Effective Date: June 1, 2022
Welcome to Filo Software, Inc (“Filo,” “we,” “us,” “our”) product offerings (the “Filo Product”) or general marketing and recruiting website (the “Website”). This Privacy Policy is intended to help users understand how we collect, use, disclose, and protect the information we receive from users of the Filo Product and Website, including users in the European Economic Area (“EEA”) (collectively, “you” or “user”). For the purposes of compliance with the EU General Data Protection Regulation (“GDPR”), we are the “controller” of Personal Data (i.e., Personal Information) we receive from you.
Within this Privacy Policy, users may be referred to as Data Subjects. A Data Subject means an identified or identifiable natural person in the EEA as set forth in the GDPR.
This Privacy Policy applies to the Filo Product and the Website, which includes highalphaspaces.com, filo.co, their subdomains, all of the websites and internet properties owned or operated by us, regardless of the medium in which the Website is accessed by a user (e.g., computer browser, mobile browser, etc.), and all activities, services, features, or resources offered by Filo.
We collect personal information to provide the information or services requested by an individual. “Personal Information” refers to any information relating to an identified or identifiable natural person who is the subject of the information. Personal Information may include, but is not limited to, your first and last name, email address, telephone number, address, financial information (for paid users), and any other personal or preference information that you provide to us.
When you use and navigate the Filo Product or Website, we may collect additional information from you that may not, by itself, reasonably identify you as the source (“Usage Information”). Usage Information may include, without limitation, the type of computer you are using, the type of internet browser you are using, the location from which you are using the Filo Product or visiting the Website, the type of computer operating system you are using with the Filo Product or to visit the Website, the domain name of the website from which you linked to the Website, the internet service provider utilized, or the areas of the Filo Product or Website you visited and the actions you performed. We will take reasonable measures to ensure that the Usage Information we collect is not personally identifiable and may not later be easily used to identify you as otherwise required by applicable law. All data and files shared with Filo under normal application usage is covered under our data and security policies, available by request.
Filo provides the ability to log in to the Filo Product using your Google account. If you authenticate yourself using any third-party services, you grant us access to your email address, and, if available, your name, photo, and username associated with them. We do not receive your password. You will also grant us access to view events on all calendars you have access to in Google Calendar and to view your calendars in Google Calendar.
We do not market to, and do not knowingly collect, any Personal Information from or about a child under the age of 13 without the consent of the child’s parent or legal guardian. If we discover that we have inadvertently collected information from a child under 13 years of age through the Filo Product or Website, we will promptly take all reasonable measures to delete that data from our systems.
When you visit the Filo Product or Website, we may collect Personal Information you voluntarily provide to us.
We store certain information, including Usage Information, from your browser using “cookies.” Cookies are small text files that are stored on a user’s computer hard drive. They are used to keep track of and store information about users. The information that is collected through cookies is handled in the same manner as other information collected here. If you prefer not to receive cookies, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. Please be aware, however, that certain features of the Filo Product and Website may be unavailable if your browser is not set to support or enable cookies.
We might receive information about you from other sources such as publicly available sources and information that we receive from our partners and other third parties. Since we may receive information about you from third parties whose privacy practices may differ from those described in this Privacy Policy, we do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available through third parties. Your use of third parties’ services and/or third-party websites is governed by and subject to the terms and conditions of those third parties and/or third-party websites. We encourage you to carefully review the privacy policies and statements of such third parties and/or third-party websites.
Except as set forth herein, we do not sell, rent, or trade your information to third parties. We use your information for various general purposes to help enhance your experience as described below:
We will not share, sell, or distribute your information with any third parties, including any of our affiliated companies, members, officers, directors, shareholders, subsidiaries, agents, or representatives, except as provided in the following circumstances:
We may employ third-party service providers to perform functions or carry out advertising or marketing on our behalf. They may have access to Personal Information needed to perform their functions, but they may not use it for other purposes.
