Privacy Policy
Last updated: 1 July 2026
files22 (“we”, operated by XXII Solutions) runs a file-sharing service. This policy explains, plainly, what we collect and why. We collect broadly to operate the service, prevent abuse, and comply with the law.
What we collect
- Account data — your identifier, email, and name from sign-in.
- IP addresses — on every request, including uploads and downloads.
- Full request headers — on every direct access to a share link (download/preview) we record the complete set of HTTP request headers, including user-agent, referrer, and device/client hints.
- Download & usage behaviour — what you download or share, when, how much, how fast, how often, and from where.
- Share-access events — each time a shared file or folder is opened.
- File metadata — names, sizes, types, timestamps, and storage usage.
- Payment data — subscription status via our processor (Creem); we do not store card numbers.
How we use it
- Operating the service (storage, sharing, download throttling, quotas).
- Security and abuse prevention — detecting malware, fraud, and prohibited content.
- Analytics and product improvement.
- Complying with legal obligations and responding to lawful requests.
Retention
We keep logs and metadata for as long as needed for the purposes above, and may retain aggregated or anonymised data indefinitely. Deleted files are removed from active storage and purged from backups on a rolling schedule.
Sharing & disclosure
We share data with infrastructure providers (Cloudflare) and our payment processor, and with authorities where required by law or to address illegal content or abuse.
Legal basis & your rights
Depending on your location (e.g. the EEA/UK under the GDPR), you may have rights to access, correct, or delete your data. Our lawful bases include performing our contract with you, our legitimate interests in running and protecting the service, and consent where required. This policy is provided for transparency and is not legal advice.
Contact
Questions or requests: privacy@files22.cc.