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PRIVACY NOTICE - YOUR PRIVACY RIGHTS

Effective Date: January 1, 2018

Last Updated: October 11, 2023





ABOUT THIS PRIVACY NOTICE

This Privacy Notice describes the information and collection practices on the
websites, mobile applications, products, and services (collectively “Services”)
that link to this Privacy Notice. These Services are provided by the provider
companies listed on https://www.signnow.com/contracting-entities . It does not
apply to our use of employee or job applicant information.

We adhere to the principles of the EU-U.S. Data Privacy Framework (DPF), the
Swiss-U.S. DPF, and the UK extension to the EU-U.S. DPF. To learn more,
click here.


We may process your personal information under an agreement with a third party
and act as a data processor. For example, if a business customer uploads a
contract for signature we will process the information under instructions from
the customer. In those cases, the terms of that agreement may also govern how
your information is used. If you believe a third party has asked us to process
your personal information on their behalf, please contact them first.

NOTICE OF COLLECTION



COLLECTION OF PERSONAL INFORMATION


The type of personal information we collect depends on your relationship with us
and the Services you use. California law requires us to tell you if we share
information for cross-contextual behavioral advertising. Described below by
category is the information we may collect. We also indicate if we share it for
cross-contextual behavioral advertising. To learn how to modify your
cross-contextual advertising preferences, view our  Notice of Right to Opt-out
of Sale/Sharing:

 * Contact information. This includes your name and email address. It also
   includes a mailing address, phone number, or electronic signature.
 * Commercial information. This includes billing and payment information (e.g.,
   credit card number, expiration date), products or services purchased.
 * Geolocation. This includes physical location and precise location including
   when you sign up for or use our Services as well as when you sign an
   electronic document.
   
 * Submitted information. We collect any information you submit to us. This
   includes feedback or questions.
 * Usage Information. We collect personal information about how you use our
   Services and the devices you use to access our Services including (i) logs
   and session data, (ii) browser and operating system information, (iii) which
   site or mobile application you came from, (iv) which site you visit when you
   leave us, (v) areas of our site or mobile application you visit and any
   actions you make, and (vi) your IP address. We also collect device
   identifiers. This might include your hardware model and operating system. In
   some cases, we may share this information for the purposes noted below.
 * Transactional data. We may collect the names and email addresses of parties
   to a transaction. We may also collect the subject line and the history of an
   individual's actions in connection with a transaction. We may also collect
   personal information about those individuals or their devices. This might
   include name, email address, IP address, and authentication methods.

We do not use or disclose sensitive personal information, as defined by
California law, for inferring characteristics or for purposes other than those
permitted by law.



USE OF PERSONAL INFORMATION


We use information for the following reasons:

 * To respond to your request and communicate with you. We use information to
   create your account and manage your relationship with us. This includes
   communication about our terms and policies. We use information to respond to
   your questions. These may be customer service questions or questions about
   product education and training.
   
 * To provide and improve our Services. We use information to provide you with
   our Services. For example, we record details about transactions involving
   electronic documents. We use information to collect payments and respond to
   related inquiries. We use information to make our Services better and develop
   new features. This also includes customizing your experience with us. We may
   also use information to analyze how our Services are used.
   
 * To conduct marketing activities. We use information to let you know about new
   features and products. These might be our offers or products, or third-party
   offers or products we think you might find interesting. We may also let you
   know about special events. We may do this by phone, online, or by email. We
   may use information to conduct surveys or run sweepstakes or other contests.
   
 * To protect our company and constituents. We use information to protect our
   company and customers, and users. This includes complying with our legal
   obligations. We use information to identify fraud and secure our systems and
   Services.

We use information for other purposes as permitted by law or as we may disclose
to you.

EU Lawful Basis for Processing Your Personal Information. If UK or European data
protection law applies and where we act as a data controller, our lawful basis
for collecting and using the personal information described here will depend on
the type of personal information and the specific context in which we collect or
use it. In those cases, we either use information (i) where we have your consent
to do so, (ii) where we need the personal information to provide you with
Services or to perform a contract with you, or (iii) where the processing is in
our legitimate interests and not overridden by your data protection interests or
fundamental rights and freedoms. We may have a legal obligation to collect or
retain personal information or may need the personal information to protect your
vital interests or those of another person. For example, when we:

 * Use personal information to create and manage an account, we do so to provide
   you with relevant Services and perform our contract with you.
   
 * Gather and record data associated with the use of a digital certificate or
   electronic signature. We do so to comply with regulations.
   
 * Use names and email addresses for email marketing purposes, we do so with
   your consent (which you can withdraw at any time) or, where permitted under
   applicable law, based on our legitimate interests.
   
