Privacy Policy

Last updated August 6, 2026

This Privacy Notice for refile ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our document generation services ("Services"), including when you visit our website, register for an account, or interact with our API.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. Emil Lienemann is a sole proprietor (Einzelunternehmer) based at Beermannstraße 4, 12435 Berlin, Germany, and is responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not ask you to provide sensitive personal information as account data. Documents you submit may nevertheless contain special-category or otherwise sensitive information, which is processed only to provide the document generation service.
Do we collect any information from third parties? We may collect information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information? We process your information to provide, improve, and administer our document generation Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. As a business based in Germany, we adhere to GDPR requirements and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG). Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
HOW DO WE HANDLE YOUR SOCIAL LOGINS?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
HOW LONG DO WE KEEP YOUR INFORMATION?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACK FEATURES
DO WE MAKE UPDATES TO THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
API SECURITY AND USAGE PATTERNS
SELF-HOSTED DEPLOYMENTS

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register for refile's document generation Services, express an interest in obtaining information about us or our Services, when you interact with our API, or otherwise when you contact us.

This personal information may include:

Name
Email address
Business information
Login credentials
Billing information
API usage patterns

Input Content and Generated Documents. When you use our Services, we process the content you provide (in various input formats) for the purpose of generating output documents. While we do not review this content manually, our systems need to process it to deliver the service. We maintain metadata about document generation for billing and service improvement.

Sensitive Information. We do not ask you to provide sensitive information as account data. Because refile processes user-supplied document content, your inputs may contain special-category or otherwise sensitive personal information. We process that content only to generate the requested output. You must ensure that you are authorized to submit it and avoid including sensitive information that is not necessary for the requested service.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our document generation API, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our document generation Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication for our document generation API
To process your API requests and deliver generated documents
To respond to user inquiries and offer support
To enable user-to-user communications (if applicable)
To manage user accounts and provide service notifications
To protect our Services from abuse and malicious users
To send administrative information regarding our Services
To respond to legal requests and prevent harm
To monitor API usage for optimization and improvement purposes
To process input content and convert it to the requested output format
To track document theme usage for service improvement (anonymized)

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Service Providers. We may share your information with service providers that we use to support our document generation API, such as cloud infrastructure providers, payment processors, and customer support tools.

The service providers used by the hosted version of refile include:
- Vercel for website hosting, serverless infrastructure, Vercel Blob storage for generated files, and Speed Insights. Depending on how you use the Services, Vercel may process technical request data, IP addresses, generated documents, download URLs, and performance data.
- Neon for the PostgreSQL database used to store account, authentication, subscription, API usage, and service metadata.
- Google for Google account sign-in. Google provides us with the account details you authorize, such as your name, email address, and profile image.
- Polar for checkout, payments, subscriptions, invoicing, and the customer billing portal. Polar processes the information required to complete and administer your purchase.
- PostHog for website analytics, page views, page-leave events, product feedback, and service telemetry. This may include technical and usage data, event properties, and the URL of the page being viewed.
- Upstash for Redis-based rate limiting and abuse prevention. Upstash may process IP addresses, API-key-derived identifiers, request counters, and timestamps.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions related to our document generation capabilities.
Third-Party Integrations. Our service integrates with various platforms including but not limited to Zapier, n8n, Make, iOS Shortcuts, and AI services like ChatGPT, Claude, and TypingMind. When you choose to use these integrations:
- You are responsible for reviewing and agreeing to their respective privacy policies
- We share only the information necessary to facilitate the integration
- The implementation and data handling practices of these integrations are controlled by their respective providers
- We do not store conversations between you and AI services, but merely facilitate the connection

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

For our document generation API, we primarily use cookies for authentication purposes and to maintain your session while using our Services. These are essential for the proper functioning of our API services.

We use PostHog for website analytics, page-view and page-leave measurement, product feedback, and service telemetry, and Vercel Speed Insights for performance measurement. These providers may use online tracking technologies when you use the hosted Services. We do not use tracking technologies for advertising purposes.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your Google account. Where you choose to do this, we receive the profile information authorized through Google, which may include your name, email address, and profile picture.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our API services are hosted on global edge servers to provide fast and reliable document generation services worldwide. If you are accessing our Services from outside Germany, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" above), in Germany, the European Union, United States, and other countries globally where our edge servers are located.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law, including using Standard Contractual Clauses and other appropriate data transfer mechanisms where necessary.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

For users of our document generation API:

We retain account information for the duration of your subscription or usage of our Services
Input content and generated documents may be stored for up to 365 days depending on your plan
When you request a download URL for a document, that URL remains valid for up to 14 days
Storage duration may differ between free and paid plans as shown on our pricing page

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at hi@refile.co.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: As a German business subject to the GDPR and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG), we respect your right to access, correct, request deletion, or request restriction of our usage of your personal information.

Your GDPR and German Data Protection Rights:

Right to be informed - about the collection and use of your personal data
Right of access - to your personal data
Right to rectification - if your personal data is inaccurate or incomplete
Right to erasure - or "right to be forgotten"
Right to restrict processing - of your personal data
Right to data portability - to receive your data in a structured format
Right to object - to processing of your personal data
Rights in relation to automated decision making and profiling

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us by:

Data Controller: Emil Lienemann Sole proprietor (Einzelunternehmer)

Email: hi@refile.co

Postal mail: Emil Lienemann Beermannstraße 4 12435 Berlin, Germany

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.

Under the GDPR and the German Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG), we are committed to fulfilling these rights. To request to review, update, or delete your personal information, please submit a request by emailing us at hi@refile.co.

We will respond to your request within 30 days as required by the GDPR.

14. API SECURITY AND USAGE PATTERNS

In Short: We implement multiple layers of security for API access and monitor usage patterns.

We take the security of your API access seriously:

API keys are randomly generated with strong entropy
We recommend regular rotation of API keys as a security best practice
We monitor API usage patterns to detect unusual activity that may indicate unauthorized access
Different security measures may apply to free versus paid tiers as outlined on our pricing page

When you use our API, we collect metadata about your usage patterns, including frequency, volume, and types of operations. This information helps us improve our service, diagnose issues, and protect against abuse.

15. SELF-HOSTED DEPLOYMENTS

In Short: Self-hosting options, if available, shift certain privacy responsibilities to you.

If you choose to use a self-hosted deployment of our service (if available):

You become the data controller for any personal information processed through your self-hosted instance
We do not have access to the content processed by your self-hosted deployment
We may collect licensing and basic usage information necessary to validate your subscription
You are responsible for implementing appropriate security measures for your deployment
You must ensure your deployment complies with applicable data protection laws in your jurisdiction

Self-hosted deployments provide greater control over your data but also transfer responsibility for privacy compliance to you.