Espresso.Social Ltd ("We") takes your privacy seriously. We are committed to handling your personal data that We process ("Data") in a transparent manner, in accordance with applicable laws and regulations, and to ensuring its confidentiality and security.

This Privacy Policy applies to the Data we collect about you as an individual through our website https://easyfiles.io and related cell phone location service ("Site"). By accessing and using the Site, you agree to this privacy policy and to the processing of Data as explained below. If you do not agree with this policy, please refrain from accessing and using Our Site.

This version is dated 22/06/2020. It may be updated from time to time, in which case you will be notified by email. Any access and use of the Site after being notified of the change implies your acceptance of such changes.

1. What is personal data?

Personal data is any data that can be used to identify an individual. Such data can either identify you directly (e.g., your first and last name, your email address) or indirectly by cross-referencing various information about you (e.g., your computer's IP address, your credit card or telephone number).

2. What type of Data about you do we collect and process?

Using the geolocation service requires you to register on our Site and, as such, the collection of the following Data:

• Your email address
• Your first name
• Your last name
• Your address
• Your city
• Your country

You may provide us with other Data when you interact with us through our contact page or otherwise, in which case the collection and subsequent processing is on your own initiative, and therefore with your consent.

This data, which, with the exception of your Internet Protocol address, does not contain personal data in the above sense, includes

• Device information: for example, your hardware model, operating system version or unique device identifier.

• Log Information: information collected automatically when you browse our Site in server logs includes your Internet Protocol address and device and event information (such as crashes, system activity, browser type, browser language, and the date and time of your browsing activities).

• Cookies and Similar Technologies: Cookies and similar technologies are used to collect and store information when you visit our Website, for example to identify your browser or device.

For more information and to learn how and to what extent you can prevent such automatic collection of information, please refer to our cookie notice.

3. For what purpose do we process your Data?

The Data that you provide to us by registering and using our Site is processed in particular for the following purposes

• to allow you to use the cell phone geolocation service offered by Our Site;

• to answer your questions when you contact Us directly

• to provide you with information about our products and services.

• improve the use and functionality of the Site;

• understand what services and products interest you;

• adapt and develop new products and services;

• correct errors;

• identify users who commit illegal acts or infringe our rights.

Your consent to the processing of your Data for these purposes may be withdrawn at any time by sending an e-mail to: contact@easyfile.io. Any such request will, however, be treated as a request to unsubscribe and terminate the contract between Us, and will be effective for the end of the current month.

4. With whom do we share your Data?

We may disclose and share some of your Data with:

• Service providers and processors that We use to ensure the proper functioning of the Site, in particular Our hosting provider and payment processing provider.

In this context, we use the services of the company GOOGLE LLC for hosting. For payment processing, we use the company Hipay, which holds your credit card number, to the exclusion of Espresso.Social Ltd, which never has access to it. For more information on how these companies handle your Data, please visit https://policies.google.com/privacy and https://hipay.com/fr/conditions-generales-dutilisation.

These suppliers may access and/or process your Data on Our behalf. In accordance with applicable legal requirements, We take commercially reasonable steps to require third parties to adequately protect your Information and process it only in accordance with Our instructions.

• Any third party to whom We have been ordered or required to disclose your Data due to a court order or governmental authority.

• Any entity that may intervene for emergency purposes that requires such disclosure.

• In addition, Espresso.Social Ltd may also be required to disclose your Data in order to comply with its legal obligations, pursuant to an order issued by a judicial or administrative authority, or in connection with legal proceedings.

Your Data will not be sold to third parties, in particular for marketing or promotional purposes.

5. Where is your Data stored?

We take steps to ensure that the Data collected is processed in accordance with this policy and applicable laws.

Your Data is hosted with GOOGLE LLC, whose servers are located in France. Notwithstanding the foregoing, your Data may occasionally be processed outside of France, in which case such transfer of data is done with your consent.

6. How do we protect your Data?

We are committed to ensuring the security of your Data.

To this end, we use a variety of technologies and security measures to protect your Data from unauthorized access, use, modification or disclosure at a level appropriate to the type of Data involved.

In addition, we endeavor to contractually ensure that the above-mentioned service providers we use handle your Data in an equally secure manner to ensure its confidentiality and integrity.

Despite our best efforts, it is not possible to fully guarantee the security of information exchanged over the Internet. Any data you transmit is done so at your own risk.

7. How long do we keep your Data?

We keep your Data for as long as you have a personal account. After you have unsubscribed, we may retain your Data if required by law or until any contractual claims made in connection with your account are time-barred.

8. Use of Cookies

When you first visit our Site, you may see a message at the bottom of the screen regarding the use of cookies. A cookie is then stored on your terminal so that your browser knows that you have seen this message and does not display it again on your next visit.

When browsing our Site, you have the option of accepting or refusing the use of cookies for statistical purposes. These cookies are used to evaluate the number of visitors and the use made of our Site by Internet users, in order to continuously improve its navigability and the relevance of the content offered.

By accepting cookies, the servers automatically record information of a general nature concerning your navigation. The statistical analysis of this information allows the continuous improvement of the site. It is carried out by Google Analytics.

The data collected are the IP address, the geographical origin, the date of the visit, its duration, the pages consulted and their sequence, as well as the pages shared on social networks. This data is anonymized and we do not analyze individual paths. We do not share it with other organizations for commercial purposes, nor do we pass it on to other sites.

You can indicate your agreement to the use of cookies either by selecting the "Yes, I agree" option provided to you or by simply continuing to browse Our Site. You may refuse the use of cookies by selecting the "No, I refuse" option, in which case you may not be able to use our Site.

All cookies that are used on Our Site have a lifetime of 30 days, after which they are automatically deleted. You may delete cookies at any time before this period expires by selecting the "delete/delete cookies" option in your browser settings. On your next visit, you will be asked to accept or decline the use of cookies.

9. Social Media and Other Websites

We may have a presence on various networks such as Facebook, Twitter, Pinterest, Instagram, LinkedIn, Youtube, etc. When you visit our page within these different networks, you should first read and understand the tools provided by these platforms that allow you to define how you intend to share your Data within these networks.

The privacy practices or policies of the relevant platforms apply there, and we encourage you to read their applicable privacy policies, terms of use and other information about how your Data is handled there.

In addition, our Site may contain references or links to other websites and social media, including through social media feeds; if you follow these links, you will leave our website. Access to and use of these sites is your responsibility. Espresso.Social Ltd has no influence on the form and content of the sites to which they link.

10. What rights do you have with respect to your Data?

You have the right to (i) submit an access request to find out what categories of Data we process about you, for what purposes, how we share it, and how long we keep it, provided that this information is consistent with the information given in this policy, (ii) ask us to rectify inaccurate Data about you, (iii) ask us to stop or limit the processing of your Data which, in practice, may need to be treated as a request to unsubscribe and terminate the contract between us.

If you wish to submit such a request or if you have any questions regarding such processing or this Policy, you may contact us by sending an email to: contact@easyfile.io.

You have the right to complain to the supervisory authority about the processing of your personal data.

If you are a resident of a country in the European Economic Area, the complaint can be filed with the data protection authority in your country.

11. Contact

If you have any questions in relation to this policy, you can contact: contact@easyfile.io.

12. Applicable law and jurisdiction

This policy is subject to English law, excluding federal private international law. Any dispute arising out of or in connection with this policy shall be subject to the exclusive jurisdiction of the Court of London in England.