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Privacy Policy

Version 1.6. Text matches the current portal agreement document.
Policy language:
FILE BUTLER™ Data Security and Privacy Policy Effective date: November 1, 2026 Last updated: November 1, 2026 1. Who we are and what this policy covers FileButler is a secure client portal operated by Envisage Companies, LLC ("Envisage," "we," "us"). This policy describes the personal information we collect through the FileButler website at filebutler.io and the FileButler client portal (together, the "Services"), how we use and protect it, and the rights you have over it. We act in two different roles: For account, billing, and usage information about the people who sign up for and use FileButler, Envisage decides how the information is used. This policy governs that information. For Customer Content, meaning the files, folders, messages, forms, and signatures a subscribing organization and its clients place in the portal, the subscribing organization controls the content and Envisage acts only as its service provider. We use Customer Content only to provide the Services to that subscriber and as this policy describes. The Services are operated from the United States. They are offered to business organizations in the United States, the European Union, Brazil, Mexico, and the South American countries listed in section 14. Sections 12 through 14 add the information the laws of those places require. Where one of those sections differs from sections 1 through 11, that section controls for the people it covers. 2. Personal information we collect, where it comes from, and why In the 12 months before the effective date, we collected the following categories of personal information. Passwords are never stored in readable form and are not a category we collect. Identifiers and contact details. Examples: Name, organization name, email address, telephone number, username. Source: You, or the subscribing organization that invites you. Purpose for collecting it: Create and manage accounts, send service messages, provide support. Billing information. Examples: Billing contact name, email address, billing address, card type, last four digits of the card, payment status. Source: You, through Stripe at checkout. Purpose for collecting it: Process subscription payments, send invoices, resolve payment disputes. Internet and device activity. Examples: Internet protocol address, device and browser type, sign-in activity, access logs, actions taken in the portal. Source: Collected automatically when you use the Services. Purpose for collecting it: Secure the Services, detect unauthorized access, keep audit records, support the subscriber's own compliance. Customer Content. Examples: Files, folder names, messages, forms, and signatures placed in the portal by a subscribing organization or its clients. Depending on what the subscriber uploads, this may include professional, employment, financial, or health information. Source: The subscribing organization and the clients it invites. Purpose for collecting it: Store, organize, deliver, and sign documents as the subscribing organization directs. Cookies and browser storage. Examples: Session identifiers, display preferences, cookie consent choices. Source: Collected automatically when you use the Services. Purpose for collecting it: Keep you signed in, secure your session, remember your settings. We collect personal information directly from you, from the subscribing organization that gives you access, automatically from your device when you use the Services, and from Stripe when you pay. We do not buy personal information from data brokers or other third parties. 3. How we disclose personal information We do not sell personal information, and we do not share it for cross-context behavioral advertising. We have not done so in the 12 months before the effective date, and we have no actual knowledge of selling or sharing the personal information of anyone under 16 years of age. We disclose personal information only for the business purposes below. Each service provider is bound by a written contract that limits its use of the information to the service it performs for us. Customer Content. Disclosed to: Backblaze, Inc. only (file storage). Business purpose: Store and deliver uploaded files and portal data. Identifiers, contact details, internet and device activity. Disclosed to: Backblaze, Inc. only (storage). Business purpose: Run the Services and keep security records. Billing information. Disclosed to: Stripe, Inc. (payment processing). Business purpose: Process payments and prevent fraud. Identifiers and Customer Content. Disclosed to: The subscribing organization that gave you access. Business purpose: Provide the Services to that organization. Any category, as required. Disclosed to: Professional advisers, law enforcement, courts, and regulators. Business purpose: Comply with law, respond to lawful requests, and protect our legal rights. Any category. Disclosed to: A successor in a merger, acquisition, or sale of the business. Business purpose: Continue the Services under the same commitments. We do not use or disclose sensitive personal information for any purpose other than providing the Services, preventing fraud and security incidents, and complying with the law. We do not disclose personal information to third parties for their own direct marketing purposes. No FileButler request sends Customer Content, tenant data, folder data, document data, or message content to any external artificial intelligence or model provider. 