Effective date: September 24, 2023
- on https://www.syngrafii.com and https://sign.syngrafii.com websites, the subdomain websites of syngrafii.com, our websites located at https://www.syngrafii.com, https://sign.syngrafii.com, the subdomain websites of syngrafii.com, https://sign.syngrafii.ca, https://sign.syngrafii.eu, any on-premises and managed instances that have a client’s own subdomain (e.g., https://sign.client.comand) and our Syngrafii mobile application (collectively, the “Syngrafii Sites”);
- when you use our platforms, including but not limited to: iinked Sign™, Video Signing Room™, iinked Seal™, Video Notary Room™, and iinked ID Verification™ and when deployed the LongPen™ (collectively, the “Platforms”);
- when you engage with us via social media;
- when you purchase our products or services; and
- when we otherwise interact with you (by email, telephone or otherwise)
(collectively, the “Services”).
By using the Services, you agree to the collection, use, and disclosure of Personal Information in accordance with this Policy.
“Audit Trail Data” is data in the MasterFile audit record that is collected automatically, either generated by the use of the Service or from the Service infrastructure itself. Audit Trail Data includes but is not limited to: session ID, start time, end time, duration, User name, User’s email address email address, User biometric data, IP address, date and time of execution, geolocation information and before and after images of the document being signed (which is a configurable option that the Customer can turn off by going into the iinked™ platform settings). For more details about the data included in the Audit Trail Data, you can review the articles we have published here and here.
“Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information.
“Customer” is a subscriber or licensee to one or more of our Services.
“Identity Verification” is a process that compares the identity that a person claims to have with the supporting data they possess.
“Identity Document” is any document that may be used to prove a person’s identity including but not limited to utility bills, passport, or driver license.
“Personal Information” means information about an identified or identifiable individual, and includes the personal information of our Customers and Users of our Services.
“Usage Data” is data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
“User” is the individual using our Service, including but not limited to the sender or signer of documents in our Services. User includes, but is not limited to: (i) an authorized user of a Customer account; and (ii) a Guest User.
“Guest User” is an end user who is not a subscriber or licensee of the Services, but was invited by a Customer or an authorized User of the Customer to use the Services to sign a document.
2. Collection of Personal Information
When you use our Services, we may collect or receive Personal Information about you to provide our Services and operate our business. The types of Personal Information that we may collect about you are:
- Information You Provide to Us Directly
You may provide your Personal Information to us when you use our Services, including when you create an account through one our Platforms or Syngrafii Sites (a “Syngrafii Account”), use the Syngrafii Sites or Platforms, contact us with inquiries, or otherwise access our Services. This information may include:
- User Profile –We collect Personal Information associated with your Syngrafii Account. This includes information such as your first and last name, email address, phone number, address, city, county, province/state, country, signatures.
- Recording of Video-Signing – Where the parties have used the Video Signing Room™ (VSR™) on our iinked™ platform, the parties will have the option to record the video-conferencing session and as such, a video recording with your image and the screenshare of the documents being signed and the audio recording may be stored on our iinked™ platform in accordance with the applicable retention period.
- Wet-Ink Signatures – If you are using LongPen™ with our iinked™ platform, we will collect Audit Trail Data.
- Chat Sessions – If you are using the VSR™ on our iinked™ platform, the parties will have the option to use the online chat functions to communicate with other parties in the VSR™ during the session. A transcript of the chat session may be stored on our iinked™ platform in accordance with the applicable retention period.
- Notary & Commissioner Seals – If you are using the VSR™ on our iinked™ platform to notarize or commission documents, you will have the ability to upload your digital notary, commissioner, or other seals.
- Documents for Identity Verification – If you are using one of the Services wherein Identity Verification is required, you may be asked to provide images or photos of identification and verification reports generated by scanning the requested Identify Documents. Personal Information that is provided to complete Identity Verification is processed by third parties and retained in accordance with the policies of those third parties. Identity Documents are stored by the originator of the signing request but are not accessible by Syngrafii.
- Contracts – Agreements that are uploaded onto our Platforms or signed on our Platforms with your Personal Information may be retained in accordance with the applicable retention period.
- Purchase or Order Details– When you make a purchase through our Services, we collect information related to that purchase. This may include information such as date and time of purchase, and total price.
- Information Received From You as Part of Your Communications
When you use our Services, complete electronic forms, communicate with us or contact us by online chat, email or phone, we may automatically collect and store certain information about you and the activity you engaged in, for example: your name and contact information; your purchase details; information that you voluntarily provide to us; the nature of your communication; the purpose of the interaction, and the action we took in response to your inquiry or request.
- Information Collected Automatically
We may receive and store certain information about you and your device(s) automatically when you access or use our Services. This information may include:
- Audit Trail Data – We may collect Audit Trail Data for our MasterFile audit record to maintain a comprehensive and complete audit trail of the activities that occurred on our Services. The Audit Trail Data helps us mitigate process breakdowns and/or fraud.
