Effective Date: October 1, 2020
Seal’s core product and Services help users create, complete, and show the validity of digital or electronic transactions, such as electronically signing a contract for mobile phone services or placing a digital signature on a loan application. As part of our Services, users want us to collect and record information that helps the parties prove the validity of the transactions. This information includes the persons who are involved in the transactions and the devices those persons use.
1. How We Collect Personal Information
Personal Information We Collect from You. You provide us with personal information about yourself when you:
Register or log in to your account
Start, sign, or review an electronic document
Create or edit your user profile
Contact customer support
Comment on our blogs or in community forums
You also provide us with personal information about others when you use parts of our affiliate Services, such as when you:
Start or participate in an electronic transaction, such as an envelope within DocuSign Signature
Share information in a Room
Add others as a member to an existing account
Examples of the categories of personal information you provide are:
Identifiers: name, email address, mailing address, phone number, or electronic signature.
Commercial information: billing information, products or services purchased.
Geolocation: physical location
The categories of personal information we automatically collect includes:
Device, Usage Information, and Transactional Data. We may collect personal information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Some examples include:
Precise geolocation information that you allow our apps to access (usually from your mobile device)
Unique device identifiers and device attributes, like operating system and browser type
Usage data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information
Transactional data, such as: names and email addresses of parties to a transaction, subject line, history of actions that individuals take on a transaction(e.g. review, sign, enable features) and personal information about those individuals or their devices, such as name, email address, IP address, and authentication methods
Information We Collect from Other Sources. We may collect personal information about you from others, such as:
Third-Party Sources. Examples of third-party sources include marketers, partners, researchers, affiliates (like companies under common ownership or control of DocuSign), service providers, and others where they are legally allowed to share your personal information with us. For example, if you register for our Services on another website, the website may provide your personal information to us.
Other Customers. Other customers may give us your personal information. For example, if a customer wants you to sign an electronic document in our Services, he or she will give us your email address and name.
Personal Information We Collect & Process on Behalf of Customers. When our business customers use certain Services, we generally process and store certain personal information on their behalf as a data processor. For example, in Seal Software when a customer uploads contracts or other documents for review, we act as a data processor and process the documents on the customer's behalf and in accordance with their instructions. In those instances, the customer is the data controller and is responsible for most aspects of the processing of the personal information. If you have any questions or concerns about how personal information is processed in these cases, including how to exercise your rights as a data subject, you should contact the customer (either your employer or the individual requesting your signature). If we receive any rights requests concerning instances where we act as data processor, we will forward your query on to the relevant customer.
We collect your personal information to provide and improve our Services and to support advertising and marketing. See Section 2 Use of Personal Information for additional information.
We may share your personal information with third parties as provided in Section 3 Personal Information Sharing.
2. Use of Personal Information
In general, we collect, use, store, and process your personal information to provide our Services, to fix and improve them, to develop new Services, and to market our companies and their products and Services. Here are some examples of how we use the personal information we process:
Provide you with the Services and products you request and collect payments
Create your account and manage your relationship with us
Send you records of our relationship, including for purchases or other events
Market features, products, or special events using email or phone or send you marketing communications about third party products and services we think may be of interest to you
Record details about what happens with electronic documents, such as who viewed or signed, the devices used and when these events occur
Run sweepstakes, contests, and refer-a-friend programs
Choose and deliver content and tailored advertising, and support the marketing and advertising of our Services
Create and review data about our users and how they use our Services
Test changes in our Services and develop new features and products
Fix problems you may have with our Services, including answering support questions and resolving disputes
Manage the Services platform including support systems and security
Prevent, investigate and respond to: fraud, unauthorized access to or use of our Services, breaches of terms and policies, or other wrongful behavior
Comply with legal obligations
Meet legal retention periods
Other Uses. We may combine the personal information we collect (“aggregate”) or remove pieces of personal information (“de-identify”) to limit or prevent identification of any particular user or device to help with goals like research and marketing. Once such information has been aggregated and anonymised so that it is no longer considered personal information under data protection law, this Privacy Notice does not apply.
We normally collect or use personal information from you or others only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, 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 in order to provide you with relevant Services and perform our contract with you.
Gather and record data associated with use of a digital certificate or digital signature, it is 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, on the basis of our legitimate interests.
Gather usage data and analyze it to improve our Services or ensure the security of our websites for example, we do so based on our legitimate interest in safeguarding and improving our Services.
3. Personal Information Sharing
We share personal information as follows:
Service Providers. We share your personal information with other companies we use to support our Services. These companies provide services like intelligent search technology, intelligent analytics, advertising, authentication systems, bill collection, fraud detection, and customer support. We have contracts with our service providers that address the safeguarding and proper use of your personal information.
Marketing Partners. We may share your personal information with sponsors of events, webinars or sweepstakes for which you register, or other parties with whom we may engage in joint marketing activities.
