Privacy Statement

4Sync Privacy Policy
Last Revised: February 27, 2023

This privacy policy ("Policy") explains how personally identifiable information is collected, used and disclosed by 4Sync Inc. ("4Sync", "we" or "us") with respect to your access and use of 4Sync's online file storage and sharing service located at https://www.4sync.com, (the "Service") and our mobile applications 4Sync Mobile ("Apps" or "App"), so you can make an informed decision about using the Service.

We reserve the right to change the provisions of this Policy at any time. We will alert you that changes have been made by indicating on this Policy the date it was last updated. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to review this Policy from time to time to make sure that you understand how any personally identifiable information you provide to us or collected about you will be used.

CHAPTER I. PERSONAL DATA WE COLLECT

We collect Personal Data from you in various ways when you use the Service and Apps.

1. Active Collection

Active Collection: We collect Personal Data: (i) that you voluntarily provide to us, such as your name, email address or your telephone number and (ii) to which you provide us access, such as social network data and performance related data.

When using our Apps we will collect Personal Data such as device type, operating system type and version.

Personal and demographic data may also be collected if you provide such information in connection with posting data, providing access to your online groups and other activities in connection with the Service.

If you choose to send a link through the "Share" function to a friend who is not yet a 4Sync user, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. 4Sync Inc. stores this information for the sole purpose of sending this one-time email.

For more information on the available opt-out options and mechanisms, please refer to CHAPTER IV. YOUR CHOICE & CONTROL.

2. Passive Collection

When you use the Service and our Apps, some Personal Data is also automatically collected, such as your Internet Protocol (IP) address, your operating system, browser type, the address of a referring website, and your activity on the Service.

We may also automatically collect certain logistical information in server logs, including information about how you use various features of the Service and information about the number, frequency and length of each session.

We may also automatically collect certain Personal Data through the use of "cookies" when you use the Service. If we link cookies to any Personal Data, we will treat this information as Personal Data. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve the Service and your experience.

If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features or services made available via the Service.

The use of cookies by our partners is not covered by our privacy statement. We do not have access or control over these cookies.

We may use Web beacons or similar technology on the Service and in our Apps. We do not tie the information gathered by clear gifs to our Users' Personal Data.

Web beacons are small, invisible graphic images that may be used on the Service or in emails relating to the Service to collect certain information and monitor user activity on the Service, such as to count visits, understand usage effectiveness and to tell if an email has been opened and acted upon. Such technologies are used to collect aggregate statistics related to usage of the Service and do not collect Personal Data.

3. Data Obtained from Other Sources

You can sign up for our Service (or link your App to your social network account) using your Facebook, Twitter or Google account credentials. If you do so:

These services will authenticate your identity and provide you the option to share certain personal information with us, such as your name and email address to pre-populate our sign-up form.

Services like Facebook Connect will give you the option to post information about your activities on this Website to your profile page to share with others within your network.

For more information, please refer to these services' Privacy Policy at:

Facebook: facebook.com/about/privacy
Twitter: twitter.com/privacy
Google: policies.google.com/privacy

4. Use of Collected Personal Data

We use Personal Data collected through the Service and Apps for the purposes described in this Policy or elsewhere on the Service or in the Apps. For example, we may use Personal Data we collect:

• to process and complete any transactions in connection with the Service and Apps;
• to request feedback and to otherwise contact you about your use of the Service and Apps;
• to respond to your emails, questions, comments, requests and complaints, and to provide customer service;
• to monitor and analyze Service and App usage and trends;
• to personalize and improve the Service or Apps, and our users' experiences with the Service and Apps (such as providing content or features that match interests), and to increase the Service's or Apps' functionality and user friendliness;
• to send you confirmations, updates, security alerts, additional information about our products and services and support and administrative messages, and otherwise facilitate your use of, and our administration and operation of, the Service or Apps. When sending marketing information about our Services or Products, we will only use your email address used during registration; we will not use other email addresses you may have provided to us, for instance in a feedback form, to send marketing emails;
• to notify you about important changes to the Service and Apps.

CHAPTER II. USE OF COOKIES & SIMILAR TECHNOLOGY

We may automatically collect certain Personal Data through the use of "cookies" when you use the Service. If we link cookies to any Personal Data, we will treat this information as Personal Data. Cookies are small data files stored on your hard drive at the request of a website. Among other things, cookies help us to improve the Service and your experience.