4. Cookies and online tracking The Services use only the cookies and browser storage needed to sign you in, keep your session secure, and store your display and consent preferences. A verification code is required at every sign-in; FileButler does not remember devices to skip it. We do not use advertising or behavioral tracking cookies, and analytics cookies are not active. Do Not Track. FileButler does not track your online activity over time or across other websites. The Services use no advertising or tracking cookies, and optional analytics stays off unless you switch it on in Cookie Settings, as our Cookie Policy explains. Third-party tracking. We do not allow third parties to collect information about your online activity over time and across different websites when you use the Services. During subscription checkout, Stripe may set its own cookies for payment processing, fraud prevention, and security, under Stripe's own privacy policy. You can change your cookie choices at any time through the Cookie Settings link on the website or through your browser settings. Blocking necessary cookies may prevent sign-in or checkout from working. 5. Your privacy rights You have the following rights over the personal information we hold about you, wherever you live. Right to know: request the categories and specific pieces of personal information we have collected about you, the categories of sources, the purposes for collecting it, and the categories of third parties we disclosed it to. Right to delete: request that we delete personal information we collected from you, subject to the exceptions the law allows, such as information we must keep to complete a transaction, maintain security, or comply with a legal obligation. Right to correct: request that we correct inaccurate personal information. Right to opt out of sale or sharing: we do not sell or share personal information, so there is nothing to opt out of. Because we do not sell or share, an opt-out preference signal sent by your browser does not change how we handle your information. Right to limit use of sensitive personal information: we use sensitive personal information only for the purposes the law permits without a limit request, so this right does not apply. Right to non-discrimination: we will not deny you the Services, charge you a different price, or provide a different level of service because you exercised any of these rights. How to submit a request Email [email protected] with "Privacy Request" in the subject line, or call +1 954-408-4253. Account holders can review and update their name, email address, telephone number, and other account details at any time in portal Settings. How we verify your request We verify requests to know, delete, or correct by matching the information you give us against the account records we hold, such as your name, the email address on the account, and the organization you belong to. For a signed-in account holder, we may confirm the request through the email address on the account. We will ask only for the information needed to verify you and will not use it for any other purpose. Authorized agents You may use an authorized agent to submit a request on your behalf. We will ask the agent for written permission signed by you, and we may also ask you to verify your identity directly with us. Response time We acknowledge requests within 5 business days and respond within 45 calendar days. If we need more time, we will tell you why and when to expect a response, up to an additional 45 days as the law allows. Requests about Customer Content If your request concerns Customer Content that a subscribing organization placed in the portal, that organization controls the content and decides how to respond. We will forward your request to the organization within 5 business days and tell you that we have done so. 6. How we protect your information We use security procedures and practices suited to the sensitivity of the information we hold, and we require every service provider that handles it to do the same. Encrypted transmission: all traffic between your browser and the Services is encrypted. Two-factor authentication: a second verification step protects sign-in. Role-based permissions: each person sees only what their role allows. Clients see only their own folders. Staff and administrator functions are checked on the server, not just hidden in the interface. Separation of each subscriber's data: every request is checked for both who you are and whether you may access the specific record requested. Audit logs: sign-ins, document access, uploads, downloads, signatures, and administrative changes are logged. Passwords: never stored in readable form and never visible to Envisage personnel. Signature records: each completed signature produces a certificate of completion that records the