Privacy Policy

Privacy Policy

We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data.

This Privacy Policy aims to give you information about how we collect and process your personal data when you visit our websites (including subdomains of our websites) and any software applications, APIs, infrastructure, or services through which we make our offerings available (collectively, the “Platform”). This Privacy Policy applies regardless of where you visit our Platform from and applies to any data that you may provide through our Platform, when you purchase our products/services, or when you otherwise interact with us. ‍ Our Platform is not intended for children, and we do not knowingly collect data relating to children. Please read this Privacy Policy carefully to understand how we collect, use, disclose, and protect your personal data and the rights you have in relation to your personal data. It is important you read this Privacy Policy together with any other Privacy Policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them. References to “you” or “your” are to you as an individual using our Platform or otherwise contacting us (whether on behalf of yourself, or another individual or organisation).

1. INFORMATION ABOUT US Our Platform is owned and operated by Filedgr, a Luxembourg private limited liability company (société à responsabilité limitée) having its registered office at 40, rue Glesener, L-1630 Luxembourg and registered with the Luxembourg Register of Commerce and Companies under number B274857 (“Filedgr”, “we”, “us”, or “our”).

For personal data that we process for our own purposes, such as providing and administering our Platform, Filedgr is the data controller. Where we process personal data solely on behalf of a client that uses our products or services, we may act as a data processor and the relevant client will generally be the data controller. Where we are processing your personal data on behalf of our client, you should refer to our client’s privacy policy, which will inform you as to how your personal data is processed.

We are bound by applicable data protection laws in respect of the handling and collection of your personal data. We are a data controller within the meaning of the 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 on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

2. OUR CONTACT DETAILS If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details below:

Email address: privacy@filedgr.com

3. WHAT PERSONAL DATA WE COLLECT ABOUT YOU Personal data or personal information means any information about you that enables you to be identified personally.

Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers that can be linked with such information in order to identify you. It does not include data where the identity has been removed (anonymous data).

Depending on how you use our Platform, we may collect, use, store and transfer different kinds of personal data about you, including:

a. Account Data includes your email address, wallet address, profile photo, username or other account identifiers associated with your Filedgr account.

b. Technical Data includes your internet protocol (IP) address, login information, browser type and version, time zone setting, operating system, device information, push notification tokens, crash logs, diagnostic data, and other technology used to access our Platform.

c. Usage Data includes information about how you use our Platform or products/services.

d. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

e. User-Provided Content includes documents, records, files, and other information that you choose to upload, store, or otherwise provide through your Filedgr Vault or other Platform services. We process User-Provided Content to provide and operate the services you request and may use third-party infrastructure and storage providers to securely store and process this data on our behalf. Where we act as a data processor, we process such data in accordance with your instructions and applicable contractual requirements. User-Provided Content is retained in accordance with our retention practices and your deletion requests, subject to applicable legal or regulatory requirements.

Where you make payments or purchase a subscription, payment-related personal data such as your name, billing address, and payment information may be collected and processed directly by our third-party payment provider, Stripe. Filedgr does not store your full payment card information or payment details.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law and will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature of our Platform or aggregate statistics about the behaviour of visitors and users of Filedgr API. However, if we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

4. IF YOU FAIL TO PROVIDE PERSONAL DATA

Where certain personal data is necessary to create or maintain your Filedgr account or provide specific features or services, you may not be able to use those features or services if you do not provide the required information. The information required may depend on how you access and use the Platform, including whether you create or access an account using a third-party wallet.

5. HOW WE COLLECT YOUR PERSONAL DATA We use different methods to collect data from and about you, including through:

a. Direct interactions. You may give us your personal data by entering information on our Platform e.g., when registering for Filedgr API, filling in forms or questionnaires, subscribing to our service or publications, by corresponding with us by phone or email, or by otherwise directly interacting with us.

b. Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

c. Third parties or publicly available sources. We may receive personal data about you from third parties and publicly available sources where necessary to provide, operate, secure, or improve our Platform. These may include technology and payment service providers, analytics providers, business partners, and publicly available blockchain networks.