- Usage Data – We may also collect Usage Data that your browser sends whenever you visit our Services or when you access the Services by or through a mobile device.
This Usage Data may include information such as your computer’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Services by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device 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.
- Location Data – We may use and store information about your location if you give us permission to do so (“Location Data”). We use Location Data to provide features of our Services and to improve and customize our Services. You can enable or disable location services when you use our Services at any time, through your device settings.
- Personal Information from Publicly Available Sources and Third Parties
We may collect or receive Personal Information about you from publicly available sources, social network providers, marketing partners, and/or third parties. This may include:
- Social Network Information– We may receive information about you from other services. For example, we receive certain information when you interact with our social media accounts.
- to make our Services function properly;
- to improve our Services;
- to recognize you when you return to the Syngrafii Sites/Platforms or the Services and to remember information you have already provided and your preferences;
- to collect information about your activities over time and across third party websites or other online services in order to deliver content and advertising tailored to your interests; and
- to provide a secure browsing experience during your use of our Services.
- Online Analytics and Advertising Technologies
We and our third party vendors may use automated technologies (including Cookie identifiers on the Syngrafii Sites and/or the Services), along with other collected information, to tailor ads or deliver content when you are on our Services or on other devices, apps or websites.
- Interest-Based Advertising
We (or our service providers) may use the information we collect, for example, IP addresses and unique mobile device identifiers, to locate or try to locate the same unique Users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. If you wish to opt out of cross device tracking for purposes of interest-based advertising, you may do so through your device settings. We may also use cross-device targeting to help identify our Users and serve advertising. This type of advertising is often called “interest-based” or “personalized” advertising—and when it occurs on mobile apps, “cross-app” advertising.
You can learn more about interest-based advertising and how to opt-out of receiving tailored advertising by visiting (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link.
To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.
To opt out of Twitter’s interest-based ads, you can follow their instructions posted here.
To opt out of Facebook’s interest based ads, you can follow their instructions posted here.
Please note that even if you opt-out, you may still receive advertisements from us. However, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.
- Mobile Applications
Depending on your permissions, we may receive your Personal Information from your Internet service and mobile device providers. Users of mobile device who do not want to receive interest-based advertising may opt-out in several ways. You can learn more about your choices for mobile devices by visiting http://www.aboutads.info/appchoices. Each operating system, (iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You should view your device or system “Settings” to determine how you can opt out of use of your device ID for “cross-app” personalized advertising.
4. Use of Your Personal Information
We may use the information we collect or receive about you for various purposes.
- To Provide You With Our Services
We use your information to provide you with the Services. For example, we use credit card information to complete a transaction or an address to fulfill your purchase order. If the applicable information is to be provided or Service is to be performed by a third party, then we will disclose the applicable Personal Information to the third party providing the information or performing applicable Services. Your information may be available or provided to third party service providers (such as credit card companies, and payment processing companies) and that are contractually obligated to protect your information as disclosed in this Policy.
- To Maintain, Support, Improve, and Personalize the Services
We use your information for our everyday business operations such as supporting, auditing, administering the Services, forum management, fulfillment, and analytics. Your information may also be used to improve the content and/or functionality of the Services. For example, it may be used to help us improve our offerings. We also use your information to personalize your experience. We may personalize the content and features you see when visiting our Services. In addition, we may personalize advertisements, marketing communications, and recommendations to make them more tailored to your interests.
Notwithstanding the foregoing, we will only use information that you have uploaded or stored in your Syngrafii Account, such as recordings from a VSR™ session or transcripts from a chat session, for the purposes of providing you with support services. For the avoidance of doubt, we are not able to see the information you have uploaded or stored in your Syngrafii Account unless we use support mode.
- To Communicate with You
We use your information to communicate with you. We may contact you with promotional offerings or other communications that may be of interest to you. If we send you marketing emails about Services that may interest you, each email will contain instructions permitting you to “unsubscribe” from receiving future marketing or other communications within ten (10) days.
In the event you contact us, we use certain information to respond to your questions and assist you with any issues that may arise in your use of the Services.
- For Account and Network Security Purposes
We care about keeping you secure and safe while using our Services. Keeping you safe requires us to process your Personal Information, such as your device information, activity information and other relevant information. We use such information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
- To Maintain Legal and Regulatory Compliance
Our Services are subject to certain laws and regulations which may require us to process your Personal Information. For example, we process your information to fulfill our business obligations, or as necessary to manage risk as required under applicable law.
- To Protect You, Others, and Our Business
- For Our Business Purposes
We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.
5. Sharing of Personal Information with Third Parties
Your Personal Information is not shared with third parties without your permission, except as described below.