signer, method, internet protocol address, timestamp, and a cryptographic hash of the signed document. Storage location: uploaded files and portal data are stored with Backblaze, Inc. only, in the United States. Customer Content is not stored or processed outside the United States. Vendor contracts: each service provider that handles personal information is bound by contract to protect it. Written security program: we maintain written policies and conduct risk assessments of the Services. Protected health information: where a subscribing organization has signed a Business Associate Agreement with Envisage, protected health information in Customer Content is handled under that agreement. Backblaze, Inc. has signed a Business Associate Agreement with Envisage Companies, LLC (parent company to FileButler) covering file storage. 7. How long we keep information Identifiers and contact details. Retention period or criteria: For the life of the account, then as long as needed to resolve disputes and meet legal obligations. Billing information. Retention period or criteria: As long as tax and accounting law requires and as needed to resolve payment disputes and chargebacks. Internet and device activity, audit logs. Retention period or criteria: As long as needed for security, to investigate incidents, and to document account access and usage. Customer Content. Retention period or criteria: Under the control of the subscribing organization. Content stays until the subscriber deletes it; deleted items go to a Recycle Bin the subscriber controls. The FileButler Data Retention Policy and the subscriber's agreement govern what happens when a subscription ends. Cookies and browser storage. Retention period or criteria: Session cookies expire when you sign out or the session ends; preference and consent cookies stay until you clear them. When information is no longer needed for these purposes, we delete it or remove the details that identify a person. 8. Security incidents and breach notification If we discover or are notified of a breach of the security of personal information, we investigate, contain it, and preserve the records needed to determine what happened. If a breach affects personal information: Your account information: we notify you within 30 calendar days of discovering the breach, and we notify government authorities as the law requires. Customer Content: we notify the subscribing organization immediately after discovering the breach, so it can notify its own clients. We give the organization the facts it needs for its notice and, at its written request, send the notice on its behalf. Delay: notice may be delayed only when law enforcement asks us to wait, or for the time needed to find out what was affected and secure the system. Where a Business Associate Agreement applies, we also follow its notice terms. 9. Confidentiality for professional subscribers Attorneys, accountants, tax preparers, and other professionals have a duty to keep their clients' information confidential. When they use FileButler, we commit to the following so they can meet that duty: Confidential handling: we treat all Customer Content as confidential. We do not use or disclose it except to provide the Services, at the subscriber's direction, or when the law requires. No other use: we never use client information, including tax return information, for marketing or for any purpose other than providing the Services. No artificial intelligence providers: Customer Content is never sent to an outside artificial intelligence or model provider. United States only: Customer Content is stored and processed only in the United States. Return of client files: the subscriber can download any client's records at any time, including when a client asks for its file back. Retention under the subscriber's control: we do not delete active Customer Content on our own schedule, so the subscriber can keep records for as long as its professional rules require. Breach notice: we notify the subscriber immediately if a breach affects its Customer Content (section 8). Medical records: a Business Associate Agreement is available on request. 10. Children The Services are for business use and are not directed to anyone under 18 years of age. We do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, contact us and we will delete it. 11. Changes to this policy When we change this policy, we post the revised version on the website with a new effective date and notify account holders with a notice in the portal telling them the policy has been updated. 