For more information on data collection via Google Analytics, please visit https://support.google.com/analytics/answer/6004245.

If you wish to block, erase, or be warned of cookies, please refer to your browser manufacturer to learn about these functions. However, if you choose to remove or reject cookies, this could affect certain features or services made available via the Service.

The use of cookies by our partners is not covered by our privacy statement. We do not have access or control over these cookies.

For more information about cookies, please visit www.allaboutcookies.org.

We may use Web beacons or similar technology on the Service and in our Apps. We do not tie the information gathered by gifs to our Users’ Personal Data.

Web beacons are small, invisible graphic images that may be used on the Service or in emails relating to the Service to collect certain information and monitor user activity on the Service, such as to count visits, understand usage effectiveness and to tell if an email has been opened and acted upon. Such technologies are used to collect aggregate statistics related to usage of the Service and do not collect Personal Data.

For more information on the available opt-out options and mechanisms, please refer to CHAPTER IV. YOUR CHOICE & CONTROL.

CHAPTER III. PERSONAL DATA DISCLOSURE TO THIRD PARTIES

We will not knowingly share the Personal Data we collect from you through the Service or Apps with third parties, except as described in this Policy or on the Service or Apps.

For example, we may share Personal Data as follows:

• with vendors, consultants, and other service providers such as a credit card processing company to bill you for services, a forum provider for hosting our public forums, and an email service provider to send out emails on our behalf ("Service Providers"). When you sign up for our services we will share your Personal Data only as necessary for the third party to provide that service;
• when you give us your consent to do so, including if we notify you on the Service or Apps that the information you provide will be shared in a particular manner and you provide such information;
• when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the applicable local laws or legal processes or to respond to lawful requests or legal authorities including, but not limited to, responding to lawful subpoenas, warrants, or court orders;
• when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to protect the rights, property, or safety of 4Sync Inc., our users, our employees, copyright owners, third parties or the public including, but not limited to, protecting 4Sync Inc. or our users from fraudulent, abusive, inappropriate, or unlawful use of the Service or Apps;
• to enforce or apply this Policy, the Terms, or our other policies or agreements;
• and in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where personally identifiable information may be disclosed or transferred as one of the business assets of 4Sync Inc.

You understand that when you use the Service, information you provide via the Service, information you grant access to by using the Service, as well as any information you share with individuals through the Service, will be available to other users and in some cases may be publicly available.

We are not responsible for the actions of Service Providers or other third parties, nor are we responsible for any additional information you provide directly to any other users or third parties, and we encourage you to become familiar with third-party privacy practices before disclosing information directly to any such third parties.

Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.

CHAPTER IV. YOUR CHOICE & CONTROL

1. Opting Out of Cookies

For details on how to opt out of data collection via Google Analytics, please refer to tools.google.com/dlpage/gaoptout.

For more information on how to opt out of cookies in your browser, please refer to www.allaboutcookies.org.

To opt out of data collection via mobile apps, please visit the DAA AppChoices page at youradchoices.com/appchoices.

2. Opting Out of Marketing Emails

You may "opt out" of receiving marketing or promotional emails from us by following the instructions in those emails. You may also opt out of such marketing emails by following the instructions within such emails or us at privacy@4sync.com. You may also log into your account and make the appropriate selections in the "Account Overview" tab in your 4Sync account on our Website.

If you opt out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.

3. Disconnecting Social Network Accounts

If you sign up for 4Sync using your Twitter, Facebook or Google account, your 4Sync account and your Twitter, Facebook or Google account respectively will be connected automatically.

The Social Networks tab within your account Settings on our Website enables you to control the information you share with social networks via connected accounts.

To opt out of your data collection by Facebook, Twitter and Google, use the "Disconnect" option in the Social Networks tab in"Settings" in your 4Sync account on our Website.

4. Withdrawing Consent to Personal Data Collection and Use

You may withdraw your consent to the collection and use of Personal Data via our Service and Apps - generally or with regard to the additionally voluntarily provided data in accordance with effect for the future.

However, in the event of your cancellation, certain features that require registration may no longer be provided. This does not apply to the revocation to collect further voluntary data, provided to us.