 * Gather usage data and analyze it to improve our Services, make conscientious
   adjustments to meet our growing customer base’s needs, or ensure the security
   of our Services, we do so based on our legitimate interest in safeguarding
   and improving our Services.

More information


We do not use or disclose sensitive personal information, as defined by
California law, for inferring characteristics or for purposes other than those
permitted by law. Review our  retention practices below. For more information
about our privacy practices, read the rest of this Privacy Notice below.



HOW WE COLLECT INFORMATION


Information we collect directly from you. We collect information if you create
an account or contact us. We also collect information when you start, sign,
edit, fill in, or review an electronic document. We collect information when you
participate in surveys or sign up for communications and when you engage with us
on social media or community forums. This could be done in person, online, or by
phone.

Information we collect automatically and passively. We collect information about
users over time and across different websites and applications. We also work
with third parties that collect personal information this way. We use several
common tracking tools to collect information. Tracking tools include browser
cookies and web beacons. To learn more about cookies, visit FTC’s Online
Tracking  here . We may work with others to gather information on our platforms
and elsewhere. We may do this on our websites and in emails we send to you. We
collect information about users over time when you use our websites. For choices
you may have on what information we automatically collect, please see  Your
Choices below.

Information we collect from others. Business partners may provide information
about you to us. This includes marketers, partners, and researchers. If you
register for our Services on another website, the website may provide your
personal information to us. Other customers may give us your personal
information. For example, a customer might send you a document to fill out and
sign. When they d o, they will give us your email address and name. If a
customer wants to add you to an existing account, they will send us information
about you. Referral sources will share information about you to send a referral.
If you use a third-party profile to set up your account with us, we will receive
information associated with that third-party profile.

We Combine Information

We may combine the personal information we receive from other sources with the
personal information we collect from you and use it as described here. This
includes information received through LinkedIn, Apple Sign-In, Microsoft, Google
OneTap, and Facebook. We also combine information we collect from you online
with information we receive from you offline. We combine information that we
have collected across third-party platforms. We combine information across
devices.



DISCLOSING INFORMATION TO OTHERS


We disclose personal information as follows:

 * Service Providers. We share all categories of your information with service
   providers to support our Services. These include providers of smart search
   technology and data analytics. It also includes quality control, security and
   advertising providers. We may also share all categories of information with
   payment processing or fraud detection services. It also includes
   authentication systems and customer support providers.
 * Affiliates. We may share all categories of information with other companies
   under our common ownership or control. These companies use your personal
   information as described in this Privacy Notice. This includes current and
   future companies. For a current list of our contracting entities, please
   visit: https://www.signnow.com/contracting-entities.
 * Marketing Partners. We may share your contact information with sponsors of
   events, webinars, or sweepstakes for which you register or other parties with
   whom we may engage in joint marketing activities.
 * Public or Government Authorities. We may share all categories of information
   to comply with our legal obligations, regulations, or contracts or to respond
   to a court order, administrative, or judicial processes, such as a subpoena,
   government audit, or search warrant where we are legally required to do so.
   We also may share your information when there are threats to the physical
   safety of any person, violations of our policies or other agreements, or to
   protect the legal rights of third parties, including our employees, users, or
   the public.
 * Corporate Transactions. All categories of your personal information may be
   disclosed or transferred to relevant third parties in the event of, or as
   part of the due diligence for, any proposed or actual reorganization, sale,
   merger, consolidation, joint venture, assignment, transfer, or other
   disposition of all or part of our business, assets, or stock (including in
   connection with any bankruptcy or similar proceeding).
 * Other internal users. When you allow others to access, use, or edit content
   in your account, we share that content with them. For example, if you send a
   document to others for review or signature, we make the contents of the
   document available to them. When you create a profile, other users may be
   able to view your profile information.
 * Public Information. Information that you have made publicly available (your
   public profile or discussion forum) will be made broadly available to others.
   When you comment on our social media pages or in our community forums, this
   information may also be read, collected, and used by others. This could be
   used to contact you, send you unsolicited messages, or for purposes neither
   we nor you have control over. We are not responsible for personal or any
   other information you submit in these forums.
 * Your Employer or Organization. When you create an account or user role with
   an email address assigned to you as an employee, contractor, or member of an
   organization (e.g., yourname@youremployer.com or yourname@nonprofit.org) or a
   personal email that you are authorized to use with an organization (e.g.,
   yourname@gmail.com), that organization (if it is our customer with certain
   features) can find your account and take certain actions that may affect your
   account, including monitoring the activity, suspending, and terminating your
   account. If you have questions or concerns about the level of access and
   control your employee or organization has over your account, you should
   contact them for more information.
 * Consent. We may share your personal information in other ways if you have
   asked us to do so or you have given consent. For example, you may ask us to
   send your personal information to a third party of your choosing.

