Date: April 3, 2024

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of users’  information (collectively “you”) when using our services and informs you of your privacy rights.

We may or may not use your personal data to improve our services. By using the service, you agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

  • Account: A unique account created to access areas of our website and advanced features as part of our service that is connected to an e-mail address.
  • Affiliate: An entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more equity interest or other securities entitled to vote for the election of directors or other managing authority.
  • Application: The software program provided by the company and downloaded by a user on a device.
  • Business: For the purposes of the CCPA (California Consumer Privacy Act) and any subsequent or related acts, refers to the company as the legal entity that collects consumers’ personal information and determines the purposes and means of the processing of consumers’ personal information or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in California.
  • Company: Our company is referred to as either “eSign,” “Company,” “we,” “us,” or “our”) which is under the name of eSignature LLC, with a mailing address of 301 W Platt St, A322, Tampa, FL 33606.
  • Consumer: For the purpose of the CCPA (California Consumer Privacy Act) and any subsequent or related acts, a consumer is a natural person who is a California resident. A resident includes (1) every individual in the USA other than for a temporary or transitory purpose and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Data Controller: For the purposes of the GDPR (General Data Protection Regulation), refers to the company as the legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.
  • Device: Any device that can access our website, such as a computer, mobile device, tablet, iPad, or digital screen.
  • Do Not Track (DNT): A concept that has been promoted by US regulatory authorities, particularly the U.S. Federal Trade Commission (FTC), for the internet industry to develop and implement a mechanism for allowing Internet users to control the tracking of their online activities across websites.
  • Facebook Fan Page: A public profile named eSign or any variation specifically created by the company on the Facebook social network and accessible at https://www.facebook.com/eSignApp.
  • Personal Data: Any information that relates to an identified or identifiable individual. For the purposes of GDPR, personal data refers to information relating to a user by name, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity. For the purposes of the CCPA, personal data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
  • Sale: For the purpose of the CCPA (California Consumer Privacy Act) and any subsequent or related acts, means the selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information to another business or a third party for monetary or other valuable consideration.
  • Service: Refers to any functionality of the website or application.
  • Service Provider: Any entity or individual who processes data or information on our behalf. Specifically, it may refer to third-party companies or individuals engaged by the company to assist in facilitating our services and provide assistance in any other manner that accesses user data. For the purpose of GDPR, service providers are considered data processors.
  • Third-party Social Media Service: Any website or social network through which a user can log in or create an account to use our website, application, and services.
  • Usage Data: Data collected automatically, either generated by the use of our services or from the website, application, or the infrastructure providing our services.
  • Website: Our website refers to any webpage, subdomain, or profile owned or operated by us, including our application. Our homepage is accessible at www.esign.com.
  • User: Referred to as “you,” “your,” or “user,” is an individual or entity accessing or using our website, application, or services. or the company. Such rights under this privacy policy shall be reserved only for those operating a device by a human. Under GDPR, this is sometimes referred to as the “data subject.”

Collecting Data

Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Email address;
  • First name, middle name, last name;
  • Street address, city, state, province, zip/postal code;
  • Phone number;
  • Payment information (such as credit card details); and
  • Usage data

Usage Data

Some usage data is collected automatically upon arrival when using our service, such as identifiers required for the functionality of the website.

Usage data may include information such as your device’s internet protocol address (IP address), browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic information.

When you access the service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device’s unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information your browser sends whenever you visit our service or access the website or application through a mobile device.

Information Collected while Using the Application

While using our website, service, and application, we may collect, with your prior permission, images and other information from your device’s camera and photo library.

We use this information to provide service features to improve and customize our service. The information may be uploaded to our servers and/or a service provider’s server or stored on your device.

You can enable or disable access to this information anytime through your device settings.

Cookies Policy

What are “Cookies”?

Cookies are small data files containing small amounts of information that are placed on your divide when visiting a website. Cookies are widely used by website owners in order to make their websites work more efficiently, as well as to provide reporting information. Cookies help us remember things about your visit, such as preferences and other settings, to make the site more functional and easier to use. They may also be used to deliver specific advertisements, services, or offers that apply to a user’s habits.

