Information We Collect
We treat different types of information differently.
One type of information we collect is the actual contents of the files uploaded to your BrickFTP™ account ("Site Content").
Additionally, we collect "metadata" about your Site Content that is distinct from the actual content itself ("Site Metadata"). Site Metadata includes file and folder names, modification dates, permissions, size information and history notification. Site Metadata also includes usernames, group names, user and group settings, and site-wide settings.
Site Metadata does not include passwords used by users to access the Service. These passwords are stored in a salted, encrypted format, unless you specifically request that they be stored in cleartext.
We also collect usage information customarily logged by web and FTP server software, including the date and time of your visit, the originating IP address, the pages and images requested, and other similar types of information ("Usage Data").
Additionally, we collect information from those who communicate with us via e-mail or our website, and information volunteered by consumers, such as the information you provide during account registration and signup ("Registration and Billing Data"), and contact form submissions and E-Mails ("Correspondence Data").
How Information is Used
"Site Content" is stored securely and may only be accessed by users on who have been given the appropriate permissions to that Site Content by someone with Site Admin permissions on the account. We will not access this data for any other purpose, except as provided below.
"Site Metadata" is used by our software systems to provide the Service and may be displayed, subject to our permissions controls, to users on the account.
"Usage Data" and "Correspondence Data" is used to help us understand how the Service and our websites are being used and to help us improve our websites and the Service.
"Registration and Billing Data" is used for billing purposes and to notify you about important service-related notices.
Unless you request otherwise, we may use the name of your company and screenshots from your website in advertisements promoting BrickFTP™.
Our Access To Your Site Content and Metadata
Our front-line employees and contractors, such as customer service agents, do not have any access to your "Site Content". They do, however, have access to "Site Metadata". They will only access "Site Metadata" for the purpose of providing customer support upon request.
We may use aggregated information about "Site Metadata" for the purpose of improving the Service. Please name your files such that the mere names of files or folders do not reveal confidential information.
We promise not to access your Site Content for any purpose. However, we feel compelled to note that due to the nature of the job, our software developers and database and server administrators may have access to your Site Content while logged in directly to our application servers.
As of September 16, 2013, there are four people at Action Verb, LLC with this level of access to our application servers, and all of whom have a legitimate business need to be able to access our application servers.
All access to our application servers by our employees is logged.
Wherever possible, browsing sessions to the Service are secured with SSL, to prevent eavesdropping, tampering, and message forgery. If SSL is enabled, you will see a lock icon in your browser.
You may choose whether to disable SSL or require SSL for your connections to the Service. We recommend always using SSL.
Cookies: Use of the Service requires support for cookies, small pieces of data that are stored on your computer's hard drive and transmitted back to the Service with each web page request. A cookie simply identifies your browser to the Service by assigning it a unique ID number, which enables us to associate your session with your account.
U.S.-EU Safe Harbor Framework
Action Verb, LLC complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Action Verb, LLC has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/
Action Verb, LLC
ATTN: EU Safe Harbor
PO Box 29502 #20898
Las Vegas, NV 89126
Action Verb, LLC has further committed to refer unresolved privacy complaints under the US-EU Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Action Verb, LLC, please visit the BBB EU SAFE HARBOR web site at http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
You may use the Service to delete any of your "Site Content," and doing so will remove such content from our active servers immediately. If you have configured backup retention after deletion for your "Site Content", backups may remain on our backup servers for the period of time that you specified as the backup retention period.
All of your "Site Content" and "Site Metadata" will be deleted from our active and backup servers within 24 hours when you cancel your account.
Because of our efforts to ensure Service availability, we maintain backup copies of all Site Metadata. As a result, residual copies of your "Site Metadata" may remain on backup media, backup servers, and disk snapshots for up to six months after deletion or account cancellation.
We do not support removal of Registration and Billing Data, Correspondence Data or Usage Data.
Your use of the Service is governed by a Terms of Service, which will prevail in the event of a conflict with this document.
This document was last updated on September 16, 2013.