To withdraw your consent to the collection and use of your Personal Data by 4Sync, please send us a сorresponding request at privacy@4sync.com.

5. Access to Your Personal Data

If your Personal Data changes, or if you no longer wish to use our Service, you may correct, update or delete it by making the change in your account or contact us at privacy@4sync.com. We will respond to your access request within 30 days.

If you wish to request the deletion of an unauthorized profile, contact us at privacy@4sync.com. We will retain your Personal Data for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

CHAPTER V. SECURITY

We take reasonable measures to protect your Personal Data in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can guarantee against any interception or any other type of misuse.

To assist with the protection of Personal Data, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Service and Apps by any person using your password. Please advise us immediately if you believe your password has been misused. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Website, you can contact us at privacy@4sync.com.

CHAPTER VI. INFORMATION RELATING TO CHILDREN

Our Services and Apps are designed for people 18 years of age and older.

4Sync does not knowingly collect Personal Data from anyone under the age of 18. If 4Sync is made aware that it has received Personal Data from someone under the age of 18, it will use reasonable efforts to remove that data from its records.

CHAPTER VII. CROSS-BORDER DATA TRANSFER

We may transfer Personal Information to countries different from your country of residence, including to the United States of America, by or on behalf of our company in accordance with this Privacy Policy (see Chapters 3 and 5 for more details) and relevant privacy laws.

Cross-border data transfer is handled in accordance with our Terms of Service, Privacy Policy and relevant privacy laws for the purpose of fulfilling our obligations as a provider of cloud data storage and cross-platform data sync services within our Digital Properties.

CHAPTER VIII. LEGAL BASIS FOR PROCESSING PERSONAL DATA OF EEA AND SWISS INDIVIDUALS

4Sync is committed to compliance and adherence to Personal Data privacy and protection laws, rules and regulations, including:
(i) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation); (ii) regulatory guidelines; (iii) applicable self-regulatory guidelines.

If there is any conflict between the Terms of Use or other policies described in this Privacy Policy, the Policies covered in this Section shall govern.

1. Access to and Deletion of Personal Data

EEA and Swiss individuals have the right to access their Personal Data that 4Sync maintains, as that term is defined in EU data protection and privacy regulations, including GDPR principles, and may be able to correct or amend that information if it is inaccurate or has been processed in violation of the GDPR principles, to the extent allowed by applicable law.

EEA and Swiss individuals have the right to:

1. request access to and rectification or erasure of their Personal Data;
2. restrict the processing of Personal Data, object to processing, and/or exercise the right of Data portability; and
3. withdraw consent without affecting the lawfulness of processing and lodge a complaint with a supervisory authority.

To exercise this right, please send us a corresponding request at privacy@4sync.com.

For more information regarding 4Sync Users' Rights set out above, please contact us at privacy@4sync.com.

4Sync is committed to resolving of complaints about our collection or use of Personal Data. EEA or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact 4Sync at privacy@4sync.com.

2. Disclosure of Personal Data to Third Parties, Onward Transfer

4Sync may disclose and transfer Personal Data of EU and Swiss individuals received to third parties, as described in this Privacy Policy. The Personal Data disclosed will be used for the purposes set forth in this Privacy Policy.

You may request disclosure, notification of the intended purpose, correction, addition, deletion, and cessation of use or cessation of disclosure of your Personal Data to third parties by contacting us at privacy@4sync.com.

3. Notifying Third Parties about Personal Data Restriction, Rectification, Erasure

Where 4Sync has disclosed Personal Data of its User to any third parties, and the User has subsequently exercised any of the rights of rectification, erasure or blocking, 4Sync will promptly notify those third parties of the User's exercising of those rights. In no case 4Sync shall be liable for the failure of any third party to comply with such User's request.

4Sync is exempt from this obligation if it is impossible or would require disproportionate effort.

Where 4Sync has made its User's Personal Data public, and the User exercises any of the rights as described above, 4Sync will take reasonable steps to inform third parties that the User has exercised those rights.

4. Collection and Use of Sensitive or Special Categories of Personal Data

4Sync does not knowingly collect, store or in any other way process Sensitive Personal Data, such as:

• Personal Data, revealing racial or ethnic origin, religious or philosophical beliefs, political opinions, trade-union membership;
• Personal Data concerning health or sex life and sexual orientation;
• biometric data or genetic data;
• Personal Data of Children under the age of 18.

