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. We also use the information you provide about someone else for communications required during the transaction process; for example, if you're an agent, we'll use your client's email address to let them know they need to sign a document.

If you provide personal information about your client(s) to us in order to complete a transaction, you represent and warrant that you have obtained their consent to do so. We also provide a number of third-party integrations, such as back-office software and other tools that enhance and improve our customers' businesses. When those users enable these integrations, data from ReFiles may be shared with those systems. We're not responsible for those tools or how they're used; they're governed by their own policies.

We also disclose information where we are required to do so by law, such as to comply with a subpoena or similar legal process. Where we are required to disclose your information pursuant to legal process, we will attempt to let you know before disclosure unless we are prohibited from doing so by law.

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. We protect your data with secure storage measures to prevent unauthorized access. 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. We may retain certain data longer if required by law or for legitimate business purposes such as resolving disputes, enforcing our agreements, or complying with legal obligations.

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.

How You Can Access Your Information

If you are a Registered User, you can retrieve, correct, or update your information by accessing your account on ReFiles or by contacting us at the contact information listed below. If you are a client of an Account Owner or Registered User, you can obtain the information related to your transaction from that Owner or User. We do not provide data contained in ReFiles to non-account holders.

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.

For transfers of personal data from the European Economic Area (EEA) or United Kingdom (UK) to the United States, we rely on Standard Contractual Clauses approved by the European Commission to ensure your data is protected in accordance with GDPR requirements.

Your personal information may be subject to access by and disclosure to law enforcement agencies in the United States. In most cases and subject to legal or contractual restrictions, you are free to withdraw your consent and discontinue using our services at any time upon reasonable, advance notice.

Our Privacy Guarantee

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

Notwithstanding any other part of this policy, ReFiles Inc. will not use customer data to contact the buyer or seller involved in any transaction.

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. ReFiles Inc. will not sell, rent, or share collected data with external organizations for marketing purposes.

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.

Changes to the Policy

You agree to this policy when you use our services or provide information to us. If you don't agree to this policy or the Terms of Use, please don't use the website or provide your information to us. We may change, modify, add, or remove portions of this policy at any time. If we do, we'll update this page to reflect the date of the last update. If we make any material changes, we'll notify you either by email (sent to the email address specified in your account) or by a notice on refiles.io before any changes go into effect. Please check this page periodically for changes. If you continue to use our Services after any changes take effect, those changes will apply to you and your information.

How To Contact Us

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