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Privacy Policy

Legal document explaining BrickFTP's commitment to protecting your privacy.

Last Updated: September 8, 2016

Thank you for visiting this web site of Action Verb LLC (hereinafter “We”). We recognize that your data is very personal and sensitive. This Privacy Policy explains our commitment to protecting your privacy, with regard to your use of ("Web Site") and the BrickFTP™ asset hosting service available from the Web Site ("Service").

Please read this Privacy Policy before using this Web Site or Service or submitting any personal information. California residents, please also see the “Note to California Residents” Section for additional rights that apply to you.

By using this Web Site and/or Service, you accept privacy practices contained in this Privacy Policy. You are encouraged to review the Privacy Policy whenever you visit the Web Site to make sure you understand how any personal information you provide will be used.

1. 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").

In order to serve our customers, we collect personally identifiable information, such as names, addresses, phone numbers, email addresses, and sometimes credit card information when our visitors voluntarily submit such information. This includes information from those who communicate with us via e-mail or this Web Site, 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"). We will only use your personally identifiable information for the following purposes: (1) to deliver the products and/or services to you that you have requested; (2) to validate your compliance with the terms and conditions; (3) for content improvement and feedback purposes; (4) to reach you, when necessary, regarding your use of the Web Site or Service; and (5) for the few situations described below to better serve you.

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.

2. 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.

E-Mail addresses collected will be used to communicate with you regarding the Service. We communicate such things as announcements of new features, changes to Terms of Use/Privacy Policy, information about pricing changes or systems outages, and other Service-related announcements. You can cancel your participation in any of these email lists at any time by clicking the Unsubscribe link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.

By submitting your email address, you also agree to allow us to use your email address for custom audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us.

Email or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader’s experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the locations (e.g. city, state, and county) associated with the applicable IP address.

We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies and other methods to help us study usage patterns on the Service. Information generated from your use of the Service will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of preparing reports regarding aggregate use of the Service. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

Third party retargeting networks may also use cookies to display our advertisements to you on other sites. You can opt-put of a third party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page.

Other parties such as advertising partners and analytics companies may also be collecting information about your online activity across various websites over time. The information collected by those third parties may include identifiers that allow those third parties to tailor the ads that they serve to your computer or other device.

If you visit this site and use OpenID or OAuth (such as Facebook or Google), you may also be sharing and integrating data with third-party social media sites, and we may track aggregate data about the number of visits to this site with an open ID, the number of items “liked” on this site, or items on this site that you choose to share with a third-party social media site.

Because there is not yet a common understanding of how to interpret web browser-based "Do Not Track" signals other than cookies, we do not currently respond to "Do Not Track" signals that are undefined.

Please note that you do have the option to configure most web browsers to not accept cookies. However, be aware that disabling cookies may keep you from having access to some functions or services on our Web Site or with our Service.

You agree that by submitting your telephone contact information on this web site and/or registering to receive the Service offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the Amended Telemarketing Sales Rule (ATSR), 16 CFR ‘310 et seq. and any applicable state and local "do not call" regulations. We retain the right to contact you via telemarketing in accordance with the ATSR and the applicable state regulations.

Unless you request otherwise, we may use the name of your company and screenshots from your website in advertisements promoting BrickFTP™.

All information may be disclosed when legally required to do so, at the request of governmental authorities conducting an investigation, to verify or enforce compliance with the Terms of Use and policies governing the Service and applicable laws or to protect against misuse or unauthorized use of the Service.

If the ownership of all or substantially all of Action Verb LLC, or individual business units associated with the Service, were to change, your user information may be transferred to the new owner so the service can continue operations. In any such transfer of information, your user information would remain subject to the promises made in this Privacy Policy. In the event of such transaction, we will alert BrickFTP™ paying customers of such change via E-Mail, and provide an opportunity to cancel or change your service.

3. Our Access To Your Site Content and Metadata

We have implemented controls designed to prevent our employees or contractors from improperly using your data for purposes other than those set forth in this Privacy Policy.

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.

These people are all Action Verb LLC employees (not contractors) located in the United States who have agreed to uphold this Privacy Policy (and its promise to not access your User Content). If they fail to preserve this confidence, they are subject to disciplinary action, including losing their job, and potential criminal prosecution.

As of May 10, 2016, 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.

4. Technology

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.