12. Additional information for people in Brazil This section applies when we process personal information about people located in Brazil, under Brazil's General Personal Data Protection Law (Law 13,709 of August 14, 2018). Where this section differs from sections 1 through 11, this section controls for people in Brazil. Our role. For account, billing, and usage information, Envisage is the controller. For Customer Content, the subscribing organization is the controller, and Envisage is its processor, acting only on the subscriber's instructions. Questions about Customer Content go first to the subscribing organization that gave you access. Legal bases for processing. We rely on the following legal bases under Article 7 of the law: Create and manage your account, provide the Services, and send service messages: Performance of a contract (Article 7, item V) Process payments and keep tax and accounting records: Compliance with a legal or regulatory obligation (Article 7, item II), and performance of a contract Secure the Services, keep audit logs, and prevent fraud: Our legitimate interests (Article 7, item IX), and the regular exercise of rights in legal, administrative, or arbitration proceedings (Article 7, item VI) Optional analytics cookies and FileButler offers and news by email: Your consent (Article 7, item I), which you may withdraw at any time Customer Content: The legal basis chosen by the subscribing organization as controller Customer Content may include sensitive personal information, such as health information. The subscribing organization is responsible for having a legal basis under Article 11 of the law before it places that information in the portal. Your rights. Under Article 18 of the law, you may ask us to: • Confirm whether we process your personal information. • Give you access to it. • Correct incomplete, inaccurate, or outdated information. • Anonymize, block, or delete information that is unnecessary, excessive, or processed unlawfully. • Transfer your information to another service provider. • Delete information we process based on your consent. • Tell you which public and private entities we share your information with. • Tell you that you may refuse consent, and what happens if you do. • Withdraw your consent. FileButler makes no decisions about you based solely on automated processing. You may also petition Brazil's National Data Protection Agency about how we handle your information. How to exercise your rights and response times. Send your request using the contact details below. You may write in Portuguese, and requests are free of charge. We confirm whether we hold your information, in simplified form, right away. We provide a complete statement of the information we hold, its source, and the purposes for processing it within 15 days of your request. Where your information is stored and international transfers. All personal information, including Customer Content, is stored in the United States with Backblaze, Inc., and payment information is processed by Stripe, Inc. in the United States. Information we collect directly from you. When FileButler collects information directly from you, Brazilian rules treat it as international collection, not an international transfer. Brazil's data protection law still applies, and we follow it. Customer Content from Brazilian subscribers. When a subscribing organization in Brazil places Customer Content in the portal, the information is transferred internationally to Envisage in the United States. For these transfers we use the standard contractual clauses approved by Brazil's National Data Protection Agency in Annex II of Resolution 19 of August 23, 2024, adopted without changes. The method, duration, and purpose of these transfers are described in Portuguese at filebutler.io/transferencia-internacional.html. On request, we provide the full text of the clauses within 15 days, except for commercial and industrial secrets. Security incidents. If a security incident may create significant risk or harm to people in Brazil, we notify Brazil's National Data Protection Agency and the people affected within 3 working days of learning that the incident affected personal information. If the incident affects Customer Content, we notify the subscribing organization immediately, so it can meet the same deadline as controller. This deadline replaces the 30 day period in section 8 for people in Brazil. Children and adolescents. The Services are not directed to children or adolescents, as defined in Brazil's Statute of Children and Adolescents and its Digital Statute (Law 15,211 of 2025). We do not knowingly collect their personal information. If you believe we have, contact us and we will delete it. Complaints. You may file a petition with Brazil's National Data Protection Agency at www.gov.br/anpd. 13. Additional information for people in the European Union This section applies when we process personal information about people in the European Union, including Portugal, Germany, France, and Spain. It reflects the General Data Protection Regulation (Regulation 2016/679 of the European Parliament and of the Council). Sections 13.1 through 13.4 add the national rules of Portugal, Germany, France, and Spain. Where this section differs from sections 1 through 11, this section controls for people in the European Union. Who is responsible. For account, billing, and usage information, the controller is Envisage Companies, LLC, which you can reach at [email protected]. For Customer Content, the subscribing organization is the controller, and Envisage is its processor under our Data Processing Agreement. Legal bases for processing. We rely on the following legal bases under Article 6 of the regulation: Create and manage your account, provide the Services, and send service messages: Performance of a contract with you or your organization (Article 6(1)(b)) Process