As part of our Web3 and blockchain integrations, we may collect personal data from publicly available sources such as public blockchains (including, but not limited to, the XRP Ledger, Polygon, and Ethereum networks). Furthermore, if you interact with our Platform using third-party wallet applications (such as the Xaman Wallet operated by XRPL Labs, MetaMask, or other Web3 wallets), we may receive personal data about you from those third-party providers. You should refer to the respective privacy policies of those third-party wallet providers for more information on how your personal data is processed by them.

6. PURPOSES FOR PROCESSING PERSONAL DATA We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: a. Where we need to provide products/services or information to you or to perform the contract we are about to enter or have entered with you. b. Where we have a legal or regulatory obligation we must comply with. c. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests may include operating, securing, improving, and developing our Platform and services, communicating with users about our services, and protecting our business and users from fraud, misuse, or security threats. Generally, we do not rely on consent as a legal basis for processing your personal data. Where we rely on your consent to process your personal data, you may withdraw your consent at any time by contacting us at privacy@filedgr.com. Withdrawal of consent will not affect the lawfulness of any processing carried out before your consent was withdrawn.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

7. MARKETING We may send you marketing communications by email about Filedgr, our products, services, and related offerings. We will generally ask for your consent before sending you marketing emails. Where permitted by applicable law, we may also send marketing communications to existing customers or individuals who have previously expressed an interest in our services where we have a legitimate interest in doing so.

You will always have a clear and easy way to opt out of marketing communications when you provide your contact details and in every marketing email we send.

We will obtain your express consent before sharing your personal data with a third party for that third party's own marketing purposes.

Opting out of marketing:a. You can ask us to stop sending you marketing messages at any time by following the unsubscribe or opt-out link in any marketing message sent to you or by contacting us at privacy@filedgr.com.
b. Where you opt out of receiving marketing messages, this will not affect other communications necessary to provide our products or services, or communications relating to transactions or your account.
c. Where we rely on your consent for marketing, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before your consent was withdrawn.

8. AUTOMATED DECISION MAKING Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you.

We do not make any automated decisions.

9. HOW WE MAY SHARE YOUR PERSONAL DATA We may share your personal data with certain parties as set out below:

a. External third parties such as:
i. Professional advisors including lawyers, bankers, auditors, and insurers.
ii. Luxembourg and/or European VAT and tax authorities, regulators, and other authorities.
iii. Service providers and subcontractors/sub-processors such as:

• Hubspot (https://www.hubspot.com/) for service desk, sales and marketing services
• Google Analytics (https://analytics.withgoogle.com/) for app analytics, diagnostic crash reporting, push notifications, and for marketing and advertising services
• Stripe (https://stripe.com/) for payment processing and subscription management services
• Web3Auth (https://web3auth.io/) for user authentication and wallet connection services.
• Firebase (https://firebase.google.com/) for app analytics, diagnostic crash reporting, and push notifications.
• Amazon Web Services (https://aws.amazon.com/?nc2=h_lg) and Google Cloud (https://cloud.google.com/) for backend infrastructure services including hosting and storage services 

b. Business transfers. If Filedgr is involved in a merger, acquisition, restructuring, sale of assets, or similar transaction, your personal data may be transferred as part of that transaction. Any successor or acquiring entity will be required to handle your personal data in accordance with applicable data protection laws.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers. We may need to share your personal data outside Luxembourg and/or EEA, for example, where our third parties are based in other countries. Whenever we transfer your personal data out of Luxembourg and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented: a. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. b. If we transfer your personal data to any other country which is not subject to an adequacy decision of Luxembourg or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in Luxembourg or the EEA (as applicable). c. Where we use certain service providers outside of Luxembourg and/or the EEA (as applicable), we may use specific contracts approved for use in Luxembourg and/or the EEA (as applicable) which give personal data the same protection it has in Luxembourg and/or the EEA (as applicable).

10. DATA SECURITY We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

11. HOW WE RETAIN YOUR PERSONAL DATA We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing our services to you and satisfying any legal, regulatory, tax, accounting or reporting requirements.