From time to time, we may be required to share Personal Information in response to a valid court order, subpoena, government investigation, or as otherwise required by law. We also reserve the right to report to law enforcement agencies any activities that we, in good faith, believe to be unlawful or related to an alleged unlawful activity.
We may release your information when we believe release is appropriate to comply with the law or any rule, regulation, government or court order; enforce or apply our User Terms (https://www.filo.co/terms-conditions) and other agreements; or protect the rights, property, or safety of Filo, our members, affiliated companies, our users, or others.
If we become involved in a transaction involving the sale or license of our assets, such as a merger or acquisition, or if Filo is transferred to another company, we may disclose and/or transfer your information as part of the transaction. If the surviving entity is not Filo, your information may be used pursuant to the surviving entity’s privacy policies, which may be different from this Privacy Policy.
Other than as set out above, you will receive notice when information about you might go to third parties and you will have an opportunity to choose not to share the information.
We may also derive, disclose, and use information and data about you that is not personally identifiable, such as, for example, aggregated and statistical information about Filo customers.
At any time, Data Subjects from the EEA may withdraw consent you have provided to us for using, disclosing, or otherwise processing your Personal Information. You may withdraw your consent by communicating your request at the Contact Information provided below.
Please note that your withdrawal of consent to process certain Personal Information about you (1) may limit our ability to deliver services to you and (2) does not affect the lawfulness of our processing activities based on your consent before its withdrawal. Note that even after withdrawing consent, IEA may use, disclose, or otherwise process your Personal Information if required to do so by law.
Personal Information shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
Personal Information collected for purposes related to the performance of a contract between the Company and the User shall be retained until such contract has been fully performed.
Personal Information collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company.
The Company may be allowed to retain Personal Information for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Under certain circumstances, Data Subjects from the EEA may have the following rights under the GDPR:
California Civil Code Section 1798.83 permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. To make such a request, please contact us at the information provided below.
We take reasonable precautions to protect the information that is either available from or collected by the Filo Product and Website. We have taken steps designed to safeguard the Filo Product’s and Website’s integrity, telecommunications, and computing infrastructure, including but not limited to, authentication, monitoring, auditing, and encryption. Unfortunately, no data transmitted over or accessible through the internet can be guaranteed to be completely secure. As a result, we cannot ensure or warrant that your information will be secure from misappropriation by hackers, nefarious or criminal activities, or in the event of a failure of computer hardware, software, or a telecommunications network.
The Filo Product and Website may contain links to, or information about, other products that are outside our control or custody. We are not responsible for the content or privacy practices of other third-party products and suggest you review their privacy statements to understand how your information is used or shared by those other products. We do not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other usage or materials available on other products, even if one or more pages of the other products is/are framed within the Filo Product or Website.
This Privacy Policy was last modified on the date first printed above. We reserve the right to update this Privacy Policy from time to time, at any time, and without notice. You should check this page periodically for changes. We will not lessen your rights under this Privacy Policy without your explicit consent.
If you ever wish to access your information or to have your information updated or modified, you may do so by contacting us at the information provided below. To cancel an account you may have with us and have your information returned to you, please also contact us at the information provided below. We will make commercially reasonable efforts to handle requests to update or modify your information within thirty (30) days.
If you would like to opt-out of receiving direct marketing communications from us, you may do so by following any instructions included in the communication or by contacting us at the information provided below.
You may file a complaint regarding this Privacy Policy or our privacy practices by communicating with us using the Contact Information provided below.
Additionally, Data Subjects from the EEA may file a complaint with EU data protection authorities (“DPAs”). A list of DPAs from the European Commission may be found here: http://ec.europa.eu/newsroom/article29/document.cfm?action=display&doc_id=50061.
If you would like to contact us with questions or comments concerning the accuracy and/or privacy of your information, or if you believe that we have not adhered to this Privacy Policy, please contact us at info@filo.co or by sending a letter to:
Filo Inc
ATTN: Support
830 Massachusetts Ave, Ste 1500, Fl. 4
Indianapolis, Indiana 46204
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