Privacy Policy

March 2020

This Privacy Policy sets forth the policies and procedures of CounterSign (“CounterSign”, “we”, “our” or “us) in regard to the collection, usage and disclosure of personal and/or business information that you may provide to us through using this website,
or by using any product, app or service provided by CounterSign (collectively, “Services”). If you do not accept this Privacy Policy and/or do not meet and/or comply with the provisions set forth herein, then you may not use any of the Services.

  1. Information we collect

    When you use our Services, you may provide CounterSign with two main types of information: (1) Non-Personal Information and (2) Personal Information. We collect information from you when you (a) use and/or access our Services, (b) open and/or respond
    to our emails, (c) contact CounterSign, (c) visit any page online that displays our content, (d) purchase products and/or services through our Services, and/or (e) provide information to any of our Service Providers (as defined below).

    1. Personal Information

      “Personal Information” is personally identifiable information that you knowingly choose to disclose, which is collected on an individual basis. We may ask for certain Personal Information from you for the purpose of providing to you content and/or services
      that you request. We collect Personal Information such as your: (i) contact information (including name, address and email); (ii) financial information (such as credit card number, expiration date, verification number and billing address);
      (iii) contact information of your company and/or other identity information you share with us (including industry or profession); (iv) location information (such as geographic location of the device you are using) and/or (v) preferences
      and feedback. By registering for any Service, you are authorizing us to collect, store and use your email address, and other such information you provide during registration, in accordance with this Privacy Policy. Once you register, you
      have opted in to receive electronic communications from CounterSign. If you use an external application accounts (like ‘Google’) to sign into the Services, we will collect and store your user identification information (“ID”). The privacy
      practices of external applications and websites are set forth in their privacy policies, and CounterSign has no control over the use of your ID by such parties. CounterSign may also provide you with the opportunity to participate in surveys
      through our Services. If you participate, we will request certain personally identifiable information. Participation in surveys is completely voluntary and you therefore have a choice whether to disclose such information.

    2. Non-Personal Information

      “Non-Personal Information” is general user information that does not contain personally identifiable information, which is collected on an aggregate basis as you use our Services. We collect Non-Personal Information such as: Cookies: We use cookies and
      web log files to track usage and trends, to improve the quality of our Service and to customize your experience. A “cookie” is a data file that resides on your computer, mobile phone, or other device, and allows CounterSign to recognize
      you as a user when you return to our Services using the same computer and web browser. Information gathered through cookies may include the date and time of visits, the pages viewed, and time spent at our Services. You can remove or block
      cookies using the settings in your browser, but in some cases that may impact your ability to use our Services. Sending a cookie to a user’s browser enables us to collect Non-Personal information about that user and keep a record of the
      user’s preferences when utilizing our services, both on an individual and aggregate basis. For example, the Company may use cookies to store the following information: session data, email address, username, and preferences. CounterSign
      may use both persistent and session cookies; persistent cookies remain on your computer after you close your session and until you delete them, while session cookies expire when you close your browser. Analytics Data: We use third party
      analytics services to help analyze how users use the Services. These analytics services use cookies to collect information such as how often users visit our website and we use the information to improve the Services. The analytics services
      ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information. If third party services collect
      information, they do so anonymously without identifying individual visitors. However, we may link the information we record using tracking technology to Personal Information we collect. Device Data: We use device data, which is information
      concerning a device you use to access, use, and/or interact with the Services, such as operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and
      time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information. Aggregate: We may collect non-identifying and
      statistical information about the use of our Services, such as how many visitors visit a specific page, how long they stay on that page and which links, if any, they click on. This information represents a generic overview of our users,
      including their collective habits. Information collected in the aggregate is not associated with you as an individual. We may share user information in the aggregate with third parties. Other Tracking Technologies: We may supplement information
      you provide to us with information from other sources, such as information to validate and/or update your address and/or other demographic information. This information is used to maintain the accuracy of information on our Services and
      for internal analysis. We may also use clear gifs, pixel tags and web beacons, which are tiny graphic images placed on website pages and/or in our emails that allow us to determine whether you have performed specific actions and are further
      used to track online movements of our users. In contrast to cookies, which are stored on your computer’s hard drive, clear gifs are embedded invisibly on web pages. We do not tie the information gathered by clear gifs to your Personal
      Information.

    3. Information you provide by using the Services

      You may submit User Content (as defined in our Terms and Conditions) to the Services, including certain information via online forms.

    4. Information you send to other Users

      This Privacy Policy only addresses the use and disclosure of information we collect from you. If you disclose your information to other parties using the Services, or visit other websites linked through the Services, different rules may apply to their
      use or disclosure of the information you disclose to them. Since CounterSign does not control the privacy policies of third parties, or other individual’s actions, you are subject to the privacy policies of that third party or those individuals.
      We encourage you to be sure the recipients are authenticated to your satisfaction before you send them any documents or sensitive information.

  2. How we use and share information

    1. General Use

      We may share your Personal Information to fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, with your consent, and/or to third parties designated by you. Except as otherwise stated in this Privacy Policy, we do not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. For example, we may use your information to:

      • maintain, and improve our sites, products, and services;
      • respond to comments and questions and provide customer service;
      • provide technical support;
      • send information including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages;
      • communicate about promotions, upcoming events, other news about products and services offered by us and our selected partners;
      • send you reminders, support and marketing messages;
      • manage our administration of the Services;
      • link or combine user information with other Personal Information we get from third parties, to help understand your needs and provide you with better service;
      • perform analytics and conduct research;
      • protect, investigate, and deter against fraudulent, unauthorized and/or illegal activity;
      • to process orders and/or otherwise provide and deliver products and services you request;
      • to process and deliver orders for additional services;
      • identify you as a user in our system;
      • facilitate the creation of and secure your Account on our network; and/or
      • develop and improve marketing and advertising for the Services and partner services.

