Privacy Policy

Our Commitment to Privacy

When you use ReFiles, we know you're trusting us with your data. We also know we have a responsibility to respect your privacy, and we work hard to do just that. This policy explains how we use personal information. By providing personal information to ReFiles Inc. through our websites, you consent to ReFiles Inc. collecting information about you and to ReFiles Inc. using your personal information in accordance with this policy. This Privacy Policy applies to websites operated by ReFiles Inc., including refiles.io.

Personal Information Collected by ReFiles Inc.

This policy applies to all information collected or submitted through ReFiles Inc.'s websites, including refiles.io. We collect personal information directly from you during the account creation process and user account setup process. This includes:

• Account information (name, email address, phone number)
• Business information (brokerage name, license numbers)
• Transaction data (deals, documents, parties, notes, milestones)
• Payment information (processed securely through third-party providers)
• Communication data (messages, support requests)

Collection of Device and Activity Data

Like most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), operating system, date/time stamp, and referring/exit pages. We use this information as needed to provide you with specific services, analyze trends, and improve our platform.

Lawful Basis for Processing

We process your personal data based on the following legal grounds:

• Contract: To perform our contract with you when you use our services, including creating your account, processing transactions, and providing customer support.
• Legitimate interests: For our legitimate business interests such as security, fraud prevention, improving our services, and communicating with you about your account.
• Legal obligations: To comply with applicable laws, regulations, and legal processes.
• Consent: Where required by law, we will obtain your consent before processing your data for specific purposes such as marketing communications.

How We Use Information

We use the information you provide when processing or completing a transaction on ReFiles to provide our services. While we do not sell your personal information to third parties, we may share your information with third parties only after receiving the Account Owner's written consent.

Finally, we never use or share the personal information provided to us online except as described in this policy.

Subprocessors

We use third-party service providers (subprocessors) to help deliver our services. These providers process personal data on our behalf and are contractually obligated to protect your information. A current list of our subprocessors is available on our Subprocessors page.

How We Protect Information

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place physical, electronic, and managerial procedures to help safeguard and secure the information we collect online. For more details about our security practices, please see our Security Policy.

Data Retention

We retain your personal data for the duration of your account. After account deletion, we retain data for 30 days before permanent deletion to allow for account recovery if requested.

Cookies

We use only essential cookies that are strictly necessary for the operation of our website and services. These cookies enable core functionality such as security, authentication, and session management. Because these cookies are essential, they do not require consent.

Your Rights Under GDPR

If you are located in the European Economic Area (EEA) or United Kingdom (UK), you have the following rights under the General Data Protection Regulation (GDPR):

• Right to access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can request that we correct any inaccurate or incomplete personal data.
• Right to erasure: You can request that we delete your personal data, subject to certain legal exceptions.
• Right to restrict processing: You can request that we limit how we use your personal data.
• Right to data portability: You can request a copy of your data in a structured, commonly used, machine-readable format.
• Right to object: You can object to our processing of your personal data based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you can withdraw that consent at any time.

To exercise any of these rights, please contact us at support@refiles.io. We will respond to your request within 30 days.

International Data Transfers

We operate in the United States. Any information provided through refiles.io will be processed and stored in the United States, where privacy laws may offer different levels of protection from those in other countries.

Our Privacy Guarantee

ReFiles Inc. customers own the data they put into ReFiles. This includes all customer data, from user information to transaction data.

ReFiles Inc. does not disclose customer data except as described in this policy.

Data Sharing Restrictions

We do not share personal information with third parties for marketing or promotional purposes under any circumstances.

We do not transfer or share consumer data with any external organizations under any circumstances, including with user or account owner consent, except as required by law or as described in this policy.

How To Contact Us

Should you have other questions or concerns about this Policy, please email us at support@refiles.io.