PRIVACY POLICY

Effective Date: 25.06.2025
Version: 1.0

1. INTRODUCTION

This Privacy Policy ("Policy") describes how SableSend ("we", "us", "our", "Service") collects, uses, stores, and protects your personal information when you use our website https://sablesend.com and mobile applications (hereinafter - "Platform").

SableSend is a service for fast and secure file sharing and creating private notes with an automatic deletion function.

2. INFORMATION WE COLLECT

2.1 Information You Voluntarily Provide

Upon account registration:

  • Email address
  • Username
  • Consent to personal data processing

When using the Service:

  • Uploaded files and their metadata (name, size, type)
  • Text of created notes
  • Security settings (passwords for files and notes)
  • Requests to customer support
  • Referral information

2.2 Automatically Collected Information

Technical data:

  • IP address
  • Browser and operating system type
  • Time and date of access to the Service
  • Device information (device ID, mobile operator, interface language)
  • Information about battery performance and network connections (Wi-Fi, mobile network)
  • App permission data on your device
  • Cookies and similar technologies
  • User action logs

Usage statistics:

  • Number of uploaded files
  • Number of created notes
  • Download statistics
  • Service performance data

2.3 Financial Information

  • Transaction and payment history
  • Cryptocurrency transfer information (provided by payment provider ExPay)
  • Account balance
  • Referral accrual data

3. PURPOSES OF PERSONAL DATA PROCESSING

We use your information for:

Providing core services:

  • Ensuring file upload, storage, and access
  • Creating and managing private notes
  • Ensuring data transfer security

Account management:

  • Creating and maintaining an account
  • User authentication
  • Providing access to the personal account

Financial operations:

  • Processing premium tariff payments
  • Managing account balance
  • Accruing referral rewards
  • Processing partner commission payouts

User support:

  • Providing technical support
  • Responding to inquiries and complaints
  • Resolving disputes

Security and compliance:

  • Preventing fraud and abuse
  • Ensuring compliance with our terms of use
  • Fulfilling legal obligations

Service improvement:

  • Analyzing Platform usage
  • Developing new features
  • Optimizing performance

4. LEGAL BASES FOR PROCESSING

Your personal data is processed on the following legal bases:

  • Consent – for data processing during registration and use of additional functions
  • Performance of a contract – for providing core Service features
  • Legitimate interest – for ensuring security, preventing fraud, and improving the Service
  • Legal obligation – for complying with applicable law

5. AUTOMATIC DATA DELETION

5.1 Files

  • Files are automatically deleted upon expiration of the set period (up to 30 days for Free, up to 40 days for Pro, up to 90 days for Enterprise)
  • When a file is downloaded at least once, the storage period is automatically extended by 30 days
  • Users can delete files prematurely via their personal account

5.2 Notes

  • Notes are automatically deleted after the first reading
  • Maximum storage period for unread notes - 7 days
  • Notes are permanently deleted without recovery possibility

5.3 Accounts

  • Inactive account data (no login for more than 2 years) may be deleted
  • Before deletion, we will send a notification to the registered email

6. DATA DISCLOSURE TO THIRD PARTIES

6.1 We DO NOT sell, rent, or transfer your personal data to third parties for their marketing purposes.

6.2 We may transfer data in the following cases:

Service providers:

  • ExPay – for processing cryptocurrency payments (we do not receive or store your crypto wallet data)
  • Hosting providers for data storage
  • Analytics services for Service improvement
  • Email service providers for sending notifications

By legal requirement:

  • Government authorities upon legal request
  • Law enforcement agencies as part of investigations
  • In case of litigation

In case of business reorganization:

  • In case of merger, acquisition, or asset sale
  • Upon transfer of business to another company

6.3 Legal Demands and Subpoenas

We may be obliged to disclose your personal data in the following cases:

  • By court order or government authority request
  • Upon receipt of a subpoena or court order
  • As part of criminal investigations
  • Upon lawful request from law enforcement agencies

Notification procedure:

we strive to notify you of receiving legal demands by sending a notification to your registered email address, except when:

  • Notification is prohibited by court order
  • We reasonably believe that notification creates a security risk
  • The request concerns emergency situations

Legal consultations: we may disclose your information to our legal advisors for legal advice on legal demands and protection of our legitimate interests.

7. INTERNATIONAL DATA TRANSFER

Your data may be processed in server centers located in various jurisdictions.

We ensure an adequate level of protection for international data transfers in accordance with applicable law.