Business Transactions. We may share your personal information during a corporate transaction like a merger, or sale of our assets, or as part of the due diligence for such contemplated transactions. If a corporate transaction occurs, we will provide notification of any changes to control of your personal information, as well as choices you may have.
Consent. We may share your personal information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you.
Your personal information may also be shared as described below:
Other Seal Software 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 an envelope to others for review or signature, we make the contents of the envelope available to them.
Third Parties. When you make a payment to another user within our Services, we share your payment method details with the third-party payment processor selected by you or the other user.
User-Generated Content. When you comment on our blogs or in our community forums, this information may also be read, collected, and used by others.
Profile Information. When you create a DocuSign profile, other DocuSign users can view your profile information. If you would like to make this information private, please visit your account settings.
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, such as email@example.com firstname.lastname@example.org, that organization (if it is a DocuSign customer with certain features) can find your account and take certain actions that may affect your account.
4. Retention of Personal Information
We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it.
See Section 5 for choices about storage of your personal information.
5. Your Choices
This section describes many of the actions you can take to change or limit the collection or use of your personal information.
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.
Marketing Messages. You can opt out of email marketing messages we send. You can opt out of these messages by clicking on the “unsubscribe” link in the email message or unsubscribe here (https://get.docusign.com/global-unsubscribe). Please note that we may send you one message to confirm you want to opt out. If you are a registered user of our Services, or if you have engaged in transactions with us, we may continue to send transactional or relationship messages (e.g., signing notifications or account notifications) after you opt out of marketing messages. If you would like your phone number added to our internal Do-Not-Call list to opt out of telemarketing messages, please contact us at https://support.docusign.com/SAR. Please include your first name, last name, company, and phone number. You can also let us know during a telemarketing call that you do not want to be called again for telemarketing purposes.
Cookies and Other Related Technology. You can decline cookies through your browser settings or via the DocuSign Cookie Preference Center and other methods detailed in our Cookie Notice (https://www.docusign.com/company/cookie-policy). However, if you decline cookies, you may not be able to use some parts of our Services. Please note we do not recognize or respond to browser-initiated Do Not Track signals.
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 location on your browser.
Closing Your Account. If you wish to close your Seal service account, please contact your Seal representative. If you wish to close your account for the affiliated DocuSign Signature service, please log in to your account and edit your plan. For more information click here (https://support.docusign.com/en/articles/How-do-I-cancel-or-downgrade-my-account).
6. Children's Privacy
Our Services are not designed for and are not marketed to people under the age of 16 (“minors”). We do not knowingly collect or ask for personal information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your personal information. We delete personal information that we learn is collected from a minor without verified parental consent. Please contact us using https://support.docusign.com/SAR if you believe we might have personal information from or about a minor.
7. Your Privacy Rights
You may have certain rights related to your personal information, subject to local data protection laws. These rights may include:
As a DocuSign Signature customer, you can access and review personal information associated with your account at any time by clicking here (https://support.docusign.com/en/guides/ndse-user-guide-manage-your-identity). For all other services, you can request the following information by contacting email@example.com: how we collect and use your personal information and why; the categories of personal information involved; 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 ask that we delete/erase or stop using your personal information (and object to use of your personal information) or export your personal information to another provider.
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.
We will take reasonable steps to verify your identity. If you have an account with us, we may verify you through your 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 satisfy ourselves of your identity. 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.
Certain personal information may be exempt from such requests under applicable law. We need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services.
If you wish to exercise these rights, please contact us at https://support.docusign.com/SAR or email firstname.lastname@example.org.
Transfers to the U.S. and Third Countries. We may transfer your personal information outside of your jurisdiction for further processing. DocuSign has adopted Binding Corporate Rules to facilitate the transfer of personal information from the European Economic Area and/or United Kingdom ("EEA") to DocuSign outside of the EEA. Transfers outside the DocuSign group are only made to organizations that agree to adhere to the standards in our Binding Corporate Rules or use another valid alternative under data protection law. You may view our Binding Corporate Rules at https://trust.docusign.com/en-us/trust-certifications/gdpr/bcr-p-processor-privacy-code and https://trust.docusign.com/en-us/trust-certifications/gdpr/bcr-c-csb-privacy-code.
California. California residents may ask for a list of third parties that have received your 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 click here (https://support.docusign.com/SAR or email email@example.com).
8. How We Protect Your Personal Information
To keep your personal information safe, we use physical, electronic, and managerial tools. We apply these tools based on the sensitivity of the personal information we collect, use, and store, and the current state of technology. We protect your personal information through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access, and unauthorize disclosure and alteration.
9. Changes to This Policy
10. How to Contact Us
If you are a visitor from the EEA, please contact Docusign International (EMEA) Ltd at firstname.lastname@example.org or DocuSign International (EMEA) Ltd, Attention: Privacy Team, 5 Hanover Quay, Ground Floor, Dublin 2, Republic of Ireland.