Cookies set by the website owner (in this case, our company) are called “first-party cookies.” Cookies set by parties other than the website owner are called “third-party cookies.” Third-party cookies enable third-party features or functionality to be provided on or through the website (such as advertising, features, and analytics). The parties that set these third-party cookies can recognize your device when it visits the website in question and when it visits certain other websites.

Why do we use Cookies?

We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons so that our website and its services operate and function as intended. We refer to these as “essential” or “strictly necessary” cookies that help to:

  • Login to our website;
  • Provide security;
  • Identify users, specifically to ensure that a user is the person they claim to be when creating an account or accessing and using our services;
  • Detect and reject spam, abuse, and other activities that violate our terms and conditions, and
  • To protect other users accessing our services.

Other cookies remember information about your browsing history and preferences. For example, cookies help us to remember your preferred language or the country you reside. We can then provide you with content in your preferred language without asking you each time you log in or visit our website.

Cookies also enable us to track and target the interests of our users to enhance the overall experience on our website. For example, these cookies help us test different versions of our website to see which particular features or content users prefer (also known as A/B testing).

Our Cookies

We DO NOT release any information derived from our cookies to any third parties other than service providers who assist us in these cookie activities.

To help us better understand how users interact with our website, certain first and third-party cookies we serve through our website for advertising, website functionality, analytics, and other purposes are mentioned in more detail below:

Types of Cookies Purpose Link to Cookies’ Policy
Payments To accept payments such as credit card transactions on our website and the saving of payment methods within your account. Stripe
Creation of an Account and Login To create a profile or account and login to the website using third-party platforms. Google, Facebook, Apple
Website Analytics To help better understand user behavior when interacting with the website. Google Analytics
Website Functionality Necessary for the function of the website and cannot be switched off. They are usually only set in response to actions you make that amount to a request for services, such as setting your privacy preferences, logging in, or utilizing a document with our systems. OneTrust

Other Tracking Technologies

Cookies are not the only way to recognize or track users on a website. We may use other similar technologies from time to time, such as web beacons (sometimes referred to as “tracking pixels” or “clear gifs”).

These are small graphics that contain a unique identifier that enables us to recognize when someone has visited our website or opened an e-mail that we have sent them. This allows us, for example, to monitor traffic patterns of users from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our website from an online advertisement displayed on a third-party website, to improve website performance, to measure the success of an e-mail campaign, or any other related reason. In many instances, these technologies rely on cookies to function properly, so declining cookies will impair their functioning.

Flash Cookies or Local Shared Objects

Our website may use technologies referred to as “Flash Cookies” (or “Local Shared Objects” or “LSOs”), among other types, to collect and store information about your use of our services, fraud prevention, and other website functionality and operation.

If you do not want Flash Cookies stored on your device, you can adjust the settings of your Flash Player to block Flash Cookies storage using the tools included in the website storage settings panel. You can also control Flash Cookies by going to the global storage settings panel and following the instructions (which may include instructions that explain, for example, how to delete existing Flash Cookies referred to as “information” on the Macromedia website), how to prevent Flash LSOs from being placed on your device without being asked, and (for Flash Player 8 and later) how to block Flash Cookies that are not being delivered by the operator of the page you are on at the time.

Please note that setting the Flash Player to restrict or limit acceptance of Flash Cookies may reduce or impede the functionality of some Flash applications, including, potentially, Flash applications used in connection with our services or online content.

Targeted Advertising

Third parties may serve cookies on your device that serve advertisements to our website. These companies may use information about your visits to our website, among other websites, to provide relevant advertisements about goods and services that you may or may not be interested in. They may also employ technology used to measure advertisements’ effectiveness. This can be accomplished by them using cookies or web beacons to collect information about your visits to this website and other websites related to goods and services of interest to you. The information collected through this process does not enable them or us to identify your name, contact details, or other personally identifying details unless you choose to provide and share.

Note that to the extent advertising technology is integrated into our website, you may still receive advertising content even if you opt out of targeted advertising. In such cases, the advertising content will not be tailored to your interests but will remain served to you.

