PRIVACY POLICY – FELICLOUD

1. OVERVIEW

Felicloud values your privacy. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the Felicloud website located at felicloud.com and any Felicloud mobile applications ("Site") or Felicloud services ("Services").

This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Data (as defined below). This Policy applies to all Felicloud services and any associated services (referred to as 'Felicloud'). The terms governing your use of the Felicloud Service are defined in our Terms of Service (the "Terms and Conditions"). The Site is operated by BTJT LDA, Portugal (hereinafter referred to as "Felicloud", "we", "us" and "our"). For the purposes of applicable European Union data protection legislation, we are the data controller.

2. WHAT PERSONAL DATA DO WE COLLECT?

Personal Data provided by you

• Personal data about you upon registration – You will be asked to provide your email address to establish an Account.
• Personal data that you choose to provide us to obtain additional Services – If you request to participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you.

Personal Data as you use our Site or Services

• Technical information – We will collect information about you as you use the Site or Service, such as your IP address, browser type and version, operating system, referral source and device information.
• Geolocation data – We collect geolocation information based on your IP address to optimize our services and comply with legal obligations.
• Analytics data – With your consent, we use Matomo (self-hosted) to collect information about your visit, such as length of visit, page views and navigation paths.
• Advertising pixels – With your consent, we use pixels from Meta (Facebook) and Reddit to measure the effectiveness of our advertising campaigns.
• Purchase information – We collect information about purchases you've made through our Site or Services.
• File metadata – We store file names, creation and modification dates, file sizes, and other metadata necessary for the operation of our cloud storage service.
• Access logs – We maintain access logs including your IP address, connection timestamps, and account activities for 30 days for security purposes.

Personal Data about you if you visit as a guest

Certain limited Services are available without being required to log in to or establish an Account, also referred to as Guest Usage. We will collect information about you such as length of visit, page views and navigation paths.

Personal Data about you from third-party sources

• Personal Data from payment processors – We will collect information about you from Stripe when you purchase products offered on the Site or Service.
• Newsletter data – If you sign up for our newsletter, we collect and process your email address for marketing purposes.

3. WHY DO WE RETAIN PERSONAL DATA?

We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes.

Specific retention periods:

• Access and connection logs: 30 days
• Active account data: for the lifetime of your account
• Data after account closure: deleted immediately and permanently
• Marketing data: until explicit unsubscription

4. HOW DO WE PROCESS PERSONAL DATA?

We may Process your Personal Data for a variety of reasons that are justified under data protection laws in the European Economic Area (EEA).

To operate the Sites and provide the Services, including to:

• initiate a payment
• authenticate your access to Account
• communicate with you about your Account, the Sites, the Services, or Felicloud
• provide file storage, synchronization, and sharing functionalities

For our legitimate interests, including to:

• enforce the terms of our Sites and Services
• manage our everyday business needs, such as monitoring, analyzing
• manage risk and protect the Sites, the Services and you from fraud
• maintain the security of our systems and detect suspicious activities

With your consent, including to:

• market to you by delivering marketing materials about Felicloud products
• send newsletters and marketing communications
• use advertising measurement pixels (Meta, Reddit)
• respond to your requests

5. DO WE SHARE PERSONAL DATA?

We may share your Personal Data or other information about you with others in a variety of ways.

• with Stripe in order to initialize a payment process
• with third party services monitoring the proper functioning of the service
• with Matomo to analyse site usage (only with your consent)
• with Meta (Facebook) and Reddit via advertising pixels (only with your consent)

We may share information about you for:

• if we need to do so to comply with a law, legal process or regulations
• to law enforcement authorities or other government officials
• to protect the vital interests of a person
• to facilitate a purchase or sale of all or part of Felicloud's business

We do not share your Personal Data with third parties for their marketing purposes.

6. SELLING DATA TO THIRD PARTIES

We do not, have not and do not have any future plans to sell your personal information to third parties.

7. AUTOMATED DECISION MAKING AND PROFILING

• to send you automated messages or notifications relevant to your user experience
• to run usability and A/B tests to help us improve our service
• to detect and prevent suspicious or fraudulent activities

8. PROCESSING IN THE EU

Server location: Your data is stored on secure servers located in Portugal (European Union), on infrastructure we own and operate. We reserve the right to move your data to other EU countries while maintaining the same level of protection. We do not store any data in the United States.

By using our Site or Services and submitting Personal Information via the Site, you understand that the collection, use, transfer, and disclosure of your Personal Data shall be governed by applicable laws in the European Union and Portugal.

9. HOW DO WE USE COOKIES AND TRACKING TECHNOLOGIES?

We use cookies (a small text file placed on your computer to identify your computer and browser) on the Site.

Types of cookies we use:

• Essential cookies: Necessary for site functionality
• Analytics cookies: Matomo (only with your consent)
• Marketing cookies: Meta (Facebook) and Reddit pixels (only with your consent)

Most web browsers are initially set up to accept cookies. Felicloud's cookies are automatically deleted after 1 year.

10. DO WE PROCESS SPECIAL CATEGORIES OF PERSONAL DATA?

Felicloud does not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.

11. WHAT PRIVACY CHOICES ARE AVAILABLE TO YOU?

At Felicloud, we want to give you maximum control over your personal data.

• Account settings: Modify your personal information in your account settings
• Marketing: Unsubscribe from marketing emails via the link in each email
• Cookies: Manage your cookie preferences in your browser settings
• Geolocation data: Contact us to disable geolocation collection

12. WHAT ARE YOUR RIGHTS?

In this section, we have summarized the rights that you have under data protection law.

Note: Filing multiple claims might be subject to a fee, not exceeding EUR 10.

13. HOW DO WE PROTECT YOUR PERSONAL DATA?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data.

• AES-256 encryption for data at rest, with optional end-to-end encryption for the folders you choose
• TLS/SSL connections for data in transit
• 24/7 monitoring of our systems
• Redundant storage designed to withstand individual hardware failures (this is not a backup: we do not keep backup copies of your files)
• Strictly controlled server access

In the unlikely event that a security breach which affects individuals' rights and freedoms is discovered, according to our risk assessment policy, Felicloud will inform those individuals without undue delay.

14. CAN CHILDREN USE OUR SERVICES?

The Site and Services are intended for users who are 18 years old or older. We do not knowingly collect Personal Information from children under the age of 18.

15. UPDATES OR CHANGES IN PROCESSING

If we wish to use your personal data for a new purpose, not covered by this Privacy Policy, then we will provide you with a new notice explaining this new use prior to commencing the processing.

We keep this Privacy Policy under regular review and we will place any updates on this web page.

16. CONTACT US

You may contact us if you have general questions or concerns about this Privacy Policy.

17. DEFINITIONS

Account

Account means a Felicloud member account.

Device Information

Device Information means data that can be automatically collected from any device used to access the Site or Services.

Guest Usage

Guest Usage means a person's Use of the Services without logging into and/or establishing an Account.

Felicloud

Felicloud means BTJT LDA and subsidiaries or affiliates.

Personal Data

Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person.

Process

Process means any method or way that we handle Personal Data or sets of Personal Data.

Services

Services means any products, services, content, features, technologies, or functions offered to you by Felicloud.

Sites

Sites means the websites, mobile apps, official social media platforms through which Felicloud offers the Services.

Technical Usage Data

Technical Usage Data means information we collect from your device that you use to access the Sites or Services.

User

User means an individual who uses the Services or accesses the Sites and has established a relationship with Felicloud.

Last Revised: 27/09/2026