Privacy & Cookie Statement

ARCHIVED 2025-01-08, DATE APPROXIMATE · VERSION 20250108_rev01 · COMPARED WITH 20241111_rev01

Full text changes — 20241111_rev01 to 20250108_rev01

COLOUR MARKS THE SEVERITY OF A FLAGGED CLAUSE · + AND − MARK ADDED AND REMOVED

59	59	- Consent: in certain situations we might ask you for consent (opt-in) to process your information. When we do, we'll make it very clear what it is we're asking consent for. You'll always have the right to withdraw your consent at any moment.
60	60
61	61	- To fulfill our Legal Obligations: Just like any other company, we're bound by laws and regulations. Sometimes, we have to use your personal information to comply with these legal requirements.
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63	63	- To protect the Vital Interests of Others: On rare occasions, we might use or share your information to protect someone's life or to handle emergency situations.
64	64
65		<table><tbody><tr><td><p><b>Purpose for processing your information</b></p></td><td><p><b>Legal Basis</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Provide and administer our Services to you</b>, such as allowing you to:</p><p>upload, create or distribute User Content;</p><p>sign-up for an account and login;</p><p>subscribe to and pay for our Services.</p><p>We also send you Service emails and messages. For example, when your Transfer has been downloaded, or that your client has commented on your Review. </p></td><td><p>Performance of a contract </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Provide our distribution and payment collection features as well as to facilitate & process orders.</b> This includes sharing Purchase Information with Uploaders, Payment and Transaction Fulfillment Providers, and Service Providers. </p></td><td><p>Performance of a contract insofar you are bound by our Terms. </p><p>Legitimate interests, such as:</p><p>Facilitating the sale and purchase of User Content. This includes payment collection. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically,<u> in particular Payment & Purchase Information.</u></p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Offer additional core elements of our Services</b>, such as sending recipients an email with a link to download or review User Content; or when you integrate our Services with third-party services.</p></td><td><p>Legitimate interests, such as:</p><p>Keeping our Services running; and</p><p>Allowing people to access and use our Services.</p><p>Facilitating the connection and integration with third-party services on your request and with your permission.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Serve and measure the effectiveness of both  non-personalised and personalised advertisements on both our Services and third-party services. </b>This includes serving you ads from our advertising clients as well as WeTransfer on our Services and measuring them to understand the effectiveness. It also includes WeTransfer's own marketing and advertising activities on third-party services, such as social media platforms. </p><p>In case of non-personalised advertisements, we use very limited information to serve you the ads, such as your non-precise geolocation (typically country) and your browser language. </p></td><td><p>When offering non-personalised ads: Legitimate Interests, such as:</p><p>Being able to offer a Free version of our Services</p><p>When offering personalised ads, and where required by law: Consent. </p></td><td><p><u>Non-personal ads</u></p><p>Geolocation (based on IP-address)</p><p>Browser language</p><p><u>Personalised ads</u></p><p>Any of the data described under:</p><p>Information you provide (<b>but not User Content)</b></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Review our Services and user base to inform the planning, improvement, and development of our Services (including advertising), our business activities (including marketing), and our technology. </b></p><p>For instance, we monitor and analyse how users are using and interacting with the Services,  each other, and across their devices. This helps us with gaining an understanding of:</p><p>how our Services, including new features, are being used,</p><p>how we might further develop our Services,</p><p>what type of people or entities our user base exists of, and</p><p>which type of potential users to focus on in our marketing & advertising activities - both on our Services and on third-party services, such as social media platforms. This purpose relates to broad user segments, and not individual targeting. </p><p>In certain cases, and where allowed by law, we could receive Information from third-parties to help improve the understanding of our user base. </p><p>Moreover, we train and improve our software and technology, such as our machine learning models and algorithms.  </p></td><td><p>Legitimate interests, such as:</p><p>Developing & improving our Services </p><p>Enhancing user experience</p><p>Making informed strategic and business decisions</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Conduct surveys and research</b>. We might ask you for feedback about our Services or about features that are in development. In some cases, we might ask you to participate in lengthier research, including as part of a panel or an Early Access Program (EAP). We might also conduct independent research to gain further user insights.</p></td><td><p>Legitimate interests, such as:</p><p>Understanding how our users and others think of our Services</p><p>Making informed strategic and business decisions</p><p>Where required, we sometimes also ask for your Consent. </p></td><td><p>Information you provide</p><p>Information we collect automatically</p></td></tr><tr><td><p><b>Enforce our Terms, guidelines, and policies</b>. We use your information to enforce our Terms and policies. If we determine that you've violated our Terms, we could remove your content or suspend your account.</p></td><td><p>Performance of a contract</p></td><td><p>Any of the data described under:</p><p>Information you provide, in particular <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Maintain and enhance the safety, integrity, security, and stability of our Services as well as to protect (the rights of) and serve the safety and wellbeing of our users, our community, and third parties.