Controlling Cookies

You can accept or reject cookies on our website by selecting the banner at the bottom of the webpage. If rejected, cookies will only be used for the website’s functionality. Any and all cookies used primarily for tracking and user behaviors will not be in use, and we shall store such decision of rejection in the event of an audit or other third-party request by a governing authority.

Such preference settings for cookies are set by each device and not by a user’s profile or account registered with us. If you decide to change your cookie preferences, you must clear your browser’s cookies and cache. This will remove saved data that websites use to identify returning visitors. However, doing this will log you out of most websites and might reset your preferences not just for our website but for any website saved or visited in the past.

Use of Personal Data

We may use your personal data for the following purposes:

  • To provide and maintain our service. This includes monitoring the usage of our website, application, and service.
  • To manage your account. To manage your registration as a user of our services. The personal data you provide can give you access to different functionalities of our website, application, and services available to you as a registered user.
  • Contact. To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • News and offers. To provide you with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  • To manage requests. To attend and manage your requests to us.
  • For business transfers. We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our service users is among the assets transferred.
  • For other purposes. We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our service, products, marketing, and overall experience.

We may share your personal information in the following situations:

  • With Service Providers. We may share your personal information with service providers to monitor and analyze the use of our service for payment processing, to contact you;
  • For business transfers. We may share or transfer your personal 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;
  • With Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any other subsidiaries, joint venture partners, or other companies we control or are under common control with us;
  • With business partners. We may share your information with our business partners to offer you certain products, services, or promotions;
  • With other users. When you share personal information or otherwise interact in public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures, and description of your activity. Similarly, other users can view descriptions of your activity, communicate with you, and view your profile;
  • With Your consent. We may disclose your personal information for any other purpose with your consent.

Retention of Personal Data

The company will retain your personal data only for as long as necessary for the purposes set out in this privacy policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our service, or we are legally obligated to retain this data for longer periods.

Transfer of Personal Data

Your information, including personal data, is processed at the company’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those from your jurisdiction.

Your consent to this privacy policy, followed by submitting such information, represents your agreement to such transfer.

The company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy, and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Disclosure of Personal Data

Business Transactions

If the company is involved in a merger, acquisition, or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

Law enforcement

Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The company may disclose your personal data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation;
  • Protect and defend the rights or property of the Company;
  • Prevent or investigate possible wrongdoing in connection with the Service;
  • Protect the personal safety of Users of the Service or the public; and
  • Protect against legal liability.

Security of Personal Data

The security of your personal data is important to us, but remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

Processing Personal Data

Service providers have access to your personal data only to perform their tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service providers to monitor and analyze the use of our service.

  • Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt out of having your activity made available to us in 1 of 2 ways:
    1. Opt-Out Browser Add-On. Installing the opt-out browser add-on is available for Google Chrome, Mozilla Firefox, Apple Safari, and Microsoft Edge. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information about visits activity with Google Analytics. You may opt out of certain Google Analytics features through your mobile device settings, such as your device advertising settings, or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy.
    2. Rejecting Consent. You may opt out of being tracked by Google Analytics by rejecting consent when arriving on our website. Your decision shall be stored in our records in connection to your IP Address for auditing purposes only.

Email Marketing

We may use your personal data to contact you with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.

We may use e-mail marketing service providers to manage and send emails to you.

Payments

As part of our service, we have paid features that give advanced accessibility to your account. To pay for such features, we may use third-party services to process and store your payment details. For easier access to changing payment methods and updating a plan on your account, we may hold your payment details including your billing details.

Such payment processors for our website, service, and application utilized by us are as follows:

GDPR Privacy

Processing Personal Data

We may process personal data under the following conditions:

  • Consent. You have given your consent to process personal data for one or more specific purposes;
  • Performance of a contract. Provision of personal data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
  • Legal obligations. Processing personal data is necessary for compliance with a legal obligation to which we are subject;
  • Vital interests. Processing personal data is necessary to protect your vital interests or that of another natural person;
  • Public interests. Processing personal data is related to a task that is carried out in the public interest or the exercise of official authority vested in us; and
  • Legitimate interests. Processing personal data is necessary for the legitimate interests pursued by us.