8. DATA SECURITY

We apply modern technical and organizational measures to protect your data:

Technical measures:

  • Data encryption in transit (SSL/TLS)
  • Data encryption at rest
  • Secured servers and databases
  • Regular security updates
  • Monitoring for unauthorized access

Organizational measures:

  • Limited access to personal data
  • Employee security training
  • Information security policies
  • Regular security audits

8.1 Links to Third-Party Resources

Our Platform may contain links to third-party websites, usually in the form of advertising materials or affiliate links.

We are not responsible for the privacy policies and security practices of such third-party resources.

We strongly recommend reviewing the privacy policies of these sites before providing them with any personal information.

9. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, pixels, and similar technologies to collect information about how you use our Services.

Cookies are small pieces of data stored on your device (computer, phone, tablet).

Pixels are small pieces of code placed on web pages that allow measuring the frequency of page views and usage.

9.1 Types of Technologies Used:

Necessary cookies:

  • User authentication
  • Session maintenance
  • Security enforcement

Functional cookies:

  • Saving interface settings
  • Language preferences
  • Improving user experience

Analytical cookies:

  • Collecting usage statistics
  • Performance analysis
  • Service improvement

9.2 Managing Cookies

You can manage cookies through your browser settings.

Disabling some cookies may limit Service functionality.

10. YOUR RIGHTS

In accordance with applicable law, you have the following rights:

10.1 Right to Access

  • Obtain information about what data we process
  • Obtain a copy of your personal data

10.2 Right to Rectification

  • Correct inaccurate or incomplete data
  • Update outdated information

10.3 Right to Erasure ("Right to Be Forgotten")

  • Delete your personal data under certain conditions
  • Immediate deletion upon withdrawal of consent

10.4 Right to Restriction of Processing

  • Temporary restriction of data processing
  • Blocking processing in disputed situations

10.5 Right to Data Portability

  • Receive data in a structured format
  • Transfer data to another service provider

10.6 Right to Object

  • Object to data processing
  • Opt-out of marketing communications

10.7 Right to Withdraw Consent

  • Withdraw consent to data processing at any time
  • The right does not affect the legality of prior processing

10.8 EU GDPR Compliance

For users from the European Union, we ensure compliance with the General Data Protection Regulation (GDPR):

  • Legal bases for data processing: we process your personal data only when there are lawful bases, as specified in section 4 of this Policy.
  • Data minimization: we collect only the personal data necessary to provide our services.
  • Storage periods: Your personal data is stored no longer than necessary for the purposes of its processing.
  • After the term expires, the data is automatically deleted.
  • Breach notification: In case of a data security breach that may pose a high risk to your rights and freedoms, we will notify you and supervisory authorities within 72 hours of discovering the breach.
  • Data transfer outside the EU: when transferring your data outside the EU, we ensure an adequate level of protection in accordance with GDPR requirements.

11. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights, please contact us:

  • Email: support@sablesend.com
  • Via the feedback form on the website
  • Via the support system in the personal account

We will review your request within 30 days and provide a response.

11.1 Managing Your Information

You can manage your personal data independently:

Via personal account:

  • Changing username
  • Updating email address
  • Notification settings
  • Deleting uploaded files
  • Viewing activity history

Via account settings:

  • Changing language preferences
  • Managing privacy settings
  • Disabling automatic notifications

Via mobile application:

  • Managing app permissions
  • Setting up automatic upload
  • Changing notification settings

If you experience difficulties changing information independently, please contact support.

12. USE OF SERVICE BY MINORS

Our Service is not intended for individuals under 18 years of age.

We do not knowingly collect personal data from children under 18.

If we become aware of collecting data from a minor, we will take steps to delete such information.

13. CHANGES TO THE PRIVACY POLICY

We may periodically update this Policy.

We will notify you of significant changes by:

  • Posting the updated version on the website
  • Sending a notification to your email (for registered users)
  • Notifying in the mobile application

Continued use of the Service after the changes take effect signifies your agreement to the updated Policy.

14. CONTACT INFORMATION

For questions related to personal data processing, please contact:

Privacy Contact Person:

  • Email: support@sablesend.com
  • Website: https://sablesend.com/contacts

Support hours: 24/7

Average response time: up to 2 hours

This Privacy Policy is compiled in Russian.

In case of discrepancies between versions in different languages, the Russian version takes precedence.

Last updated: 25.06.2025