5. EU-US Privacy Shield Framework

Action Verb LLC Complies with the EU-US Privacy Shield Framework as set forth by the US 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 Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit

Our Privacy Shield commitment applies to the following types of data collected: "Site Content", "Site Metadata", and "Registration and Billing Data". Under Privacy Shield, you have a right to remove, access, or correct this data. See Paragraph 6 of this Policy to learn how to remove your data.

In compliance with the EU-US Privacy Shield Principles, Action Verb LLC commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact Action Verb LLC at: 8605 Santa Monica Blvd #20898, West Hollywood, CA 90069, United States, or by telephone at +1 (800) 286-8372 or by e-mail at [email protected]

Action Verb LLC has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and 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, please visit for more information and to file a complaint.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Action Verb LLC's is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, Action Verb LLC is potentially liable.

6. Removing Information

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 7 days 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 30 days after deletion or account cancellation.

We do not support removal of Registration and Billing Data, Correspondence Data or Usage Data.

You have the right to obtain our confirmation of whether we maintain personal information relating to you. Upon request, we will provide you with access to the personal information that we hold about you. You may also may correct, amend, or delete the personal information we hold about you. Your right to access your Personal Data may be restricted in exceptional circumstances, including, but not limited to, when the burden or expense of providing this access would be disproportionate to the risks to your privacy in the case in question, or when the rights of persons other than you would be violated by the provision of such access. If we determine that your access should be restricted in a particular instance, we will provide you with an explanation of our determination and respond to any inquiries you may have.

We do not knowingly intend to collect personally identifiable information from children under 18 years of age. If your minor child has provided us with personally identifiable information, you may contact us at the phone number or mailing address listed in Section 9 herein if you want this information deleted from our records. We will then make reasonable efforts to remove your child’s information from the database that stores the information.

7. Other Provisions

Your use of the Service is governed by a Terms of Service, which will prevail in the event of a conflict with this document, except with respect to EU-US Privacy Shield provisions.

This Privacy Policy does not describe information collection practices on other third party sites, including those linked to or from the Web Site. We do not control and are not liable for actions of any third parties who we may promote and/or link to from this Web Site. We pride ourselves in recommending quality companies, but have no control over the actions of those third parties, the content they provide, or their privacy practices. While we are not liable for any of the actions of those third parties, you should feel free to give us feedback from time to time on your experiences with any third parties to whom we work with so that we may enhance our future service to all customers.

We use third parties to facilitate our business, such as server hosting, file hosting, and payment processing. In connection with these offerings and business operations, our service providers may have access to your information for use for a limited time in connection with these business activities. Where we utilize third parties for the processing or storing of any information, we have ensured that they will fully comply with this Privacy Policy.

8. Changes to this Privacy Policy

Action Verb LLC reserves the right to change this Privacy Policy at any time by posting a new Privacy Policy at this location and alerting BrickFTP™ paying customers of such change via E-Mail. Any change(s) to this Privacy Policy will take effect thirty (30) days after such changes have been posted. Your continued use of the Service following such changes will indicate your acceptance of those changes.

This document was last updated according to the date at the top of this page.

9. Contact Us

Action Verb LLC regularly reviews its compliance with this policy. Questions regarding the Privacy Policy should be sent by e-mail to us using our online contact form. Alternatively, you may call us at (800) 286-8372 or write to us at Action Verb LLC, ATTN: Privacy Policy, 8605 Santa Monica Blvd #20898, West Hollywood, CA 90069.

10. Note To California Residents

If you live in the State of California, under the California Civil Code, you have the right to request that companies who conduct business in California provide you with a list of all third parties to which the company has disclosed Personal Information during the preceding year for direct marketing purposes.

Alternatively, the law provides that if a company has a Privacy Policy that gives either an opt-out (often referred to as “unsubscribe”) or opt-in choice for use of your Personal Information by third parties (such as advertisers or affiliated companies) for marketing purposes, that the company may instead provide you with information on how to exercise your disclosure choice options.

This Site qualifies for the alternative option; it has a comprehensive Privacy Policy and provides you with details on how you may either opt-out or opt-in to the use of your Personal Information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your Personal Information for marketing purposes during the preceding year.

If you are a California resident and want to request information about how to exercise your third party disclosure choices, you must send a request using the online contact form listed in Section 9 above.

All requests must be labeled "Your California Privacy Rights" on the subject of the actual request. For all requests, please include your name, street address, city, state, and zip code. Please include your zip code for our own recordkeeping.

Requests that are improperly labeled or that are missing the required information will not be processed.