In any case, we will gladly help clarify the specific legal basis that applies to the processing, particularly whether the provision of personal data is a statutory or contractual requirement or a requirement necessary to enter into a contract.

Rights under GDPR

The company undertakes to respect the confidentiality of your personal data and to guarantee you can exercise your rights.

You have the right under this privacy policy, and by law if you are within the European Union, to:

  • Request access to your personal data. The right to access, update, or delete the information we have on you. Whenever possible, you can access, update, or request the deletion of your personal data directly within your account settings section. If you cannot perform these actions yourself, please contact us to assist you. This also enables you to receive a copy of the personal data we hold about you;
  • Request correction of the personal data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected;
  • Object to processing of your personal data. This right exists where we are relying on a legitimate interest as the legal basis for our processing, and there is something about your particular situation, which makes you want to object to our processing of your personal data on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes;
  • Request the erasure of your personal data. You have the right to ask us to delete or remove personal data when there is no good reason for us to continue processing it;
  • Request the transfer of your personal data. We will provide to you, or to a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you; and
  • Withdraw your consent. You have the right to withdraw your consent to use your personal data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the service.

Exercising GDPR Rights

You may exercise your rights of access, rectification, cancellation, and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority office.

Facebook Fan Page

Data Controller for the Facebook

We, the company, is the data controller of your personal data collected while using the service. As the operator of the Facebook fan page https://www.facebook.com/eSignApp, we and the operator of the social network (Facebook) are joint controllers.

We have entered into agreements with Facebook that define the terms for use of the Facebook fan page, among other things. These terms are mostly based on the Facebook terms of service: https://www.facebook.com/terms.php

Visit the Facebook privacy policy https://www.facebook.com/policy.php for more information about how Facebook manages personal data or contact Facebook using the resources below:

  • Contact Page: www.facebook.com/help
  • Mailing Address: Facebook, Inc. ATTN, Privacy Operations, 1601 Willow Road, Menlo Park, CA 94025, USA

Facebook Insights

We use the Facebook insights function in connection with the operation of the Facebook fan page and on the basis of the GDPR to obtain anonymized statistical data about our users.

For this purpose, Facebook places a cookie on the user’s device visiting our Facebook fan page. Each cookie contains a unique identifier code and remains active for a period of two years, except when it is deleted before the end of this period.

Facebook receives, records, and processes the information stored in the cookie, especially when the user visits the services provided by other members of the Facebook fan page and services by other companies that use Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook privacy policy here: https://www.facebook.com/full_data_use_policy

CCPA Privacy

This privacy notice section for California residents supplements the information contained in our privacy policy, and it applies solely to all visitors, users, and others who reside in California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information that we may collect or may have collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but it reflects our good-faith belief, to the best of our knowledge, that some of that information from the applicable category may be and may have been collected.

Category A – Identifiers. Examples include a user’s real name, alias, postal address, unique personal identifier, online identifier, internet protocol (IP) address, email address, account name, driver’s license number, passport number, or other similar identifiers.

  • Do we collect? Yes

Category B: Personal information categories. Examples include a user’s name, signature, Social Security number (SSN), physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

  • Do we collect? Yes

Category C: Protected classification characteristics. Examples include a user’s age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

  • Do we collect? No (unless uploaded by the user and stored in their My Documents area)

Category D: Commercial information. Examples include a user’s records and history of products or services purchased or considered.

  • Do we collect? Yes

Category E: Biometric information. Examples include a user’s genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

  • Do we collect? Yes

Category F: Internet or other similar network activity. Examples include a user’s interaction with our service or an advertisement.

  • Do we collect? Yes

Category G: Geolocation data. Examples include a user’s approximate physical location.

  • Do we collect? Yes

Category H: Sensory data. Examples include a user’s audio, electronic, visual, thermal, olfactory, or similar information.

  • Do we collect? Yes

Category I: Professional or employment-related information. Examples include a user’s current or past job history or performance evaluations.