If 4Sync is made aware that it has received such Sensitive Personal Data, we will take reasonable steps to remove this Personal Data from our records.

CHAPTER IX. LEGAL BASIS FOR PROCESSING PERSONAL DATA OF U.S. RESIDENTS

4Sync is committed to compliance to Personal Data privacy and protection laws and regulations, including California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA) and others ("U.S. Privacy Laws").

If there is any conflict between the 4Sync Terms of Service or Privacy Policy, the Policies covered in this Section shall govern.

1. Personal Data Rights of the U.S. Residents

4Sync does not collect Personal Data from Users who do not have a registered 4Sync account.

We do not sell or share any of the Personal Data collected, or otherwise processed to third parties.

In accordance with U.S. Privacy laws, registered 4Sync Users regardless of their state of residence have the right to:

(i) access Personal Data 4Sync has collected from them,
(ii) request deletion of Personal Data collected.
(iii) request correction of Personal Data collected,
(iv) request limitation of use and disclosure of Sensitive Personal Data. 4Sync does not knowingly collect, store or in any other way process Sensitive Personal Data, such as Personal Data, revealing racial or ethnic origin, religious or philosophical beliefs, political opinions, trade-union membership; Personal Data concerning health or sex life and sexual orientation; biometric data or genetic data; Personal Data of Children under the age of 18.

If 4Sync is made aware that it has received such Sensitive Personal Data, we will take reasonable steps to remove this Personal Data from our records.

If you are a California resident, have a registered account at 4Sync, and wish to access or delete your Personal Data collected, please follow the instructions below:

To exercise any of these rights, please follow the instructions below:

1. Visit https://www.4sync.com in a web-browser on your desktop computer or notebook.
2. Sign in your 4Sync account.
3. Go to account "Settings".
4. Switch to the "CPRA" tab.
5. Select the option you need by checking the relevant box.
6. Click "Submit".

2. Processing of Children’s Personal Data

4Sync Services are intended for use by individuals 18 years of age and older.

If we are made aware that 4Sync has obtained Personal Data of Children below the age of 18 years, we will use reasonable efforts to remove this Data from our records.

CHAPTER X. LEGAL BASIS FOR PROCESSING PERSONAL DATA WITHIN THE TERRITORY OF BRAZIL

4Sync is committed to compliance and adherence to Personal Data privacy and protection laws, rules and regulations, including:

(i) Law 13,709/2018 of the Brazilian Congress (Lei Geral de Proteção de Dados Pessoais (LGPD), General Data Protection Law, "GDPL"); (ii) regulatory and applicable self-regulatory guidelines.

If there is any conflict between the Terms of Use or other policies described in this Privacy Policy, the Policies covered in this Section shall govern.

For more information, please refer to 4Sync LGPD compliance policy.

CHAPTER XI. LEGAL BASIS FOR PROCESSING PERSONAL DATA OF CHINESE RESIDENTS

4Sync is committed to compliance and adherence to Personal Data privacy and protection laws, rules and regulations, including:

• Personal Information Protection Law ("PIPL") of the National People's Congress of the People's Republic of China ("PRC"),
• other applicable regulatory / self-regulatory guidelines.

If there is any conflict between the Terms of Service or other policies described in this Privacy Policy, the Policies covered in this Section shall govern.

For more information, please refer to 4Sync PIPL Compliance Policy.

CHAPTER XII. LINKS TO OTHER WEBSITES

The Service may contain links to other websites. Any Personal Data you provide on the linked pages is provided directly to that third party and is subject to that third-party's privacy policy.

This Privacy Policy does not apply to such linked websites, and we are not responsible for the content or privacy and security practices and policies of these websites or any other websites that are linked to/from the Service. We encourage you to learn about their privacy and security practices and policies before providing them with personally identifiable information.

Chapter XIII. MODIFICATIONS

We reserve the right to change our Privacy Policy from time to time.

If we make any changes to this Policy, we will change the "Last Revised" date, and in some cases we may provide you with additional notice.

Your continued use of our Website and Services constitutes your acceptance of the Policy then in effect.

CHAPTER XIV. QUESTIONS TO THIS PRIVACY POLICY

If you have any questions about this Privacy Policy, please contact us at privacy@4sync.com.