payments and keep tax and accounting records: Compliance with a legal obligation (Article 6(1)(c)) Secure the Services, keep audit logs, and prevent fraud: Our legitimate interests in protecting the Services and the people who use them (Article 6(1)(f)) Optional analytics cookies and FileButler offers and news by email: Your consent (Article 6(1)(a)), which you may withdraw at any time Customer Content: The legal basis chosen by the subscribing organization as controller If Customer Content includes special categories of information, such as health information, the subscribing organization is responsible for meeting Article 9 of the regulation. Your rights. You may ask us to: • Give you access to your personal information (Article 15). • Correct inaccurate information (Article 16). • Erase your information (Article 17). • Restrict how we process it (Article 18). • Give you your information in a portable format (Article 20). • Stop processing it based on our legitimate interests (Article 21). • Withdraw your consent at any time, without affecting processing that took place before you withdrew it (Article 7(3)). FileButler makes no decisions about you based solely on automated processing, including profiling. Response time. We respond within one month of receiving your request. If a request is complex, we may extend that by up to two more months, and we tell you within the first month. This replaces the 45 day period in section 5 for people in the European Union. Where your information is stored and international transfers. All personal information, including Customer Content, is stored in the United States with Backblaze, Inc., and payment information is processed by Stripe, Inc. in the United States. Information we collect directly from you. We collect it directly and store it in the United States, and we apply this section to it. Customer Content from subscribers in the European Economic Area. When a subscribing organization places Customer Content in the portal, the information is transferred to Envisage in the United States. For these transfers we use the European Commission's 2021 standard contractual clauses (Commission Implementing Decision 2021/914): Module Two when the subscriber is a controller, and Module Three when the subscriber is itself a processor. We add supplementary measures, including encryption in transit and at rest, role-based access controls, and audit logging. We do not currently rely on the European Union and United States Data Privacy Framework. You may ask us for a copy of the clauses we use. Security incidents. If a breach of security affects your account information, we notify the competent supervisory authority, listed in sections 13.1 through 13.4, within 72 hours of becoming aware of it, unless the breach is unlikely to put your rights and freedoms at risk. If the breach is likely to put them at high risk, we also notify you without undue delay. If a breach affects Customer Content, we notify the subscribing organization without undue delay, so it can meet its own 72 hour deadline. These deadlines replace the 30 day period in section 8 for people in the European Union. Cookies. We place cookies that are not strictly necessary only with your prior consent, as the national laws in sections 13.1 through 13.4 require. Optional analytics stays off until you switch it on in Cookie Settings, as section 4 and our Cookie Policy describe. Children. The Services are for business use and are not directed to anyone under 18 years of age. The age at which a child may consent to online services in each country is listed below. Complaints. You may file a complaint with the data protection authority in the country where you live or work, or where you believe a violation took place. The authorities for Portugal, Germany, France, and Spain are listed below. 13.1 Portugal Laws. Portugal's Law 58/2019 of August 8, 2019, which carries out the regulation in Portugal, and Law 41/2004 of August 18, 2004, on privacy in electronic communications. Cookies. Under Article 5 of Law 41/2004, we place cookies that are not strictly necessary only with your prior consent. Children. In Portugal, a child may consent to online services from age 13 under Article 16 of Law 58/2019. Authority. Portugal's National Data Protection Commission (Comissão Nacional de Proteção de Dados), www.cnpd.pt. 13.2 Germany Laws. Germany's Federal Data Protection Act (Bundesdatenschutzgesetz) and the Telecommunications Digital Services Data Protection Act (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz). Cookies. Under Section 25 of the Telecommunications Digital Services Data Protection Act, we store information on your device, or read it from your device, only with your consent, unless it is strictly necessary to provide the Services you asked for. Children. In Germany, a child may consent to online services from age 16, under Article 8 of the regulation. Authority. The data protection authority of the German state (Land) where you live or work. The Federal Commissioner for Data Protection and Freedom of Information lists every state authority at www.bfdi.bund.de. 13.3 France Laws. France's Law 78-17 of January 6, 1978, on information technology, files, and