Personal Data provided by you

• Personal data about you upon registration - You will be asked to provide your email address to establish an Account.
• Personal data that you choose to provide us to obtain additional Services or specific online Services – If you request to participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you.

We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Policy.

Personal Data as you use our Site or Services

We will collect information about you as you use the Site or Service, such as your IP address, browser type and version, operating system, referral source and device information.
Through tracking services, we will collect information about you such as length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your usage, operating system, device information, behavior, visited pages, etc. This anonymous information can not be identified directly with you.
We collect information about purchases you've made through our Site or Services, such as product type, subscription type, date of purchase, etc.

Personal Data about you if you visit as a guest

Certain limited Services are available without being required to log in to or establish an Account, also referred to as Guest Usage. Such is visiting our trade site, accessing a download or upload link and others. We will collect information about you such as length of visit, page views and navigation paths, as well as information about the timing, frequency and pattern of your service usage, operating system, device information, behavior, visited pages. This anonymous information can not be identified directly with you.

Personal Data about you from third-party sources

• Personal Data from payment processors: we will collect information about you from payment providers when you purchase products offered on the Site or Service. Information varies per payment providers but might include: your IP address, country, email, post code, name, last four digits of your card.
• Personal Data about your friends and contacts – It may be easier to share content with your friends and contacts if you provide their email addresses while using the Service or if you connect your contact list or friend list to your Account. If you choose to connect your contact list information on your device with your Account and/or establish an account connection between a social media platform and your Account, we will collect and use your contact list or friend list information to show suggestions when you want to share content from your pCloud with someone.
• Personal Data from your accounts for other services - You have the option to back up content from various services you use. In this case you will be asked to authorize access to your third party services' accounts. Upon this event we might receive various Personal Data about you, depending on the named service's Privacy Policy.
• Personal Data about you when you register with third party services - When you choose to establish an Account at pCloud with a third party service, we might receive information about you such as name, language, gender and other, depending on the access permissions you allow.

3. Why Do We Retain Personal Data?

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal data in accordance with this Privacy Policy.

4. How Do We Process Personal Data?

We may Process your Personal Data for a variety of reasons that are justified under data protection laws in the European Economic Area (EEA) and Switzerland.

To operate the Sites and provide the Services, including to:

• initiate a payment
• authenticate your access to Account.
• communicate with you about your Account, the Sites, the Services, or pCloud.
• create an account connection between your Account and a third-party account or platform.

For our legitimate interests, including to:

• enforce the terms of our Sites and Services;
• manage our everyday business needs, such as monitoring, analyzing;
• anonymize Personal data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services.
• to manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality.
• to manage risk and protect the Sites, the Services and you from fraud by verifying your identity, and helping to detect and prevent fraud and abuse of the Sites or Services.
• to comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

With your consent, including to:

• to market to you by delivering marketing materials about pCloud products and online Services. We may also Process your Personal Data to tailor certain Services or Site experiences to better match our understanding of your interests.
• to provide personalized Services offered by pCloud on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature or offer to you on third-party websites. We may use tracking technologies to provide these online services and/or work with other third-parties such as advertising or analytics companies to provide these online services.
• to respond to your requests, for example to contact you about a question you submitted to our customer service team.

You can withdraw your consent at any time and free of charge. Please refer to the section on “Your Privacy Choices” for more information on how to do that.

5. Do We Share Personal Data?

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy. We may share your Personal Data or other information for the following reasons:

• with payment providers in order to initialize a payment process - personal data necessary to facilitate the transaction;
• with third party services monitoring the proper functioning of the service - Anonymous data and performance analytics to help us enhance Users’ experiences.

We may share information about you with other parties for pCloud’s business purposes or as permitted or required by law, including:

• if we need to do so to comply with a law, legal process or regulations;
• to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to pCloud;
• if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
• to protect the vital interests of a person;
• to investigate violations of or enforce a user agreement or other legal terms applicable to any Service;
• to protect our property, Services and legal rights;
• to facilitate a purchase or sale of all or part of pCloud’s business;
• to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants;
• to companies that we plan to merge with or be acquired by; and
• to support our audit, compliance, and corporate governance functions.

With your consent:

• We share your Personal Data and other information with your consent or direction, including if you authorize an account connection with a third-party account or platform.
• We share your Personal Data with advertising and analytical companies to deliver information relevant to you about new features and offers.

Profile Information You Make Available to Others:

• By using the Site or the Services you may make certain of your Personal Information available to others. For example, your email address will be visible when you share a file or a folder with another user of the Site or Services. You should therefore ensure that any person who you share a file or folder with is someone who you are happy to share your email address with.

In addition, pCloud may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services.

We do not share your Personal Data with third parties for their marketing purposes.

6. Selling data to third parties

We do not, have not and do not have any future plans to sell your personal information to third parties.