</b></p><p>For instance, we implement security measures, perform diagnostics, troubleshoot and fix issues with the Services. </p><p>We also use automated means as well as human moderation to investigate, detect, and act against (suspicions of) illegal or unwanted activity or User Content. Examples include of illegal activity or content, but are not limited to, Child Sexual Abuse Material (CSAM), malware, fraud, and copyright infringement. </p><p>Next to automated means, we rely on reports of users and third parties to become aware of suspicious or illegal content and activity. </p></td><td><p>Legitimate interests, such as:</p><p>Ensure ongoing security, stability, and availability of our Services</p><p>Ensure the safety of our Users and community</p><p>Protect the rights & reputation of WeTransfer and others.</p></td><td><p>Any of the data described under:</p><p>Information you provide, including <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Communicate and Promote WeTransfer, our Services, our events & promotions  both on- and off-WeTransfer. </b></p><p>We may send you direct marketing messages, including email, about WeTransfer, features of the Services, and third party services. We may also send or offer you promotions, contests, or marketing campaigns or event information. </p></td><td><p>Legitimate interests, such as:</p><p>Direct marketing</p><p>Consent, where required by law. For instance, when we send you email marketing. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>To establish, exercise, or defend legal claims. </b>In case of negotiations, disputes, or (potential) litigation we may need to process your information or possibly share it with our lawyers. </p></td><td><p>Legitimate interests, such as: </p><p>Defending ourselves, our users, or others in specific legal matters</p><p>Seeking legal advice</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Comply with legal obligations </b>As a business we are sometimes obliged to process your information in relation to laws, such as:</p><p>Dutch law (as our headquarters are based in The Netherlands), including civil law, tax laws, law enforcement laws</p><p>EU law, including laws regarding consumer protection, law enforcement, illegal content, hosting services. </p></td><td><p>Complying with Legal Obligations</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Share your information with others</b></p><p>There are limited instances in which we will share your information with others. These are described in more detail in section "How & when we share your information with others", but here's a brief overview: You might request us to share the information, for instance, when you integrate our Services with another third-party service of your choice. In certain cases we might need to share your information with law enforcement, public authorities, or other third-parties. For example, when we have a legal obligation to do so, when there are valid legal grounds for further investigation, or when there's an emergency or life-threatening situation.</p></td><td><p>Complying with Legal obligations, such as:</p><p>EU laws, such as the EU Digital Services Act</p><p>Dutch law (as our headquarters are based in The Netherlands)</p><p>Legitimate Interests, such as: </p><p>Complying with regulatory requests, court orders, search warrants, or subpoenas when not specifically dictated by applicable law</p><p>Complying with laws from countries where our local entities reside, such as France, The UK, and the USA. </p><p>Laws from the country you reside in </p><p>Following case law related to the disclosure of user  information. For instance, in relation to illegal content</p><p>Vital interests of an individual (emergency or life-threatening situation)</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table>
	65	<table><tbody><tr><td><p><b>Purpose for processing your information</b></p></td><td><p><b>Legal Basis</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Provide and administer our Services to you</b>, such as allowing you to:</p><p>upload, create or distribute User Content;</p><p>sign-up for an account and login;</p><p>subscribe to and pay for our Services.</p><p>We also send you Service emails and messages. For example, when your Transfer has been downloaded, or that your client has commented on your Review. </p></td><td><p>Performance of a contract </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Provide our distribution and payment collection features as well as to facilitate & process orders.</b> This includes sharing Purchase Information with Uploaders, Payment and Transaction Fulfillment Providers, and Service Providers. </p></td><td><p>Performance of a contract insofar you are bound by our Terms. </p><p>Legitimate interests, such as:</p><p>Facilitating the sale and purchase of User Content. This includes payment collection. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically,<u> in particular Payment & Purchase Information.</u></p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Offer additional core elements of our Services</b>, such as sending recipients an email with a link to download or review User Content; or when you integrate our Services with third-party services.</p></td><td><p>Legitimate interests, such as:</p><p>Keeping our Services running; and</p><p>Allowing people to access and use our Services.</p><p>Facilitating the connection and integration with third-party services on your request and with your permission.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Serve and measure the effectiveness of both  non-personalised and personalised advertisements on both our Services and third-party services. </b>This includes serving you ads from our advertising clients as well as WeTransfer on our Services and measuring them to understand the effectiveness. It also includes WeTransfer's own marketing and advertising activities on third-party services, such as social media platforms. </p><p>In case of non-personalised advertisements, we use very limited information to serve you the ads, such as your non-precise geolocation (typically country) and your browser language. </p></td><td><p>When offering non-personalised ads: Legitimate Interests, such as:</p><p>Being able to offer a Free version of our Services</p><p>When offering personalised ads, and where required by law: Consent. </p></td><td><p><u>Non-personal ads</u></p><p>Geolocation (based on IP-address)</p><p>Browser language</p><p><u>Personalised ads</u></p><p>Any of the data described under:</p><p>Information you provide (<b>but not User Content)</b></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Review our Services and user base to inform the planning, improvement, and development of our Services (including advertising), our business activities (including marketing), and our technology. </b></p><p>For instance, we monitor and analyse how users are using and interacting with the Services,  each other, and across their devices. This helps us with gaining an understanding of:</p><p>how our Services, including new features, are being used,</p><p>how we might further develop our Services,</p><p>what type of people or entities our user base exists of, and</p><p>which type of potential users to focus on in our marketing & advertising activities - both on our Services and on third-party services, such as social media platforms. This purpose relates to broad user segments, and not individual targeting. </p><p>In certain cases, and where allowed by law, we could receive Information from third-parties to help improve the understanding of our user base. </p><p>Moreover, we train and improve our software and technology, such as our machine learning models and algorithms.  </p></td><td><p>Legitimate interests, such as:</p><p>Developing & improving our Services </p><p>Enhancing user experience</p><p>Making informed strategic and business decisions</p><p>In case we would like to conduct analysis and research on your Content, we will always request your prior Consent.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Conduct surveys and research</b>. We might ask you for feedback about our Services or about features that are in development. In some cases, we might ask you to participate in lengthier research, including as part of a panel or an Early Access Program (EAP). We might also conduct independent research to gain further user insights.</p></td><td><p>Legitimate interests, such as:</p><p>Understanding how our users and others think of our Services</p><p>Making informed strategic and business decisions</p><p>Where required, we sometimes also ask for your Consent. </p></td><td><p>Information you provide</p><p>Information we collect automatically</p></td></tr><tr><td><p><b>Enforce our Terms, guidelines, and policies</b>. We use your information to enforce our Terms and policies. If we determine that you've violated our Terms, we could remove your content or suspend your account.</p></td><td><p>Performance of a contract</p></td><td><p>Any of the data described under:</p><p>Information you provide, in particular <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Maintain and enhance the safety, integrity, security, and stability of our Services as well as to protect (the rights of) and serve the safety and wellbeing of our users, our community, and third parties.</b></p><p>For instance, we implement security measures, perform diagnostics, troubleshoot and fix issues with the Services. </p><p>We also use automated means as well as human moderation to investigate, detect, and act against (suspicions of) illegal or unwanted activity or User Content. Examples include of illegal activity or content, but are not limited to, Child Sexual Abuse Material (CSAM), malware, fraud, and copyright infringement. </p><p>Next to automated means, we rely on reports of users and third parties to become aware of suspicious or illegal content and activity. </p></td><td><p>Legitimate interests, such as:</p><p>Ensure ongoing security, stability, and availability of our Services</p><p>Ensure the safety of our Users and community</p><p>Protect the rights & reputation of WeTransfer and others.</p></td><td><p>Any of the data described under:</p><p>Information you provide, including <u>User Content</u></p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Communicate and Promote WeTransfer, our Services, our events & promotions  both on- and off-WeTransfer. </b></p><p>We may send you direct marketing messages, including email, about WeTransfer, features of the Services, and third party services. We may also send or offer you promotions, contests, or marketing campaigns or event information. </p></td><td><p>Legitimate interests, such as:</p><p>Direct marketing</p><p>Consent, where required by law. For instance, when we send you email marketing. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>To establish, exercise, or defend legal claims. </b>In case of negotiations, disputes, or (potential) litigation we may need to process your information or possibly share it with our lawyers. </p></td><td><p>Legitimate interests, such as: </p><p>Defending ourselves, our users, or others in specific legal matters</p><p>Seeking legal advice</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Comply with legal obligations </b>As a business we are sometimes obliged to process your information in relation to laws, such as:</p><p>Dutch law (as our headquarters are based in The Netherlands), including civil law, tax laws, law enforcement laws</p><p>EU law, including laws regarding consumer protection, law enforcement, illegal content, hosting services. </p></td><td><p>Complying with Legal Obligations</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Share your information with others</b></p><p>There are limited instances in which we will share your information with others. These are described in more detail in section "How & when we share your information with others", but here's a brief overview: You might request us to share the information, for instance, when you integrate our Services with another third-party service of your choice. In certain cases we might need to share your information with law enforcement, public authorities, or other third-parties. For example, when we have a legal obligation to do so, when there are valid legal grounds for further investigation, or when there's an emergency or life-threatening situation.</p></td><td><p>Complying with Legal obligations, such as:</p><p>EU laws, such as the EU Digital Services Act</p><p>Dutch law (as our headquarters are based in The Netherlands)</p><p>Legitimate Interests, such as: </p><p>Complying with regulatory requests, court orders, search warrants, or subpoenas when not specifically dictated by applicable law</p><p>Complying with laws from countries where our local entities reside, such as France, The UK, and the USA. </p><p>Laws from the country you reside in </p><p>Following case law related to the disclosure of user  information. For instance, in relation to illegal content</p><p>Vital interests of an individual (emergency or life-threatening situation)</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table>
66	66
67	67	## How & when we share your information with others
68	68
69	69	There are limited instances in which we will share your information with others. This section describes with whom we might share your personal information, why, and which categories of information.