freedoms (Loi Informatique et Libertés). Cookies. Under Article 82 of Law 78-17, we place cookies that are not strictly necessary only with your prior consent. Refusing cookies is as easy as accepting them. Children. In France, a child may consent to online services from age 15 under Article 45 of Law 78-17. Instructions for after death. Under Article 85 of Law 78-17, you may give us instructions on how your personal information is kept, deleted, or shared after your death. Send them using the contact details below. Authority. France's National Commission on Information Technology and Freedoms (Commission Nationale de l'Informatique et des Libertés), www.cnil.fr. 13.4 Spain Laws. Spain's Organic Law 3/2018 of December 5, 2018, on the protection of personal data and the guarantee of digital rights, and Law 34/2002 of July 11, 2002, on information society services and electronic commerce. Cookies. Under Article 22.2 of Law 34/2002, we place cookies that are not strictly necessary only with your prior consent. Children. In Spain, a child may consent to online services from age 14 under Article 7 of Organic Law 3/2018. Deceased persons. Under Article 3 of Organic Law 3/2018, the heirs or relatives of a deceased person may ask us for access to, correction of, or deletion of that person's information, unless the person prohibited it. Authority. The Spanish Data Protection Agency (Agencia Española de Protección de Datos), www.aepd.es. 14. Additional information for people in Mexico and other Latin American countries This section applies when we process personal information about people in Mexico, Argentina, Colombia, Chile, Peru, Ecuador, Uruguay, Paraguay, or Bolivia. Sections 14.1 through 14.9 add the rules of each country. Where this section differs from sections 1 through 11, this section controls for the people it covers. Our role. For account, billing, and usage information, Envisage is the controller. For Customer Content, the subscribing organization is the controller, and Envisage is its processor, acting only on the subscriber's instructions under our Data Processing Agreement. Questions about Customer Content go first to the subscribing organization that gave you access. Sensitive information. Customer Content may include sensitive personal information, such as health information. The subscribing organization is responsible for having the consent or other legal basis its country's law requires before it places that information in the portal. Where your information is stored. All personal information, including Customer Content, is stored in the United States with Backblaze, Inc., and payment information is processed by Stripe, Inc. in the United States. Information we collect directly from you is collected by Envisage in the United States. When a subscribing organization places Customer Content in the portal, the information goes to Envisage in the United States as the subscriber's processor. The country sections below explain the safeguards for that step. How to exercise your rights. Email [email protected] with "Privacy Request" in the subject line, or call +1 954-408-4253. You may write in Spanish. Requests are free of charge, except where the law allows a reasonable charge for copies or delivery. Requests about Customer Content are forwarded to the subscribing organization as section 5 describes. Automated decisions. FileButler makes no decisions about you based solely on automated processing. Response times and breach notice. The response times and breach notice periods in each country section replace the 45 day period in section 5 and the 30 day period in section 8 for people in that country. If a breach affects Customer Content, we notify the subscribing organization immediately, so it can meet its own obligations as controller. Children. The Services are for business use and are not directed to anyone under 18 years of age. 14.1 Mexico Law. Mexico's Federal Law on the Protection of Personal Data Held by Private Parties, in force since March 21, 2025. For people in Mexico, this section together with sections 1 through 11 is our privacy notice (aviso de privacidad). Who is responsible. Envisage Companies, LLC, of Fort Lauderdale, Florida, United States, is responsible for your account, billing, and usage information. Our privacy team, reachable at [email protected], handles requests from people in Mexico. Purposes. We use your information to create and manage your account, provide the Services, process payments, and secure the Services. These purposes are necessary for the Services. We also use it for optional analytics and to send FileButler offers and news by email. You may refuse these optional uses at any time by emailing [email protected] or through Cookie Settings, and refusing does not affect your use of the Services. Your rights. You may ask us to give you access to your information, correct it, cancel (delete) it, or stop using it for specific purposes (opposition). You may also withdraw your consent and limit how we use or disclose your information. Your request should include your name and a way to send you our answer, a document that proves your identity or your representative's authority, and a clear description