Privacy Policy

1. Scope

This Privacy Policy describes how FileSentinel, LLC ("FileSentinel," "we," "us," or "our") collects, uses, and discloses personal information through our website at filesentinel.app, our secure document collection portal at vault.filesentinel.app, our GoHighLevel (GHL) Marketplace application, and any related services (collectively, the "Services").

FileSentinel serves two groups of users: Agency Users (CPA firms, bookkeepers, financial advisors, and other professional services firms that install and administer FileSentinel through GHL) and End Clients (the firms' clients who receive magic links and upload documents). This Policy applies to both groups unless otherwise noted.

This Policy applies to:

• the FileSentinel marketing and information website at filesentinel.app
• the secure document upload portal at vault.filesentinel.app (accessed via magic link)
• the FileSentinel GHL Marketplace application and admin sidebar panel
• transactional email communications sent via Resend on behalf of Agency Users
• any SMS or other communications we may send in connection with the Services

This Policy does not govern the independent data practices of GoHighLevel or other third-party platforms.

Agency Users act as the primary data controllers for their clients' information. FileSentinel acts as a data processor on behalf of Agency Users when handling End Client data.

2. Information We Collect

A. Information provided directly

• End Client name and email address (provided by Agency Users when creating document requests)
• Documents and files uploaded by End Clients, which may include tax returns, financial statements, bank records, identification documents, insurance records, and other sensitive materials
• Agency User account information: firm name, GHL location ID, notification email, branding preferences, and custom domain settings
• Communications you send us, including support requests, feedback, and inquiries
• Payment-related information processed through GHL Marketplace (not stored directly by FileSentinel)

B. Information collected automatically

• IP address and approximate geolocation (city-level, derived from IP)
• Browser type, operating system, and device information
• Magic link access events: timestamp of link redemption, IP address, and user agent
• File upload timestamps and file metadata (filename, size, content type)
• Portal activity events: checklist item views, annotation events, and document access requests
• Aggregate, non-personally-identifiable edge analytics via Cloudflare

C. Information from third parties

• GoHighLevel: contact name, email, and GHL contact ID when Agency Users sync contacts via OAuth
• GHL Marketplace: billing and subscription status for Agency User accounts
• Cloudflare: infrastructure-level security signals and WAF threat intelligence

3. How We Use Your Information

We use information we collect to:

• Generate and deliver magic links to End Clients on behalf of Agency Users
• Process, store, and make uploaded documents available to the requesting Agency User
• Send transactional email notifications to Agency Users (upload received, portal accessed, link expiring)
• Maintain an audit trail of portal activity for each document request
• Provision, manage, and authenticate Agency User accounts
• Enforce link expiry, revocation, and security controls
• Detect and prevent fraud, unauthorized access, and abuse of the Services
• Comply with legal obligations and respond to lawful government requests
• Operate, maintain, and improve the Services
• Communicate with Agency Users about the Services, updates, and support

We do not use End Client documents for any purpose beyond storing them for retrieval by the Agency User that created the request. We do not sell, license, or use uploaded documents for advertising, analytics, or AI model training.

4. Calls, Texts & Automated Messages

FileSentinel's primary communication channel is transactional email. Magic links and portal notifications are delivered via email through our Resend integration.

When you provide a phone number in connection with the Services, or where Agency Users configure SMS delivery of magic links through GHL, you or your clients may receive text messages. By providing a phone number, you acknowledge that:

• message frequency may vary
• message and data rates may apply
• consent to receive messages is not a condition of purchase or use of the Services
• you may reply STOP at any time to opt out of text messages
• you may reply HELP for help, where supported
• wireless carriers are not liable for delayed or undelivered messages

FileSentinel does not place outbound phone calls, conduct automated or prerecorded calling campaigns, or use AI-generated voice communications.

To revoke consent to receive text messages, reply STOP to any message or contact us using the information in Section 18. We will honor revocation requests within no more than 10 business days.

5. Consent Records

Where we rely on consent for communications or data practices, we maintain records of:

• The form, page, or mechanism through which consent was given
• The date and time of consent
• The disclosure language presented at the time of consent
• The email address or phone number provided
• IP address or other submission metadata
• Subsequent opt-out or preference changes

We also log magic link issuance events, first access events (timestamp and IP), and file upload events as part of the portal activity audit trail.

Agency Users may access their own portal activity logs through the FileSentinel admin panel. End Clients may request a copy of their activity record by contacting us using the information in Section 18.

6. Cookies & Analytics

• Session tokens: short-lived, cryptographically signed tokens used to authenticate portal access. Not used for tracking or advertising.
• Cloudflare edge analytics: aggregate, anonymized traffic data. No persistent cross-site tracking cookies are placed for analytics purposes.
• No advertising cookies: we do not use advertising networks, retargeting pixels, or third-party tracking scripts on the portal or admin interface.

The marketing website at filesentinel.app may use standard analytics tools to measure site performance. You may enable browser privacy settings or Global Privacy Control (GPC) to limit analytics tracking.

7. Children's Privacy

The Services are designed for use by professional services firms and their adult business clients. The Services are not directed at children under the age of 13, and we do not knowingly collect personal information from anyone under 13 (or under 16 where required by applicable state law).

If you believe we have inadvertently received personal information from a child under 13, please contact us immediately using the information in Section 18. We will promptly delete such information.

8. Sensitive Financial Documents

End Clients may upload documents containing sensitive personal and financial information, including:

• Federal and state tax returns and related schedules
• Bank statements and financial account records
• Pay stubs and income documentation
• Social Security numbers and government-issued identification
• Investment and retirement account statements
• Legal documents such as wills, trusts, or estate planning records
• Insurance policies and claims documentation
• Mortgage applications, loan records, and credit documentation

FileSentinel treats all uploaded documents as sensitive. We do not open, read, analyze, or process the contents of uploaded files beyond the technical operations necessary to store them securely and make them available to the Agency User that created the request. All files are encrypted at rest in Cloudflare R2 and accessible only to the Agency User account that initiated the request.

Agency Users collecting documents from clients subject to GLBA, IRS recordkeeping requirements, state CPA licensing rules, or other regulatory frameworks remain solely responsible for their own regulatory compliance. FileSentinel is a technology service provider and does not independently assume compliance obligations under those frameworks.

9. How We Disclose Your Information

A. Agency Users

End Client information (name, email, uploaded documents, and portal activity) is made available to the Agency User (the GHL account) that created the document request. Agency Users are responsible for handling this information in accordance with their own privacy policies and applicable legal obligations.

B. Service providers

We share information with trusted service providers that perform functions on our behalf:

• Cloudflare - infrastructure, file storage (R2), database (D1), CDN, and security services
• Resend - transactional email delivery
• GoHighLevel - OAuth authentication, contact data sync, and billing processing

These providers access information only as necessary to deliver services on our behalf and are bound by appropriate data protection obligations.

C. Legal and safety disclosures

We may disclose information when required by applicable law, subpoena, court order, or government request, or when we believe in good faith that disclosure is necessary to prevent harm, fraud, or illegal activity.

D. Business transfers

If FileSentinel is acquired, merged, or transfers substantially all of its assets, personal information may be transferred as part of that transaction. We will provide advance notice if such a transfer materially changes how your information is used.

10. Data Retention

• Uploaded documents - retained until the Agency User deletes them or the account is terminated. Agency Users should establish their own retention policies consistent with applicable regulatory requirements.
• Portal activity logs - retained for a minimum of 12 months from the date of the event.
• Magic link tokens - expire after the configured period (72 hours to 7 days) and are cryptographically invalidated on expiry, revocation, or rotation. Token hashes are retained for audit purposes.
• Agency User account data - retained for the duration of the active subscription and for a reasonable period after termination.
• Consent records - retained for a minimum of 4 years, or longer where required by applicable law.

Upon a verified written deletion request from an End Client, and subject to legal hold obligations, we will delete or de-identify personal information within a reasonable timeframe not to exceed 45 days.

11. Data Security

We implement reasonable administrative, technical, and physical safeguards, including:

• Encryption at rest - all uploaded documents stored in Cloudflare R2, encrypted using AES-256
• Encryption in transit - all data transmitted protected by TLS (HTTPS), enforced at Cloudflare's edge
• Token security - magic link dispatch tokens are single-use, SHA-256 hashed, and expire automatically; session tokens are short-lived and cryptographically signed
• Tenant isolation - every database query scoped to a unique account_id; R2 storage paths prefixed per account; no cross-tenant data access through the API
• HMAC-signed webhooks - all incoming GHL webhooks verified against a shared HMAC secret before processing
• Rate limiting and WAF - Cloudflare WAF enforces rate limits (10 token validation attempts per IP per minute) and DDoS protection
• No raw secrets stored - no plaintext credentials, tokens, or sensitive values stored in the database; only cryptographic hashes

No method of transmission or storage is completely secure. If you believe a security incident has occurred, please contact us immediately using the information in Section 18.

12. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Access - request a copy of the personal information we hold about you
• Correction - request that we correct inaccurate or incomplete personal information
• Deletion - request that we delete your personal information, subject to legal retention requirements
• Portability - request your personal information in a structured, machine-readable format
• Opt out of sale - we do not sell personal information; no action is required to opt out
• Non-discrimination - we will not discriminate against you for exercising your privacy rights

For End Clients: We recommend contacting your CPA firm, bookkeeper, or financial advisor directly to exercise your rights with respect to documents you have uploaded. FileSentinel will cooperate with Agency Users in responding to client requests.

To submit a privacy rights request to FileSentinel directly, contact us using the information in Section 18. We will respond within 45 days of a verified request.

13. State-Specific Disclosures

California (CCPA / CPRA)

California residents have rights under the CCPA and CPRA, including the right to know, delete, correct, and opt out of the sale or sharing of personal information. We do not sell or share personal information for cross-context behavioral advertising. Contact us using the information in Section 18 to submit a CCPA request. We will respond within 45 days and will not charge a fee for your first request in a 12-month period.

Virginia, Colorado, Connecticut, Texas, and other state privacy laws

Residents of states with comprehensive consumer privacy laws have rights to access, correct, delete, and port their personal information, and to opt out of certain processing. We honor verified requests from residents of all states with applicable privacy law protections.

Washington (My Health MY Data Act)

Where the Services incidentally process health-related personal information belonging to Washington residents, we treat such data as sensitive personal information subject to WMHMDA protections.

Nevada

FileSentinel does not sell personal information under NRS Chapter 603A. No action is necessary for Nevada residents to opt out.

14. Text Message Program Disclosures

Where we offer an SMS or MMS messaging program in connection with the Services:

• message frequency may vary
• message and data rates may apply
• consent is not a condition of purchase or use of the Services
• reply STOP to opt out of text messages
• reply HELP for help, where supported
• wireless carriers are not liable for delayed or undelivered messages

We may use third-party messaging platforms to operate these programs.

To opt out of text messages from FileSentinel, reply STOP to any message or contact us using the information in Section 18. To opt out of messages sent by your Agency User (CPA firm, financial advisor, or other service provider) through GHL, contact them directly or reply STOP to their messages.

15. AI & Automated Communications

FileSentinel uses automated systems to deliver transactional messages on behalf of Agency Users, including:

• Automated email notifications when documents are uploaded or a magic link is first accessed
• Automated magic link generation and delivery triggered by Agency User actions
• Automated link expiry warnings sent to Agency Users before portal links expire

These messages are transactional in nature, not marketing messages. They are sent on behalf of the Agency User (your professional service provider) and relate directly to your document request.

FileSentinel does not currently use generative artificial intelligence to create or personalize communications sent to End Clients. Uploaded documents are not processed by, shared with, or used to train AI models.

Agency Users who use GHL's AI features are subject to GHL's own terms and disclosures for AI-assisted communications, separate from FileSentinel's Services.

16. Third-Party Links & Services

The Services may contain links to or integrations with third-party platforms, including GoHighLevel, Cloudflare, and Resend. FileSentinel is not responsible for the privacy, security, or content practices of any third party. Review the privacy policies of any third-party services you interact with through or alongside the Services.

FileSentinel's integration with GoHighLevel operates under the GoHighLevel Terms of Service and Privacy Policy. Agency Users are responsible for ensuring that GHL account practices comply with applicable law.

17. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will provide at least 14 days' advance notice via email to Agency Users or by posting a prominent notice on the Services.

Your continued use of the Services after the effective date of any update constitutes your acceptance of the revised Policy.

18. Contact Us

For questions about this Privacy Policy, to exercise your privacy rights, or to report a security concern:

FileSentinel, LLC
[Mailing Address Line 1]
[City, State ZIP Code]

Email: [email protected]
Website: filesentinel.app

We will respond to privacy rights requests within 45 days of a verified request. For urgent security matters, include "SECURITY" in the subject line of your email.