Filen
A single roll-up of ownership and CLOUD Act exposure.
-
EU-Sovereign EU/EEA/Switzerland-owned and -operated, with no identified CLOUD Act exposure.
-
EU-Based This listing EU-operated, with at most minor or transient US exposure.
-
EU-Hosted EU hosting available, but a US parent or hyperscaler sub-processor creates material exposure.
-
US-Linked Operated by a US-incorporated entity, directly subject to US jurisdiction.
German zero-knowledge E2E cloud (Filen Cloud Dienste UG, Recklinghausen, 2021), Tier IV ISO 27001 DCs, no US data, open source apps.
Filen is a European service hosted in Germany, with at most minor, transient US exposure under the CLOUD Act. It is listed under File sharing.
Assessment notes
Filen Cloud Dienste UG (Recklinghausen, Germany; founded mid-2021 by Jan Lenczyk, Jan Kulartz, and Phil Hedrich) runs an explicit ''next-generation zero-knowledge end-to-end encrypted cloud'' from Tier IV ISO 27001-certified German data centres with no data stored in the United States, AES-256 client-side encryption, open-source applications on GitHub, and a founder-led cap table with no external venture capital; sub-processors are disclosed on the /privacy page (Stripe IE, PayPal US, Cloudflare US, Sentry US); EU-owned and EU-hosted with only minor CLOUD Act exposure: the US-jurisdiction sub-processors are all transient (payments, error telemetry, bot protection) and, because storage is zero-knowledge end-to-end encrypted, none of them can read file content; zero-knowledge E2E encryption, open-source clients, and disclosed sub-processors; the key documentation gap is no standalone public DPA URL.
Findings
- CLOUD Act
- CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
-
None EU operator, no US parent, no US sub-processors of note.
-
Minor This listing A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
Material US parent, or a core sub-processor is a US-owned hyperscaler.
-
Direct The operator itself is US-incorporated.
-
- Ownership
- Ownership
Where ultimate control over the operating company sits.
-
EU-owned This listing EU-incorporated and EU-controlled; no significant US ownership.
-
EU HQ, US-funded EU-headquartered but US venture- or PE-controlled.
-
EU subsidiary, US parent European operating company owned by a US parent company.
-
US-owned The operating company itself is US-headquartered.
-
Other A non-EU jurisdiction. Swiss/EEA-owned vendors count as European here; the UK and others do not.
-
- Sub-processors
- 7 · 5 US
Verified signals
-
EU / adequacy hosting: Yes
-
EU / adequacy operator: Yes
-
No US CLOUD Act exposure: Not assessed
-
Public DPA: No
-
Sub-processors disclosed: Yes
-
Open-source clients: Yes
-
Third-party certification: No
Jump to
About Filen
Filen is a German-headquartered zero-knowledge end-to-end encrypted cloud-storage product operated by Filen Cloud Dienste UG (haftungsbeschränkt), founded in mid-2021 in Recklinghausen, Germany by Jan Lenczyk (CEO + CTO), Jan Kulartz (COO + CMO), and Phil Hedrich (CDO + Customer Care). The product is structurally similar to Mega and Internxt (every file is encrypted on the user's device with AES-256 before it leaves the client, the encryption keys never reach Filen's servers, and the company mathematically cannot read uploaded content) and ships as Filen Drive, Filen Notes, Filen Chats, Filen Sync, and a network-drive client across Windows, macOS, Linux, iOS, Android, and the web. The applications are open source on GitHub for independent audit.
For an EU-sovereignty audit Filen is among the cleanest listings in the file-sharing category. All servers are located in Germany in Tier IV ISO 27001-certified high-security data centres across multiple regions for disaster-recovery redundancy. The vendor states explicitly that no data is stored in the United States, an unusually strong commitment for a product at this price point. German data-protection law (Bundesdatenschutzgesetz) applies on top of GDPR, and the UG legal structure is a German limited-liability format. The ownership chain is clean: founder-led with no VC/PE investors on record. Customer keys, file content, file names, and metadata are all encrypted client-side: zero-knowledge end-to-end. Among the strong EU-owned file-sharing alternatives (Proton Drive, Tresorit, Internxt, Filen, Cryptee), Filen wins on price-to-performance for users who want German jurisdiction specifically.