  • Do we collect? No (unless uploaded by the user and stored in their My Documents area)

Category J: Non-public education information. Examples include education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

  • Do we collect? No (unless uploaded by the user and stored in their My Documents area)

Category K: Inferences drawn from other personal information. Examples include a user’s profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Do we collect? No (unless uploaded by the user and stored in their My Documents area)

Not Included Under CCPA

Under CCPA, personal information does not include:

  • Publicly available information from government records
  • Deidentified or aggregated consumer information
  • Information excluded from the CCPA’s scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. Through forms or when details are entered using our website, application, or service.
  • Indirectly from You. From observing your activity on our service.
  • Automatically from You. Through cookies which we or our service providers set on your device as you navigate and use our services.
  • From Service Providers. For example, third-party vendors to monitor and analyze the use of our service, third-party vendors for payment processing, or other third-party vendors that we use to provide the service to you.

Use of Personal Information for Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

  • To operate our Service and provide You with our Service.
  • To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.
  • To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to You when collecting Your personal information or as otherwise set forth in the CCPA.
  • For internal administrative and auditing purposes.
  • To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal Iinformation, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity

Share of Personal Information

We may share your personal information identified in the above categories with the following categories of third parties:

  • Service providers;
  • Payment processors;
  • Our affiliates;
  • Our business partners; and
  • Third-party vendors to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

Sale of Personal Information of Minors Under 16 Years of Age

We do not sell the personal information of consumers We actually know are less than 16 years of age, unless We receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has provided Us with personal information, please contact Us with sufficient detail to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If You are a resident of California, You have the following rights:

  • The right to notice. You have the right to be notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to request. Under CCPA, You have the right to request that We disclose information to You about Our collection, use, sale, disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:
    • The categories of personal information We collected about You
    • The categories of sources for the personal information We collected about You
    • Our business or commercial purpose for collecting or selling that personal information
    • The categories of third parties with whom We share that personal information
    • The specific pieces of personal information We collected about You
    • If we sold Your personal information or disclosed Your personal information for a business purpose, We will disclose to You:
      • The categories of personal information categories sold
      • The categories of personal information categories disclosed
  • The right to say no to the sale of Personal Data (opt-out). You have the right to direct Us to not sell Your personal information. To submit an opt-out request please contact Us.
  • The right to delete Personal Data. You have the right to request the deletion of Your Personal Data, subject to certain exceptions. Once We receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless an exception applies. We may deny Your deletion request if retaining the information is necessary for Us or Our Service Providers to:
    • Complete the transaction for which We collected the personal information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing business relationship with You, or otherwise perform our contract with You.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
    • Debug products to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if You previously provided informed consent.
    • Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with Us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of that information that are compatible with the context in which You provided it.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer’s rights, including by:
    • Denying goods or services to You
    • Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
    • Providing a different level or quality of goods or services to You
    • Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

  • Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an authorized representative
  • Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if We cannot:

  • Verify Your identity or authority to make the request
  • And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request’s receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The opt out will place a cookie on Your computer that is unique to the browser You use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

  • “Opt out of Interest-Based Ads” or “Opt out of Ads Personalization” on Android devices
  • “Limit Ad Tracking” on iOS devices

You can also stop the collection of location information from Your mobile device by changing the preferences on Your mobile device.

Do Not Track Policy as Required by CalOPPA

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Your California Privacy Rights (California’s Shine the Light law)

Under California Civil Code Section 1798 (California’s Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties’ direct marketing purposes.

If you’d like to request more information under the California Shine the Light law, and if You are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Deletion Request

You have the right to request that we delete any personal information we collect from you, subject to certain exceptions. Unless an exception applies, we will delete your personal information from our records once we receive and confirm your verifiable consumer request.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. Complete the transaction for which we collected the personal information, provide a good or service you requested, take reasonably anticipated actions within the context of our ongoing business relationship with you, or otherwise perform our contract with you. Some financial records may be kept for accounting purposes.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  5. Comply with a legal obligation.
  6. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request by emailing us at support@esign.com.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: