Last updated: 27 June 2026
1. Who we are
FILOTRON is provided by Cogent Logic Limited, a company registered in England & Wales (company number 13830535), registered office 8 The Quadrant, Buxton, SK17 6AW, United Kingdom (VAT No. GB 405914408). For the limited personal data described below, Cogent Logic Limited is the data controller. You can reach us at customers@cogentlogic.com.
2. Our privacy principle
FILOTRON is designed so that your everyday use is anonymous. You sign in only to do two things:
- Purchase a subscription and set up a security certificate on your first device; and
- Set up a security certificate on each subsequent device you add.
Once a device has its certificate, your account identity is not stored on it. When your devices connect to one another, no account information travels between them. As a result, all peer-to-peer (device-to-device) operations are 100% anonymous, and the security certificates on your devices contain no real-world identity.
In short: we touch your identity only to let you pay and to issue device certificates — never during the file management and transfers you do day to day.
3. What we collect, and why
| Data | Why | Notes |
|---|---|---|
| Sign-in identity | To create your account so you can subscribe and obtain device certificates. | Your email address, and a name if your provider supplies one, from Apple, Google, Microsoft or email sign-in, plus an internal account identifier. |
| Subscription status | To know whether you have an active Pro plan and apply your device limit. | Held against your account identifier. We do not receive or store your card or payment details — those are handled by Apple, Google or Paddle. |
| Device registry | To manage the devices in your fleet and enforce device limits. | A non-identifying device identifier and a friendly name for each device you enrol, linked to your account. These are not your real identity and are not embedded in certificates. |
We do not use analytics, advertising or tracking of any kind, in the app or on this website.
4. What we never see
- Your files and transfers. File contents move directly between your devices over an end-to-end encrypted, peer-to-peer connection. We do not host, route through, observe or back up your files.
- Your peer-to-peer activity. Because no account information is present on devices after setup, device-to-device activity cannot be linked back to your account.
- Your identity in certificates. Device certificates carry no personal data and no real-world identity.
5. Service providers
We use a small number of trusted providers to operate the parts of the Service that involve your account. They process data only as needed to provide their function:
| Provider | Role |
|---|---|
| Supabase | Authentication and the account database (sign-in, account identifier, device registry, subscription status). |
| RevenueCat | Subscription management — records whether your account has an active plan. |
| Apple, Google, Microsoft | Sign-in identity providers, when you choose to sign in with one of them. |
| Paddle | Payment processor and Merchant of Record for purchases on Windows and Linux. |
| FILOTRON Certificate Authority | Issues the security certificates your devices use, without learning your account identity. |
Apple, Google and Apple/Google app stores, and Paddle, also act as independent controllers of the payment and store data they hold under their own privacy policies.
6. Legal bases (UK GDPR)
- Performance of a contract — to create your account, take payment, issue device certificates and provide the Service you have purchased.
- Legitimate interests — to keep the Service secure and prevent abuse (for example, enforcing device limits), balanced against your rights.
- Legal obligation — where we must keep certain records (for example, for tax).
7. International transfers
Some of our providers operate outside the United Kingdom (for example, in the United States or the European Economic Area). Where account data is transferred internationally, we rely on appropriate safeguards, such as the UK’s International Data Transfer Agreement or Standard Contractual Clauses, as applicable.
8. Retention & account deletion
We keep account data for as long as your account is active and as needed to provide the Service, then delete or anonymise it, except where we must retain certain records by law (for example, tax records). You can delete your account at any time from within the app; deleting your account removes your account data, cancels active processing, and revokes your devices’ ability to be managed under that account.
9. Your rights
Subject to UK data-protection law, you have the right to access, correct, delete, restrict or object to the processing of your personal data, and to data portability. To exercise any of these, email customers@cogentlogic.com. You also have the right to complain to the UK Information Commissioner’s Office (ICO) at ico.org.uk, though we’d appreciate the chance to help first.
10. Children
FILOTRON is not directed at children under 16, and we do not knowingly collect personal data from them. If you believe a child has provided us with personal data, contact us and we will delete it.
12. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version here with a new “last updated” date, and where changes are material we will take reasonable steps to bring them to your attention.
13. Contact
For any privacy question or request, email customers@cogentlogic.com, or write to Cogent Logic Limited, 8 The Quadrant, Buxton, SK17 6AW, United Kingdom.