Pricing is the most aggressive in the directory's encrypted-cloud category: free tier available with limited storage; Pro I starts at €1.99/month for 200 GiB; Pro II / III / IV scale up with more storage and higher upload caps; unlimited bandwidth, uploads, client-side encryption, syncing, and file sharing across all paid tiers. No lifetime plans (vendor explicitly opts out). Best fit: privacy-conscious individuals and small teams who want German jurisdiction, zero-knowledge encryption by default, open-source apps, and aggressive pricing; particularly relevant for journalists, NGOs, and SMBs in DACH.
Sub-processor map · 7
-
Cloudflare, Inc. USUnited States
Bot protection via Turnstile (Standard Contractual Clauses)
-
Coinbase Inc. USUnited States
Cryptocurrency payment processing (Standard Contractual Clauses)
-
PayPal Inc. USUnited States
Payment processing (Standard Contractual Clauses)
-
Sentry Inc. USUnited States
Error management / telemetry (Standard Contractual Clauses)
-
Stripe Payments Europe Ltd. USIreland
Payment processing
-
Fider EUGermany
Feature-suggestion tool (open source, self-hosted by Filen on its German infrastructure)
-
Plausible Analytics EUEstonia
Web analytics (self-hosted by Filen in Germany)
| Vendor | Country | Purpose | Owner |
|---|---|---|---|
| Cloudflare, Inc. | United States | Bot protection via Turnstile (Standard Contractual Clauses) | US |
| Coinbase Inc. | United States | Cryptocurrency payment processing (Standard Contractual Clauses) | US |
| PayPal Inc. | United States | Payment processing (Standard Contractual Clauses) | US |
| Sentry Inc. | United States | Error management / telemetry (Standard Contractual Clauses) | US |
| Stripe Payments Europe Ltd. | Ireland | Payment processing | US |
| Fider | Germany | Feature-suggestion tool (open source, self-hosted by Filen on its German infrastructure) | EU |
| Plausible Analytics | Estonia | Web analytics (self-hosted by Filen in Germany) | EU |
Source: the vendor’s published sub-processor list, read 26 Aug 2026.
Frameworks & certifications · none listed
Capability matrix
Table 2Capabilities of Filen
Integration & access
Compliance & governance
Pricing & tiers
Public documents
Alternatives in this category
-
Switzerland · €4/moEU-BasedCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
-
None EU operator, no US parent, no US sub-processors of note.
-
Minor This listing A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
Material US parent, or a core sub-processor is a US-owned hyperscaler.
-
Direct The operator itself is US-incorporated.
Public DPA: Yes Sub-processors: Yes Open source: No -
-
Switzerland · €10/moEU-HostedCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
-
None EU operator, no US parent, no US sub-processors of note.
-
Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
Material This listing US parent, or a core sub-processor is a US-owned hyperscaler.
-
Direct The operator itself is US-incorporated.
Public DPA: Yes Sub-processors: Yes Open source: No -
-
Switzerland · €4/moEU-SovereignCLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
-
None This listing EU operator, no US parent, no US sub-processors of note.
-
Minor A transient US sub-processor (CDN, maps); data at rest stays in the EU.
-
Material US parent, or a core sub-processor is a US-owned hyperscaler.
-
Direct The operator itself is US-incorporated.
Public DPA: Yes Sub-processors: No Open source: No -
| Product | Sovereignty | CLOUD Act | Signals | From |
|---|---|---|---|---|
Proton Drive
Switzerland
|
EU-Based | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Yes
Sub-processors: Yes
Open source: No
|
€4/mo |
Tresorit
Switzerland
|
EU-Hosted | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Yes
Sub-processors: Yes
Open source: No
|
€10/mo |
kDrive (Infomaniak)
Switzerland
|
EU-Sovereign | CLOUD Act exposure
How exposed customer data is to US authorities under the CLOUD Act (Clarifying Lawful Overseas Use of Data Act).
|
Public DPA: Yes
Sub-processors: No
Open source: No
|
€4/mo |