- Service Providers
We may share your information with our third party service providers for certain business purposes. This information is provided in order for them to provide us services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, ID Verification, customer support and other services. These third party service providers have access to your Personal Information solely for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
- When Required by Law
We recognize that information related to your use of our Services (including your Syngrafii Account) could contain personal information. However, we may be required to disclose your information to third parties including law enforcement agencies when required to protect and defend our legal rights, protect the security of Users of our Services, prevent fraud, comply with the law, respond to legal process, or a request for cooperation by a government entity.
- Corporate Transactions
In the event of a sale, transfer, amalgamation, merger, reorganization, dissolution, or similar event we may transfer your information to one or more third parties as part of that transaction.
- With Your Consent
We also may share or disclose your information with your consent or at your direction.
6. Security of Personal Information
We have implemented organizational, technological, and physical security controls that are designed to safeguard Personal Information. However, no online activity is ever fully secure or error-free. While we strive to protect your information, we cannot guarantee that your Personal Information is absolutely secure. Please keep this in mind when disclosing any information to us.
Please recognize that protecting your Personal Information is also your responsibility. We urge you to take every precaution to protect your information when you are on the Internet, or when you communicate with us and with other through the Internet.
We will retain your Personal Information for as long as your account is active or as needed to provide you with the Services and to maintain a record of your transactions. We will retain and use your Personal Information 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 platform traffic 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 Services, or we are legally obligated to retain this data for longer time periods.
8. Your Rights
Syngrafii aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. Whenever possible, you can update your Personal Information directly by logging into your Syngrafii Account. If you are unable to change your Personal Information, please contact us to make the required changes.
- Your Rights
This section lists the privacy-related rights (“Rights”) that we extend to all of our Customers. These Rights do not extend to Guest Users. Guest Users must contact the Customer directly to exercise their Rights.
Your right to know and right to deletion are not absolute and are subject to certain exceptions. For example, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of our systems.
- Right to Know– You have the right to know the Personal Information we collect, use, and disclose about you.
- Right to Deletion– You have the right to request that we delete any Personal Information we have collected from you or maintain about you. We may save Personal Information when permitted by applicable law including, without limitation, when the information is needed for a legal purpose.
- Right to Rectification– If you have a Syngrafii Account, you may modify your Personal Information by contacting us at the address provided at Section 15 of this Policy.
You can also request that we provide you with a copy of your Personal Information in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
- Asserting Your Rights
You may exercise your right to know or your right to deletion by contacting us as set out in Section 15. We may ask you to verify your identity if you are contacting us through online chat, email, or phone. You may also designate an authorized agent to make a request to know or a request to delete. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.
For Personal Information that we have collected that is not accessible through the Syngrafii Account, you can request, in writing, that we correct an error or omission to your Personal Information or delete your Personal Information. We will respond to written requests within thirty (30) days, or alternatively, the timeframe prescribed by the relevant legislation.
9. Transfer of Personal Information
Syngrafii is based in Canada and, regardless of where you use our Services, the information collected as part of that use may be transferred to and maintained on servers located in Canada and elsewhere. Any information we obtain about you will be stored in accordance with Canadian privacy laws, regulations, and standards, which may not be equivalent to the laws in your country of residence. By using our Services, you consent to this collection, transfer, storage, and processing of information to and in Canada or elsewhere.
For certain Customers, when requested, we will facilitate the hosting of Personal Information in a specific geographic region. For example, we may be able to offer On-premise/Managed and Private Instance solutions to some Customers to ensure their Personal Information resides in a specific geographic region. However, even with these solutions, there may be circumstances where Personal Information must be transferred outside of the specific geographic region for processing by one of our third party service providers.
All payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover PCI-DSS requirements help ensure the secure handling of payment information.
11. Third-Party Sites
Some of the functionality may be provided by third parties and the Services may link to other third-party websites that are not controlled by Syngrafii. These third parties are not under our control and Syngrafii is not responsible for their privacy policies or practices. If you provide any Personal Information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.
12. Children’s Privacy
Our Service does not address anyone under the age of majority (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of age of majority. If you are a parent or guardian and you are aware that your Children has provided us with Personal Information, please contact us. If we become aware that we have collected Personal Information from Children without verification of parental consent, we take steps to remove that information from our servers.
Platform Users are responsible within their own jurisdictions to ensure that all signers are legally capable of signing the document being presented for signing.
13. “Do Not Track” Signals
We do not support Do Not Track (“DNT”). DNT is a preference you can set 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.
We may update our Policy from time to time. We will notify you of any changes by posting the new Policy on this page.
We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the “effective date” at the top of this Policy.
You are advised to review this Policy periodically for any changes. Changes to this Policy are effective when they are posted on this page.
15. Contact Us
If you have any questions or concerns relating to this Policy or our privacy practices, please contact us at firstname.lastname@example.org.