Switching to another provider

This page gives the information referred to in Section 7.5 of the Terms of Service: how to switch, the available formats and their limitations, and the measures taken to protect data against unlawful access by non-EU authorities. We treat Chapters VI and VII of Regulation (EU) 2023/2854 (the Data Act), on switching and on access by non-EU authorities, as applying to the Service, with or without an Account.

How to switch

You may at any time ask to move your Files, Transfer metadata and Account data to another provider or to your own systems, or to have them erased. Write to info@letmedrop.com and, if you are moving to another provider, tell us which. The switch needs no more than two months' notice and is free of charge.

We then keep providing the Service and allow the export of those data for 30 days, which you may extend once, and for a further 30 days in which any data not yet exported can still be retrieved. Files that would expire during the first period are kept until it ends. Throughout, we give you reasonable assistance, tell you of any known risk to the continuity of the Service and keep your data secure.

Once the switch is complete, the contract ends and we tell you so, any prepaid subscription fees for the remaining period are refunded within 14 days, and the data are erased, save for the records that the Privacy Policy states are kept for longer.

What can be moved

• Files: every File of your Transfers that has not been deleted.
• Transfer metadata: for each Transfer, its dates, status and price, and the name, size and type of each File.
• Account data: your Account record, subscriptions, payments, invoice records, contract confirmations, legal acceptances and the other records named in the next section.

Data structures and formats

This section is the register of the structures and formats in which those data are available.

The holder of an Account downloads the export from the Account's settings page. A Sender without an Account has no such page and asks at info@letmedrop.com.

The data file has three top-level sections: export_metadata, portable_per_art20 and access_per_art15. The last of them holds user_record_full, accounts, sessions, subscriptions, subscription_payments, subscription_plan_changes, subscription_plan_change_withdrawals, withdrawal_requests, withdrawal_handlings, transfers, payments, invoices, contract_confirmations, download_charges, iban_change_requests, iban_change_logs, legal_document_acceptances, files_metadata, subscription_events, account_deletion_requests, branding, beneficiary_details_change_logs, payout_batches, payout_events and connected_accounts. The guide in the ZIP file explains them section by section.

There is no separate programming interface. The ways to take data out are the download link and the export, both over HTTPS. The link of a Drop & Charge Transfer asks whoever opens it for the Recipient's price, so for those Files ask at info@letmedrop.com: moving them is free of charge.

Limitations

• The export holds the metadata of the Files, not their contents.
• We keep no backups of Files, so a File that has been deleted cannot be recovered. Please keep your own copies.
• Files do not stay for ever. A Transfer expires at the end of the period the Sender chose, 30 days at most, and its Files are then deleted within 24 hours. A Transfer whose payment or upload is not completed within 48 hours of its creation lapses, and its Files are deleted within a further 24 hours (Section 7.2 of the Terms of Service and Section 8 of the Privacy Policy).
• A large ZIP archive (over 4 GB) may not open with the tool built into your computer. You can also download the Files one by one.
• The export covers the Service's account database. It does not hold, for example, support correspondence, server logs or the invoice documents themselves. The guide in the ZIP file lists those categories and says how to ask for them.
• Storage paths, security tokens and upload state are internal to the Service and are not moved. The identifiers of other people are left out of the export, and an IBAN appears masked.

Protection against unlawful access by non-EU authorities

Where the data are, and under which jurisdiction. Files are stored with Cloudflare R2, in a bucket created under its European Union jurisdictional restriction, in data centres located exclusively in the EU/EEA. Account data and Transfer metadata are held on our server, whose hosting and data centre providers are in Portugal and the Netherlands, and the backups of our databases are stored exclusively in EU/EEA data centres. So that infrastructure is subject to the law of the countries where it stands. Cloudflare belongs to a US-based group, so we assume that it may receive requests from United States authorities. The Service is operated from Portugal, and the Terms of Service are governed by Portuguese law.

Encryption. Connections to the Service use HTTPS. At rest, the storage provider encrypts Files with AES-256, under keys that it manages. We add no encryption of our own to Files.

Providers outside the EEA. Content delivery and protection against attacks, which Cloudflare provides, may involve processing outside the EEA. Cloudflare, Google, Sentry and GoDaddy (which registers some of our domains and receives only our own data) belong to US-based groups and may process data in the United States. Where they do, it is only with the safeguards required in the EU, namely the European Commission's adequacy decision for the EU-US Data Privacy Framework, for providers certified under it, or standard contractual clauses approved by the European Commission.

Requests from authorities. We may have to share data with public authorities, including courts, where the law requires it. Cloudflare's data processing addendum provides that, if it becomes aware of third-party legal process requesting personal data that it processes for a customer, it notifies the customer immediately unless that is legally prohibited, tells the requester that it may not disclose the data without the customer's consent, directs the requester to the customer and, if it does disclose, discloses the minimum it is legally required to. Where it identifies that such a request from a government authority raises a conflict of law, it pursues legal remedies, up to an appellate court, before producing the data. These steps do not apply where it believes in good faith that the request is necessary because of an emergency involving danger of death or serious physical injury; it then notifies the customer of the disclosure as soon as possible afterwards, unless that is legally prohibited.

Non-personal data. Files can hold non-personal data, and the location and the encryption above apply to every File alike. Cloudflare's addendum speaks of personal data, and a request made to Cloudflare may not reach us. Under Article 32 of the Data Act, a decision of a court or authority outside the Union on non-personal data held in the Union is recognised only if it rests on an international agreement, or where the conditions of its paragraph 3 are met. If such a request reaches us, we follow that Article: we give the minimum amount of data permissible, and we tell the customer before complying, unless the request serves law enforcement and telling would defeat it.

You can ask for more information, including a copy of the applicable safeguards, at info@letmedrop.com.