
| 179 | 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. | |
| 181 | 180 | |
| 182 | If you think we have infringed your privacy rights, you can lodge a complaint with the relevant supervisory authority. You can lodge your complaint in particular in the country where you live, your place of work or place where you believe we infringed your right(s). | |
| 181 | **Lodge a complaint** | |
| 183 | 182 | |
| 183 | If you're unhappy with how we've handled your request or your personal information, we encourage you to contact us. You also have the right to file a complaint with our lead supervisory authority, the Dutch "[Autoriteit Persoonsgegevens](https://www.autoriteitpersoonsgegevens.nl/en)" (based in The Netherlands) or with your [local supervisory authority](https://edpb.europa.eu/about-edpb/about-edpb/members_en%E2%80%9D.). | |
| 184 | ||
| 184 | 185 | **Withdrawal of consent** |
| 185 | 186 | |
| 186 | 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. | |
| 187 | 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. | |
| 187 | 188 | |
| 188 | **California consumers** | |
| 189 | **How to exercise your rights** | |
| 189 | 190 | |
| 190 | Subject to certain limitations under California Civil Code § 1798.83, if you are a California resident, you may ask us to provide you with (i) a list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year and (ii) the identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year. We do not, however, share your personal information with marketers, subject to the above statute. | |
| 191 | To exercise any of the above rights, please contact us via [legal@wetransfer.com](mailto:legal@wetransfer.com). 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. | |
| 191 | 192 | |
| 192 | - How to contact WeTransfer | |
| 193 | - Minors | |
| 193 | 194 | |
| 194 | Our support team is available via [support@wetransfer.com](mailto:support@wetransfer.com). If you have any questions, please email us in English, to make sure we can help you in the best way. If you have questions about the way WeTransfer processes your personal information or the personal information WeTransfer stores about you, please contact WeTransfer by sending an email with your question to [legal@wetransfer.com](mailto:legal@wetransfer.com). If you need to contact our Data Protection Officer, please do so via [dpo@wetransfer.com](mailto:dpo@wetransfer.com). We speak Dutch & English. | |
| 195 | WeTransfer's Services are not directed towards minors. You are only allowed to use our Services when aged 16 and over. | |
| 195 | 196 | |
| 196 | - Revisions to the Privacy & Cookie Statement | |
| 197 | - How to contact us | |
| 197 | 198 | |
| 198 | Note that WeTransfer may revise this Privacy & Cookie Statement from time to time. Each revised version shall be dated and posted on the website. WeTransfer recommends that you review the website from time to time and take note of any changes. If you do not agree with the Privacy & Cookie Statement, you should not or no longer access or use the website and/or service. By continuing to use the website and/or service you accept any changes made to the Privacy & Cookie Statement. | |
| 199 | You can contact us about this privacy policy or other related questions via [legal@wetransfer.com](mailto:legal@wetransfer.com). You can also reach us by mail on Keizersgracht 271-287, 1016 ED, Amsterdam, The Netherlands. | |
| 200 | ||
| 201 | You can reach out to our Data Protection Officer via email [dpo@wetransfer.com](mailto:dpo@wetransfer.com) or by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium. |