Effective Date: January 1, 2020
I. IMPORTANT INFORMATION AND WHO WE ARE Click Here
II. THE INFORMATION WE COLLECT ABOUT YOU Click Here
III. HOW IS YOUR INFORMATION COLLECTED Click Here
IV. SOCIAL MEDIA AND TECHNOLOGY INTEGRATIONS Click Here
V. ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING Click Here
VI. HOW WE USE YOUR INFORMATION Click Here
VII. DISCLOSURES OF YOUR INFORMATION Click Here
VIII. YOUR RIGHTS AND CHOICES Click Here
IX. DATA SECURITY Click Here
X. INTERNATIONAL TRANSFERS Click Here
XI. QUESTIONS Click Here
XII. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS Click Here
XIII. ADDITIONAL INFORMATION FOR DATA SUBJECTS IN THE EUROPEAN UNION Click Here
I. IMPORTANT INFORMATION AND WHO WE ARE
The Site is not intended for children and we do not knowingly collect information relating to children. If Files Keepers discovers that it has inadvertently collected personal information from anyone younger than the age of 13, it will delete that information. Furthermore, we do not knowingly “sell” the personal information of children under 16 years old who are California residents without their affirmative authorization.
It is important that the information we hold about you is accurate and current. Please keep us informed if your information changes during your relationship with us. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable.
Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.
E. CONTENT FROM AND LINKS TO OTHER WEBSITES, AND FILE KEEPERS CONTENT FOUND OUTSIDE THE SITE
In addition, File Keepers content may be included on web pages and websites that are not associated with File Keepers and over which we have no control. Other parties may collect data through the use of their own cookies, web beacons or other technology, independently collect information or solicit information, and may have the ability to track your use of their websites and services. File Keepers is not responsible for the privacy practices or the content of any other party.
II. THE INFORMATION WE COLLECT ABOUT YOU
We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. The categories of information that we and our service providers collect, use, store and transfer are as follows:
- Contact Information includes name, business name, title or role, billing address, delivery address, email address and telephone numbers.
- Demographic Information includes zip code, gender, age and income.
- Financial Information includes bank account and payment card details.
- Transaction Information includes details about the products and services you have purchase and have order from us.
- Technical Information includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology or other unique identifier (a set of numbers or characters that is assigned to your computer, mobile phone, or other device when you are on the Internet) (“Device Identifier”) for any computer, mobile phone, tablet or other device (“Device”) used to access the Site.
- Profile Information includes your username and password, your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our website, such as the areas of our Site you visit or use, the products or services you view or consider, and the time of day you visited the Site.
- Marketing and Communications Information includes your preferences in receiving marketing from us and our partners and your communication preferences.
- Location Information includes information about your location using a variety of technologies, such as GPS, IP address, and connected or nearby Wi-Fi networks.
- Job Applicant Data includes your employment and education history, transcript, writing samples, and references as necessary to consider your job application for open positions.
- Content includes the content within any messages you send to us (such as questions and comments to customer support), and the content of any physical documents or electronic files we store for you.
III. HOW IS YOUR INFORMATION COLLECTED?
We use different methods to collect information from and about you including through:
Direct interactions. You may give us your Demographic, Contact, Financial, Profile, or Marketing and Communications Information by filling in forms or by corresponding with us by mail, phone, email, or otherwise. This includes information you provide when you:
- purchase our products or services;
- create or use an account on our Site;
- subscribe to our service or publications;
- request marketing to be sent to you;
- provide us with information as part of your use of our storage services;
- enter a contest, promotion or survey; or
- give us feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical, Usage, and Location Information about your equipment, browsing actions and patterns. We collect this information by using cookies, web beacons, embedded scripts and other similar technologies. We may also receive Technical Information about you if you visit other websites employing our cookies.
- Cookies – Cookies are data files sent to and stored on the Device you use to view a website. Cookies can be used for many purposes, including to monitor use of our Site, to customize content specific to your interests, to ensure that you do not see the same advertisement repeatedly and to store your user name and password so you do not have to re-enter it each time you visit the Site. If you choose to disable cookies on your Device, some features of the Site or our content may not function properly.
- Web Beacons – Web Beacons are small graphic images or other web programming code (also known as “1×1 GIFs” or “clear GIFs”) that may be included on the Site and in our e-mail messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Site, to monitor how users navigate the Site, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- Embedded Scripts – Embedded scripts are programming code designed to collect information about your interactions with the Site, such as the links you click. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the Site.
- analytics, advertising and marketing providers;
- social networks;
- business partners such as delivery services;
- publicly availably sources; and
- information your company provides about you and you provide about the company.
IV. SOCIAL MEDIA AND TECHNOLOGY INTEGRATIONS
V. ANALYTICS PROVIDERS & AD SERVERS; ONLINE TRACKING
File Keepers works with certain other parties (including network advertisers, ad agencies, and analytics companies) to provide us with information regarding traffic on the Site, to serve advertisements, including our advertisements elsewhere online, and to provide us with information regarding the use of the Site and the effectiveness of our advertisements. For example, if you clicked on one of our advertisements that led you to the Site, our vendor(s) or other parties may be able to tell us which advertisement you clicked on and where you were viewing the advertisement. These other parties may set and access their own tracking technologies (including cookies, embedded scripts, and web beacons) and may otherwise collect or have access to your Device Identifier, Usage Data and related information about you. These technologies, including those set by network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times, conduct research regarding the usefulness of certain advertisements to you, and assist in providing analytics. We may share Device Identifier and Usage Data about visitors with advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of vendors to perform advertising and analytics services, some of these companies may be members of the Network Advertising Initiative (“NAI”) or the Digital Advertising Alliance (“DAA“) Self-Regulatory Program for Online Behavioral Advertising.
For additional information regarding targeted advertising and the “opt-out” procedures of NAI members and DAA Self-Regulatory Program participating companies, you may visit:
- NAI Opt-Out Tool (for website users): http://www.networkadvertising.org/managing/opt_out.asp
- DAA Consumer Choice (for website users): http://www.aboutads.info/choices/
- DAA AppChoices (for mobile app users): http://youradchoices.com/appchoices
Please note that opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Site and elsewhere online. Some other parties may collect information about your online activities over time and across different websites.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. However, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, unless and until the law is interpreted to require us to do so, the Site currently does not alter its practices when a “Do Not Track” signal from a visitor’s browser is received. To find out more about “Do Not Track,” you may wish to visit http://www.allaboutdnt.com.
VI. HOW WE USE YOUR INFORMATION
We use the information we collect:
- to provide you with our products and services and respond to your customer service requests;
- to communicate with you information about the Site, our products or services, or promotional material from some of our advertisers or business partners,
- to process a transaction you initiate;
- to provide you with information, products or services that you have requested or agreed to receive;
- to verify your contact information is valid;
- to customize and tailor your experience on the Site, for example, by displaying content that we think you might be interested in;
- to send you offers or information on behalf of our business partners or affiliates;
- to improve the Site, our products and services;
- to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- to contact you with regard to your use of the Site and, in our discretion, changes to the Site policies or functionality;
- to develop and send you direct marketing, including advertisements and communications about our and other entities’ products, offers, Promotions, rewards, events and services; and
- for other business and commercial purposes at your direction, or with your consent or notice.
VII. DISCLOSURES OF YOUR INFORMATION
We may share non-personally identifiable information, such as aggregated user statistics, in our discretion and without restriction.
A. RELATED PARTIES AND AFFILIATES
File Keepers discloses information to its parent, affiliates, and related entities (including without limitation, Raleigh Enterprises, Raleigh Creative, Hollywood Rentals, Sunset Marquis, Cavatina at Sunset Marquis Hotel, Raleigh Studios, and Rosenthal – The Malibu Estate) for a variety of purposes, including for business, operational, commercial and marketing purposes. File Keepers may, and reserves the right to, share your information with any other company that is not presently, but becomes, a File Keepers parent, subsidiary, or affiliate.
B. EXTERNAL PARTIES
We share information with service providers in connection with the service providers’ performance of services to, or on behalf of, the Site or File Keepers. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us. These service providers may store or use your information outside of the EU or United States.
If your company has provided you with access to the Site, we may share information about your use of the Site, including your Contact Information and Usage Information, with your company or its agents.
Partners or At Your Request or Direction
Administrative & Legal Reasons
We may transfer and disclose information to other parties to:
- comply with a valid legal inquiry or process such as a search warrant, subpoena, statute or court order, or if in our opinion such disclosure is required by law;
- protect the safety, interests, rights, property or security of File Keepers, you, or any other party;
- respond to a breach or attempted breach of the security of our Site;
- at the request of a government agency or File Keepers conducting an investigation.
We may also use information to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers, or law enforcement agencies in our discretion. File Keepers may also disclose and transfer your information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if File Keepers (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to another party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of File Keepers’ ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.
We share information with vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the “Analytics Providers & Ad Servers; Online Tracking” section above.
Sweepstakes, Contests & Promotions
We may offer sweepstakes, contests, and other promotions (any, a “Promotion“) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your information may be disclosed to other parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winners list.