70	70
71	71	<table><tbody><tr><td><p><b>Categories of recipients</b></p></td><td><p><b>Reason(s) for sharing</b></p></td><td><p><b>Information categories</b></p></td></tr><tr><td><p><b>Service Providers</b> These could be parties that provide services, such as cloud hosting, content delivery, security, survey & research, and customer support. </p></td><td><p>We have to rely on service providers to offer our Services to you, and to ensure that our Services remain secure. Our employees also use a wide variety of tools of Service providers to conduct planning, research, and execution of projects. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p><p>As it relates to offering you our Services under our Terms.</p></td></tr><tr><td><p><b>Advertising Partners, including our Advertising Clients</b></p></td><td><p>We share your information to deliver our advertisements to you. We also share aggregated information with our advertising partners to measure the effectiveness of our advertising services. </p><p>In case we have your permission, we might also share certain personal information to deliver more relevant advertising.  </p></td><td><p>Your hashed email address</p><p>Technical information</p><p>Usage information</p></td></tr><tr><td><p><b>Marketing Partners </b>Examples are partners that promote WeTransfer, or platforms, apps, websites that allow WeTransfer to advertise its Services to you. </p></td><td><p>We do this to promote through communication and advertisements WeTransfer, our Services, and other activities,  events or campaigns we host. These partners also enable us to allow you to sign-up for events and campaigns. Moreover, we measure the effectiveness of our marketing activities and campaigns.</p></td><td><p>User Information</p><p>Information related to Communication, Surveys, Events</p><p>Technical Information</p></td></tr><tr><td><p><b>Payment & Transaction Fulfillment Platforms</b></p></td><td><p>We share the information related to the transaction with payment and transaction fulfilment providers, and other service providers, when you make a purchase or collect a payment on our Services. This could be when you pay for a subscription or when you pay for User Content from another user; or when you request a payment before enabling a download. We share this information so they can fulfill the order, and in some cases for security reasons. </p></td><td><p>User Information</p><p>Technical Information</p><p>Payment & Purchase Information</p></td></tr><tr><td><p><b>Law enforcement and other authorities, or other parties to legal review or litigation</b></p></td><td><p>We may access, preserve, and share your information, including User Content,  with law enforcement agencies, public authorities, IP rights holders, or other third parties if we have good faith belief that it is necessary to: </p><p>comply with applicable law, legal process, search warrant, subpoena or government requests, </p><p>protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm</p><p>detect, investigate, prevent, or address unwanted activity, copyright infringement, or other illegal activity.</p><p>investigate (suspicions of) violations of our Terms, Guidelines, or Policies - as well as to enforce them; or </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Other users</b></p></td><td><p>You may choose to interact with other users by sharing files or reviews with them; or by downloading or purchasing their User Content. In these instances, we could (have to) share or display some of your personal information with them to ensure that our Services work properly. </p></td><td><p>User Information</p><p>User Content</p><p>Payment & Purchase information </p></td></tr><tr><td><p><b>Other WeTransfer companies, or companies we acquire</b></p></td><td><p>As a global company we have entities and colleagues in several countries around the world. These entities -and the colleagues who work there- may process your information for us. For instance, to review, develop & improve features, for security and content moderation, for analytics, technical & customer support. </p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr><tr><td><p><b>Parties in relation to Corporate Transactions</b></p></td><td><p>Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganisation, financing, change of control, or acquisition of all or a portion of our business.</p></td><td><p>Any of the data described under:</p><p>Information you provide</p><p>Information we collect automatically</p><p>Information we receive from Other sources</p></td></tr></tbody></table>
199	199	WeTransfer's Services are not directed towards minors. You are only allowed to use our Services when aged 16 and over.
200	200
201	201	- How to contact us
202	202
203	203	You can contact us about this privacy policy or other related questions via [legal@wetransfer.com](mailto:legal@wetransfer.com). You can also reach us by mail on Keizersgracht 281, 1016 ED, Amsterdam, The Netherlands.
204	204
205		You can reach out to our Data Protection Officer via email [dpo@wetransfer.com](mailto:dpo@wetransfer.com) or by mail at the following address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium.
	205	You can reach out to our Data Protection Officer via email [dpo@bendingspoons.com](mailto:dpo@bendingspoons.com).