We may retain your personal data for a longer period in the event of a complaint if we reasonably believe there is prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data (see your legal rights below).

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Otherwise, we securely erase or anonymise your personal data where we no longer require your information for the purposes collected.

12. ACCOUNT AND DATA DELETION

You can delete your account through the account settings in the Filedgr app or by contacting us at privacy@filedgr.com. When you request deletion, your device will be signed out and app data stored on the device, including session, PIN, and biometric unlock data, will be removed immediately.

Your account and any remaining personal data will be permanently deleted within 30 days of the deletion request. For legal or regulatory reasons, we may need to contact you directly before the deletion is complete. We may request additional information from you where necessary to verify your identity before processing your request.

Once your account and data have been deleted, the deletion cannot be undone. Certain information may be retained where required by law or where another lawful basis for retention applies.

Please note that Filedgr does not intentionally publish directly identifying personal data, such as your name or email address, to public blockchains. However, blockchain-related information, including wallet addresses, transaction hashes, timestamps, and content identifiers, may remain recorded on the applicable blockchain after account or data deletion. Such information cannot be deleted or altered by Filedgr. Where such information constitutes personal data under applicable law, Filedgr will treat it in accordance with its legal obligations. Filedgr does not control decentralized blockchain networks and therefore cannot remove information that has been recorded on them.

13. YOUR LEGAL RIGHTS

You have certain rights regarding the personal data we hold about you, subject to applicable data protection laws and any applicable limitations. These rights may include:

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may ask us to correct inaccurate or incomplete personal data.
• Erasure: You may ask us to delete your personal data where we no longer have a lawful reason to retain it.
• Restriction: You may ask us to restrict how we process your personal data in certain circumstances.
• Objection: You may object to certain processing of your personal data, including processing based on our legitimate interests or for direct marketing.
• Data portability: Where applicable, you may request certain personal data you have provided to us in a structured, commonly used and machine-readable format.
• Withdrawal of consent: Where we rely on your consent, you may withdraw that consent at any time.

To exercise any of these rights, please contact us at privacy@filedgr.com. We may request information necessary to verify your identity before processing your request. These rights are subject to applicable legal conditions and exceptions.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular the National Commission for Data Protection (Commission nationale pour la protection des données or "CNPD") in Luxembourg, or the supervisory authority in the country where you live, work, or believe that an infringement of data protection law has occurred.

14. THIRD-PARTY LINKS

Our Platform may contain links to third-party websites, services, or applications that are not operated or controlled by Filedgr. We are not responsible for the privacy practices or content of those third parties. We encourage you to review the privacy policies of any third-party services you access through links on our Platform.

15. UPDATES TO THIS PRIVACY POLICY

We keep this Privacy Policy under regular review and may update it from time to time to reflect changes to our services, data processing practices, or applicable legal requirements. Any changes will be posted on our Platform. Where appropriate, we will provide additional notice of material changes.

‍ DISCLAIMER: The contents of our websites (including subdomains of our websites) and applications, APIs, and infrastructure through which we make our products/services available (together, the “Platform”) are provided for general information only. It is not intended to amount to advice on which you should rely. You must obtain professional or specialist advice before taking, or refraining from, any action on the basis of the content on the Platform. Although we make reasonable efforts to update the information on our Platform, we make no representations, warranties or guarantees, whether expressed or implied, that the content on our Platform is accurate, complete or up to date. If you enter into any financial or blockchain-based transactions pursuant to, or in connection with, material you have seen on our Platform, note that such transactions will be conducted solely through the underlying public blockchain networks (including, but not limited to, the XRP Ledger, Polygon, and Ethereum networks) and are entirely separate from our Platform. We have no insight into and have no control over any such transactions, nor do we have any ability to reverse or amend such transactions. With that in mind, we will have no liability to you or any third party for any claims or damages that may arise as a result of any such transactions that you may enter into.

© 2026 Filedgr SARL Filedgr is a private limited liability company (société à responsabilité limitée), having its registered office at 40, rue Glesener, L-1630 Luxembourg and registered with the Luxembourg Register of Commerce and Companies (Registre de Commerce et des Sociétés) under number B274857.