We may share information for other reasons we may describe to you or as
otherwise permitted by law.






RETENTION OF PERSONAL INFORMATION


We keep your personal information for as long as necessary or relevant for the
purposes for which it is processed. We also keep information as required by law.
You can control and delete documents in your account at any time. If the
document has been shared with another party, it will remain visible to them
until either they delete it or it is deleted by all parties with access to the
document.


Your Choices


You have certain choices described here. You can also decide what information
you give us. If you do not provide us with certain personal information, you may
not be able to use some parts of our Services. For example, if you do not adopt
an electronic signature, then you will not be able to sign certain documents
electronically. This section describes other choices you have:

 * Profile. You are not required to fill out a profile. If you do, you can
   access and review this personal information. If any personal information is
   inaccurate or incomplete, you can make changes in your account settings. We
   may make changes to your account if the change is requested by you, your
   employer (if the account is used for business purposes), or our business
   customer who controls your account.
 * Marketing. You can opt out of email marketing messages we send you by
   clicking on the “unsubscribe” link in the email message or by visiting the 
   Privacy Request Portal. Please note that we may send you one message to
   confirm you want to opt out. We will continue to send transactional or
   relationship messages after you opt out of marketing messages. If you would
   like your phone number added to our Do-Not-Call list to opt out of
   telemarketing messages, please visit the  Privacy Request Portal.
 * Cookies and Other Related Technology. You can manage cookies through your
   browser settings or our Cookie Preference Center and other methods detailed
   in our Cookie Notice ( https://www.signnow.com/cookies). However, if you
   decline cookies, you may not be able to use some parts of our Services.
 * Shine the Light. California residents may ask for a list of third parties
   that have received their personal information for direct marketing purposes
   during the previous calendar year. This list also contains the types of
   personal information shared. We provide this list at no cost. If you are a
   California resident and would like to request this information, please
   contact us via the  Privacy Request Portal.
 * Device and Usage Information. If you do not want us to see your device
   location, you can turn off location sharing on your device, change your
   device privacy settings, or decline to share the location on your browser.
 * Closing Your Account. If you wish to close your account, please log in to
   your account and delete the account through account settings. If you need
   assistance closing your account, you can contact the support team through the
   means described on the relevant website. Please include in your email your
   first name, last name, company (if applicable), and a list of Services you
   wish to cancel. As part of our security and privacy practices, we are unable
   to go into your account to delete any documents or export certain documents
   as it would require us to have direct access to the documents in your
   account. If you intend to close your account with us, we encourage you to
   export all necessary documents before closing your account. Once an account
   has been closed we will deactivate your account and within a reasonable
   amount of time begin the process to delete the account along with any
   remaining documents. Once the deletion process is complete we cannot
   guarantee that you will be able to re-activate your account or recover
   documents associated with your original account.

Children and Our Services


Our Services are not designed for and are not marketed to children under 18. We
do not knowingly collect personal information from children. Users of our
services may send forms or notices that gather personal information about
minors. Users are responsible for obtaining appropriate consents. If you are a
parent or legal guardian and believe we have your child’s information, please
contact us through the  Privacy Request Portal. We will delete personal
information that we learn is collected from a minor.


Your Privacy Rights


Under certain laws you may have additional rights related to your personal
information. Those rights are described in more detail below. To exercise any of
these rights, please visit the  Privacy Request Portal.

 * You can access and review personal information associated with your account
   that you have provided us by logging into your account with us and reviewing
   the information listed in your profile.
 * You can request to know the following:
 * How we collect and use your personal information and why;
 * The categories of personal information we have collected and the categories
   of recipients of your personal information;
 * How we received your personal information and its source;
 * Our business purpose for using your personal information; and
 * How long we use or store your personal information or the manner in which we
   determine relevant retention periods.

 * You have a right to correct inaccurate personal information about you.
 * In certain situations, you can request that we erase/delete or stop using
   your personal information.
 * In certain situations you can object to or restrict our use of your personal
   information.
 * You have the right to ask us to export your personal information to another
   third party of your choosing or provide you with a  copy of your personal
   information.
 * Where we rely on your consent to process your personal information, you
   can withdraw consent you may have already provided at any time. This will not
   affect the lawfulness of the processing prior to the withdrawal of your
   consent. You have the right not to be discriminated against for exercising a
   privacy right.
 * If you are unsatisfied with our response to your complaint, you have a right
   to raise questions or complaints with your local data protection authority at
   any time.