7. Automated decision making and profiling

We use the information about you and your usage of the service:

• to send you automated messages or notifications relevant to your user experience.
• to run usability and A/B tests to help us improve our service.

8. Processing in the EU and the US

You may choose to store your information on secure servers in the European Union or the United States. If you choose to store your information in the United States you are causing your Personal Data to be transferred to our servers located in the United States. The laws of the United States may not be as protective of your privacy as those of the European Union. Furthermore, if you are outside the United States and the European Union, the laws of these jurisdictions may not be as protective of your privacy as the laws of your location. You can change where your data is stored, and choose to have your data stored in the European Union or the United States, by using the options available in your account settings. By using our Site or Services and submitting Personal Information via the Site, you understand that the collection, use, transfer, and disclosure of your Personal Data shall be governed by applicable laws in the European Union and United States.

9. How Do We Use Cookies and Tracking Technologies?

We use cookies (a small text file placed on your computer to identify your computer and browser) on the Site. We use cookies to improve the experience of the Site and Services, such as pre-populating your username for easier login and preserving your user session. We do not use cookies to collect Personal Information. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. pCloud's cookies are automatically deleted after 1 year.

10. Do we process special categories of personal data?

pCloud does not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

11. What Privacy Choices Are Available To You?

At pCloud, we want to give you maximum control over your personal data. Learn here how you can manage your information.

12. What Are Your Rights?

In this section, we have summarized the rights that you have under data protection law. For a more detailed explanation of your rights, please refer to the relevant laws and guidance from the regulatory authorities.

The right to be informed
pCloud’s Privacy Policy describes our practices in detail using simple language. Everything you need to know is here. If you have more questions, feel free to contact us at privacy@pcloud.com.

The right to rectification
If you believe we have the wrong data about you, or that your data is incomplete, feel free to change it at any time through your Account settings. Learn here how you can manage your information.

The right to erasure
When you delete your pCloud account your data and files are deleted from your devices without undue delay.

The right to restrict processing
You can temporary restrict the processing of your data by suspending your account. Suspended accounts are kept for 3 months, unless specifically stated otherwise. During this period the account can be restored at any time and information or files will be lost. At the end of the period non-restored accounts are deleted automatically and information is deleted. Contact us at privacy@pcloud.com to request account suspensions by stating your reasons.

The right to data portability
Contact us at privacy@pcloud.com to request a copy of the data we store about you. Once it is ready, you will receive the file via email.

The right of access
Read our privacy policy for details about what data is processed by us. Contact us at privacy@pcloud.com if you have further questions.

The right to object
On top of the ability to opt out of processing by changing your settings, you can object to the processing of certain forms of data, as described in Privacy Options. Contact us at privacy@pcloud.com if you have further questions.

The right to appeal automated decisions and profiling We may make an automated decision to block a user, in case we suspect this user is using our services for illegal acts or acts that violate our terms of use. If you believe that your account was unlawfully blocked, you can contact our support team.

The right against discrimination
If you’re a resident of California, United States, you have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the California Consumer Privacy Act (CCPA).

Note that filing multiple claims might be subject to a fee, not exceeding 10 GBP.

13. How Do We Protect Your Personal Data?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised.

In the unlikely event that a security breach which affects individuals’ rights and freedoms is discovered, according to our risk assesment policy, pCloud will inform those individuals without undue delay.

14. Can Children Use Our Services?

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18. If we become aware that we have inadvertently received Personal Information from a child under the age of 18, we will delete such information from our records.

15. Updates or Changes in Processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

We keep this Privacy Policy under regular review and we will place any updates on this web page https://www.pcloud.com/privacy_policy.html.

In other circumstances, if we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will become effective on the revision date, shown in the revised Privacy Policy. Your continued use of our Site or Services constitutes your consent to the revised Privacy Policy.

16. Contact Us

You may contact us if you have general questions or concerns about this Privacy Policy and supplemental notices or the way in which we handle your Personal Data.
Our Data Protection Officer can be contacted at privacy@pcloud.com

17. Definitions

Account means a pCloud member account.

Device Information means data that can be automatically collected from any device used to access the Site or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Site or Services;

Guest Usage means a person’s Use of the Services without logging into and/or establishing an Account.

pCloud means pCloud AG, LTD and subsidiaries or affiliates. In this Privacy Policy, pCloud is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. “Personal Data” can include, but is not limited to, name, telephone number, email address, date of birth.

Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by pCloud with an Account or Guest Usage.

Sites means the websites, mobile apps, official social media platforms, or other online properties through which pCloud offers the Services and which has posted or linked to this Privacy Policy.

Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies.

User means an individual who uses the Services or accesses the Sites and has established a relationship with pCloud (for example, by opening an Account and agreeing to the pCloud Terms of Service) or otherwise uses the Services for Guest Usage.

Revised: 1 April 2020