of the information and the right you want to exercise. Response times. We answer within 20 business days of receiving your request. If we grant it, we carry it out within 15 business days after we tell you. We may extend each period once, for the same length of time, when the circumstances justify it, and we tell you if we do. Transfers. We do not transfer your personal information to third parties that would need your consent. Backblaze, Inc. and Stripe, Inc. receive it only as service providers acting on our behalf. Security incidents. If a breach significantly affects your property or non-property rights, we inform you immediately. Changes. We announce changes to this privacy notice as section 11 describes. Complaints. If we deny your request or do not answer in time, you may file a complaint with Mexico's Secretariat of Anti-Corruption and Good Governance (Secretaría Anticorrupción y Buen Gobierno). 14.2 Argentina Law. Argentina's Personal Data Protection Law 25,326 and its regulation, Decree 1558/2001. Your rights. You may ask us for access to your information, and to correct, update, or delete it. You may exercise the right of access free of charge at intervals of no less than six months, unless you show a legitimate interest under Article 14, paragraph 3, of Law 25,326. Response times. We answer access requests within 10 calendar days. We correct, update, or delete information within 5 business days of a verified request. Customer Content from Argentine subscribers. When a subscribing organization in Argentina places Customer Content in the portal, the information goes to Envisage in the United States. For these transfers we use the model contractual clauses approved by Argentina's Agency for Access to Public Information. Security incidents. If a breach affects your account information, we notify you without undue delay, and we keep a record of every incident. Complaints. THE AGENCY FOR ACCESS TO PUBLIC INFORMATION, as the Control Body of Law 25,326, has the power to address the complaints and claims filed by anyone whose rights are affected by noncompliance with the rules in force on personal data protection. In the original Spanish: "LA AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA, en su carácter de Órgano de Control de la Ley N° 25.326, tiene la atribución de atender las denuncias y reclamos que interpongan quienes resulten afectados en sus derechos por incumplimiento de las normas vigentes en materia de protección de datos personales." Website: www.argentina.gob.ar/aaip. 14.3 Colombia Law. Colombia's Statutory Law 1581 of 2012 and Decree 1377 of 2013. For people in Colombia, this section together with sections 1 through 11 is our personal data processing policy. Your rights. Under Article 8 of Law 1581, you may know, update, and correct your information; ask for proof of the authorization you gave us; be told how we use your information; file complaints with the Superintendence of Industry and Commerce; withdraw your authorization or ask us to delete your information when we do not respect your rights; and access your information free of charge. Response times. We answer questions (consultas) within 10 business days. If we need more time, we tell you why and answer within 5 more business days. We resolve claims (reclamos), such as requests to correct, update, or delete information, within 15 business days. If we need more time, we tell you why and resolve the claim within 8 more business days. Transfers. The Superintendence of Industry and Commerce lists the United States among the countries with an adequate level of protection. When a subscribing organization in Colombia places Customer Content in the portal, Envisage receives it as the subscriber's processor, under a transmission contract that meets Article 25 of Decree 1377 of 2013. Security incidents. If a breach affects your account information, we notify the Superintendence of Industry and Commerce within 15 business days of detecting it, and we notify you without undue delay. Complaints. Colombia's Superintendence of Industry and Commerce (Superintendencia de Industria y Comercio), www.sic.gov.co. 14.4 Chile Law. Chile's Law 19,628 on the protection of private life, as amended by Law 21,719. The amendments take effect on December 1, 2026, or on any later date set by law. Your rights. You may ask us for access to your information, and to correct it, delete it, object to its processing, receive it in a portable format, or temporarily block its processing. You may also ask not to be subject to decisions based solely on automated processing. Response times. We answer within 30 calendar days of receiving your request. We may extend that once, by up to 30 more days, and we tell you if we do. We answer requests to block processing within 2 business days. Customer Content from Chilean subscribers. When a subscribing organization in Chile places Customer Content in the portal, the information goes to Envisage in the United States. For these transfers we use contractual clauses that provide the safeguards Chilean law requires. Security incidents. If a breach creates a reasonable risk to your rights, we notify Chile's Personal Data Protection Agency by the fastest means available and without undue delay. If the breach involves sensitive information, information about children under 14, or information about financial or commercial obligations, we also notify you. Complaints. Chile's Personal Data Protection Agency (Agencia de Protección de Datos Personales). 