C. BUSINESS TRANSFERS, MERGERS AND ACQUISITIONS
File Keepers may also disclose and transfer your information: (i) to a subsequent owner, co-owner or operator of the Site or applicable database, or of our products or services; (ii) if File Keepers (or any of its affiliated, parent, or subsidiary companies) assigns its rights regarding any of your information to another party; or (iii) in connection with a corporate merger, consolidation, restructuring, the sale of certain of File Keepers’ ownership interests, assets, or both, or other company change, including, without limitation, during the course of any due diligence process. These transfers and disclosures may be carried out without notice to you.
We do not allow our service providers to retain, use, or disclose your information for their own commercial purposes and only permit them to use your information for specified purposes and in accordance with our instructions.
VIII. YOUR RIGHTS AND CHOICES
A. ACCESSING, UPDATING, CORRECTING OR DELETING INFORMATION
You may review, update, correct or delete the information in your profile by logging into your website account. You may also contact us at Privacy@filekeepers.com or EUprivacy@filekeepers.com to accomplish the foregoing or if you have additional requests or questions.
You are responsible for maintaining the accuracy of the information you submit to us, such as your Contact Information. If you contact us with changes, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable. Note, however, that information may persist internally for our administrative purposes and that residual data may remain on backup media or for other reasons.
B. EMAIL COMMUNICATIONS
You can ask us to stop sending you marketing emails at any time by following the opt-out links on any marketing emails sent to you or by contacting us. Alternatively you may contact us at Privacy@filekeepers.com or EUprivacy@filekeepers.com.
Where you opt-out of receiving these marketing emails, this will not apply to information provided to us as a result of the purchase of a product or service or other transactions.
IX. DATA SECURITY
File Keepers takes commercially reasonable security measures to help protect information collected by or submitted to File Keepers via telephone, email, or our website from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your information to those employees, agents, and contractors who have a business need to know. However, please note that transmission over the Internet or wireless networks cannot be guaranteed to be 100% secure; and therefore we cannot ensure or warrant the security of any information we collect. You use our Site and provide us with your information at your own risk.
X. INTERNATIONAL TRANSFERS
The Site is operated in the United States, and File Keepers and our service providers, vendors and partners operate in the United States and other jurisdictions. If you are located outside of the United States, please be aware that any information you provide to us may be transferred to and processed in the United States and other countries. By using the Site, or providing us with any information, you consent to this transfer, processing and storage of your information in countries where the privacy laws may not be as comprehensive as those in the country where you reside or are located.
We can also be contacted by mail at:
5300 Melrose Ave – 4th Fl. West Office Bldg.,
Hollywood, CA 90038
XII. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS
Our Site is intended to provide information to job applicants and our business customers. You understand that personal information collected about you is solely within the context of (i) your role as an employee, job applicant, owner, director, officer, or contractor or (ii) File Keepers conducting due diligence regarding, or providing or receiving a product or service to or from your employer.
If information about you has been processed by us as a service provider on behalf of a business customer and you wish to exercise any rights you have with regard to such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
B. SHINE THE LIGHT
Pursuant to California Civil Code Section 1798.83, customers who are residents of the State of California have the right to request from companies conducting business in California certain information regarding File Keepers’ disclosure within the immediately preceding calendar year of that California resident’s personal information to third parties (and in some cases, affiliates) for their direct marketing purposes. If you are a California resident and you have questions about our practices with respect to sharing information with third parties and affiliates for their direct marketing purposes, please send your request to the following email address: Privacy@filekeepers.com or write to us at the following mailing address: File Keepers, 5300 Melrose Ave – 4th Fl. West Office Bldg., Hollywood, CA 90038. You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We are not responsible for notices that are not labelled or sent properly, or do not have complete information.
XIII. ADDITIONAL INFORMATION FOR DATA SUBJECTS IN THE EUROPEAN UNION
A. PERSONAL DATA
B. LEGAL BASES FOR PROCESSING PERSONAL DATA
We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform obligations relating to a contract to which you are a party or to take steps at your request before entering into such a contract.
- Where it is necessary for our legitimate interests (or those of our customers or a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests include those related to providing services to our customers and conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us using the contact information provided above.
D. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, you can ask us to delete your data: see “EU Data Subject Rights” section below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
E. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
F. EU DATA SUBJECT RIGHTS
Under certain circumstances, data subjects in the EU may have rights under data protection laws in relation to your personal data as outlined below:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it affects your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact EUprivacy@filekeepers.com.
If your personal data has been processed by us on behalf of a customer and you wish to exercise any rights you have with such personal data, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal data. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time Limit To Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Complaints to Supervisory Authority
EU data subjects may have the right to make a complaint at any time to the supervisory authority for data protection issues. However, we would appreciate the chance to deal with your concerns before you approach the supervisory authority so please first contact us directly to allow us to do so.