Notice of Right to Opt-out of Sale/Sharing. California, Nevada, and Virginia law
require that we tell you if we sell personal information to a third party for
monetary or (in California) other valuable consideration. We do not do this. We
also do not sell personal information of minors under the age of 16 for monetary
or other valuable consideration. We may share information with third parties in
order to provide cross-contextual behavioral advertising. This sharing provides
you with more tailored and personalized content and ads. In the Notice at
Collection (above), we outlined which categories of information are shared for
cross-contextual behavioral advertising. Some browsers also allow you to tell
websites not to share your information for cross-contextual behavioral
advertising. We will respond to these signals in a frictionless manner. If you
configure this setting on your browser, certain features on our site may not
work and you will receive less targeted advertising. To learn how to configure
this setting, view  here . Additionally, the Self-Regulatory Program for Online
Behavioral Advertising provides consumers with the ability to manage certain
choices online  here  and provides a tool for managing mobile choices here .
Selections are browser and device-specific.

How it works. If you wish to exercise these rights, please contact us via the 
Privacy Request Portal. For security purposes and as required by law, if you
make a request to exercise the rights referenced above, we will require you to
provide certain information for identity verification purposes. If you have an
account with us, we may verify you through the login of your account. If you do
not have an account with us, we may require you to provide additional
information from which we can confirm your identity. Where permitted by law you
may authorize an agent to make a request to us on your behalf, and we will
verify the identity of your agent or authorized legal representative by either
seeking confirmation from you or documents that establish the agent’s
authorization to act on your behalf.

Exceptions. In some cases, we may not be able to complete your request because
an exception exists under applicable law. For example, we may need to keep some
information to provide the Services.


Transfers to the U.S. and Third Countries


EU-U.S. / Swiss-U.S. Data Privacy Framework. We participate in the EU-U.S. Data
Privacy Framework (DPF), the Swiss-U.S. DPF, an the UK extension to the EU-U.S.
DPF. We comply with the DPF Principles with respect to personal information
transferred from the EEA, Switzerland, and UK to the United States in reliance
on the DPF. If there is any conflict between the terms in this Privacy Notice
and the DPF Principles, the DPF Principles shall govern. To learn more about the
DPF program, and to view our certification, please
visit www.dataprivacyframework.gov. 

airSlate, Inc.’s controlled U.S. subsidiaries and affiliates, as identified in
our self-certification and below, also adhere to the DPF Principles:

 * AIRSLATE LEGAL FORMS, INC.
 * DOCHUB LLC
 * INSTAPAGE, INC.

We are subject to the investigatory and enforcement powers of the U.S. Federal
Trade Commission. If third-party agents process personal information on our
behalf in a manner inconsistent with the DPF Principles, we remain liable unless
we prove we are not responsible for the event giving rise to any damages. If you
have a question or complaint related to our compliance with the DPF Principles,
please contact us as indicated at the bottom of this Privacy Notice. For any
complaints related to the DPF that cannot be resolved with us directly, you may
refer the matter, free of charge, to JAMS Mediation, Arbitration and ADR
Services, an independent dispute resolution body based in the United States, at
https://www.jamsadr.com/eu-us-data-privacy-framework. Finally, under limited
circumstances and after other available dispute resolution mechanisms have been
exhausted, binding arbitration is available to address certain residual
complaints under the DPF not resolved by other means
(see https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf for
details).

For other transfers to Third Countries, we have adopted the Standard Contractual
Clauses to facilitate the transfer of personal information from the European
Economic Area, Switzerland, and/or United Kingdom to our company and affiliates,
and/or service providers outside of these countries. Transfers outside the group
of our companies are only made to organizations that agree to adhere to the
security and privacy standards in our Data Processing Addendum and our Standard
Contractual Clauses or use another valid alternative under data protection law.
You may view our Data Processing Addendum and Standard Contractual Clauses
at https://www.signnow.com/dpa .

Security Measures


We use reasonable security measures as required by relevant law. The Internet is
not 100% secure. We cannot promise that your use of our sites or platforms will
be completely safe. We encourage you to use caution when using the Internet.
This includes not sharing your passwords.


Third-Party Sites and Links


If you click on a link to a third-party website, you will be taken to sites we
do not control. This includes our social media pages. These third-parties’
privacy practices may be different than ours, and our Privacy Notice does not
apply to their actions. We are not responsible for these third-party practices
and encourage you to read their privacy notices carefully.


Changes to This Privacy Notice


We may make changes or updates to this Privacy Notice. We will notify you of any
material changes to this Privacy Notice as required by law. This may include
posting changes on our website. Please check our site periodically for updates.


How to Contact Us


For questions or complaints regarding our use of your personal information or
this Privacy Notice, please contact us via email or by sending a letter to
airSlate Inc. Attention: Data Privacy Officer, 17 Station Street, 3rd Floor,
Brookline, Massachusetts 02445.

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