14.5 Peru Law. Peru's Personal Data Protection Law 29733 and its Regulation, approved by Supreme Decree 016-2024-JUS and in force since March 30, 2025. Your rights. You may ask us for information about how we process your personal information, and for access to it. You may also ask us to correct or update it, cancel (delete) it, or stop processing it (opposition). You may also object to decisions based solely on automated processing. Response times. We answer access requests within 20 business days. We answer requests to correct, cancel, or oppose processing within 10 business days. Customer Content from Peruvian subscribers. When a subscribing organization in Peru places Customer Content in the portal, the information goes to Envisage in the United States. For these transfers we use contractual clauses that commit us to the protection Peruvian law requires. Security incidents. If a security incident involving your information meets the thresholds the Regulation sets, we notify Peru's National Authority for Personal Data Protection within 48 hours of becoming aware of it. If the incident affects your rights, we notify you without undue delay and within 48 hours. Complaints. Peru's National Authority for Personal Data Protection (Autoridad Nacional de Protección de Datos Personales), part of the Ministry of Justice and Human Rights. 14.6 Ecuador Law. Ecuador's Organic Law on Personal Data Protection of May 2021 and its Regulation of November 2023. Your rights. You may ask us for information about how we process your personal information, for access to it, and to correct, update, or delete it. You may also object to its processing, ask to receive it in a portable format, ask us to suspend processing, and ask not to be subject to decisions based solely on automated processing. Response times. We answer within 15 days of receiving your request. Customer Content from Ecuadorian subscribers. When a subscribing organization in Ecuador places Customer Content in the portal, the information goes to Envisage in the United States. For these transfers we use binding contractual clauses that provide the safeguards Ecuadorian law requires. Security incidents. If a breach affects your account information, we notify Ecuador's Superintendence of Personal Data Protection as soon as possible and no later than 5 days after we learn of it, unless the breach is unlikely to put your rights at risk. If the breach creates a risk to your rights, we notify you without delay and no later than 3 days after we learn of that risk. Complaints. Ecuador's Superintendence of Personal Data Protection (Superintendencia de Protección de Datos Personales). 14.7 Uruguay Law. Uruguay's Law 18,331 of 2008 on personal data protection, as amended by Law 19,670 of 2018, and its regulations, Decree 414/009 and Decree 64/020. Your rights. You may ask us for access to your information, and to correct, update, add to, or delete it. You may also ask to receive it in a portable format. Response times. We answer requests for access, correction, update, or deletion within 5 business days. Customer Content from Uruguayan subscribers. When a subscribing organization in Uruguay places Customer Content in the portal, the information goes to Envisage in the United States. For these transfers we use contractual clauses that provide the safeguards Uruguayan law requires. Security incidents. If a breach may significantly affect your rights, we notify Uruguay's Regulatory and Control Unit for Personal Data without undue delay, and we inform you. Complaints. Uruguay's Regulatory and Control Unit for Personal Data (Unidad Reguladora y de Control de Datos Personales). 14.8 Paraguay Law. Paraguay's Law 7593 of 2025 on personal data protection takes full effect in November 2027. Until then, we apply section 5 to requests from people in Paraguay. Your rights. You may ask us for access to your information, and to correct or delete it. You may also object to its use for commercial or advertising purposes, ask to receive it in a portable format, and challenge decisions based solely on automated processing. Security incidents. Once the law takes effect, if a breach affects your account information, we notify Paraguay's National Personal Data Protection Agency and, where appropriate, the people affected, within 72 hours of becoming aware of it. Complaints. Once it begins operating, Paraguay's National Personal Data Protection Agency (Agencia Nacional de Protección de Datos Personales). 14.9 Bolivia Bolivia does not currently have a general personal data protection law. Article 130 of the Constitution of Bolivia protects your right to know what information is held about you, and to have it corrected or deleted. We honor those rights through the process and response times in section 5. Contact us FileButler Email: [email protected] Envisage Companies, LLC Email: [email protected] Fort Lauderdale, Florida Phone: +1 954-408-4253