      The information collected in the aggregate enables CounterSign to better understand your use of the Services and to enhance your enjoyment. We may use financial information to process payment for any purchases made on the Services, enroll you in one of our accounts and/or other related services in which you elect to participate. If you use the Services, you agree to receive certain communications from us including but not limited to the following:

      • Special Offers, Newsletters and Updates. We will occasionally send you information on products, special deals, promotions and newsletters. You can sign up for these emails from us at any time on our website. You may elect not to receive these types of communications by notifying us.
      • Customer Service. Based upon the personally identifiable information you provide us, we will communicate with you in response to your inquiries, to provide the services you request and to manage your account. We will communicate with you by email or telephone, as you may elect.
      • Supplementation of Information. In order to process your credit card orders, we use a third party provider to validate and verify your account information. All billing and account information is transmitted via https, which is a secure encrypted protocol system.
    2. Parties with whom we may share your information

      We may share Personal Information and User Content with vendors, employees, contractors and/or agents who are performing services for CounterSign, (such as the servers for our email communications who are provided access to user’s email address for purposes of sending emails from us; authentication systems, and fraud detection) (collectively, “Service Providers”). Our Service Providers will be given access to your information as is reasonably necessary to provide the Services and related products and/or services. We strive to use commercially acceptable means to protect your Personal Information. If Service Providers acquire confidential or proprietary information belonging to CounterSign or its customers, such information is required to be handled in confidence and may not be disclosed to unauthorized third parties. Service Providers who violate our security and safe maintenance of data policies are subject to appropriate discipline including, but not limited to, termination. Certain Service Providers will automatically collect non-identifying information about your use of our Services by using cookies and other technologies as similarly used by CounterSign.

    3. Disclosures

      We also may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. For example, we will disclose your Personal Information in the following circumstances: (i) to investigate and defend CounterSign members, employees, officers, agents, contractors, principals and affiliates against any third party claims and/or allegations and/or otherwise to protect CounterSign from liability, (ii) to investigate, prevent and/or take action regarding suspected and/or actual illegal activities, (iii) to assist government enforcement agencies, respond to a legal process and/or comply with the law, (iv) to exercise or protect the rights, property and/or personal safety of the users of the Services and/or (v) to protect the security and/or integrity of the Service. In response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can (and you authorize us to) disclose your Personal Information, including your name, city, state, telephone number, email address, user ID history, fraud complaints, and usage history, without a subpoena, in connection with an investigation of fraud, intellectual property infringement, piracy, and/or other unlawful activity.

    4. Business Transitions

      In the event we undergo a business transaction such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred and/or examined during the due diligence process. You acknowledge and consent that such transfers may occur and are permitted by this Privacy Policy, and that any acquirer of our assets may continue to process your Personal Information as set forth in this Privacy Policy.

  3. Information Choices

    Depending on the situation, CounterSign may obtain consent to the collection of Personal Information in different ways. Express consent may be obtained verbally, online and/or in writing. Implied consent may be obtained through your use of our Services and related services, and/or when you approach us to obtain information, inquire about or request services from us. CounterSign will offer individuals the opportunity to choose (opt out) whether their Personal Information is to be used for any purpose other than what it was collected for. We respect your privacy and give you an opportunity to opt out of receiving announcements of certain information. Although we think that you benefit from a more personalized experience when we know more about you and what you like, you can limit the information you provide to CounterSign, and you can limit the communications that CounterSign sends to you. If you visit our website and volunteer personally identifiable information, you can opt out of receiving notifications, and you may review, modify, update, and/or delete such Personal Information by contacting us and/or by changing your preferences on the Services. Please be aware that even after your request for a change is processed, CounterSign may, for a time, retain residual information about you in its backup and/or archival copies of its database. Please be aware that we may still email you non-commercial emails related to your account and your transactions through our Services. CounterSign may retain information (including without limitation your account information) for a commercially reasonable time for backup, archival, and/or audit purposes. In some cases, if you choose not to provide CounterSign with requested information, you may not be able to use and/or access our Services.

  4. California Privacy Rights

    Effective January 1, 2020, the California law known as the California Consumer Privacy Act (“CCPA”) allows, with some exceptions, California residents to request that a business that collects consumers’ personal information to give consumers access to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with the CCPA, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information.

    Notice to Business-to-Business Consumers: Many of the obligations imposed by the CCPA currently do not apply to personal information reflecting communications or transactions between the business and a California resident where the resident is acting on behalf of another business, e.g., a business-to-business transaction. If your personal information is being processed within this context, your rights under the CCPA are limited.

    Your Rights Under California Law

    The following are your rights under California law:

    • To request that the business disclose what personal information (about you) it collects, uses, discloses, and sells.
    • To request deletion of your personal information collected or maintained by the business. This right is limited, and we may not always honor your request, particularly when it is necessary to maintain your information for legal purposes or to complete the business we have with you.
    • To opt-out of the sale of your personal information by the business. A “sale” occurs when your personal information is exchanged with a, non-service provider, third party in exchange for valuable consideration. It is not a sale when you intentionally authorize us to disclose your personal information or interact with a third party. To exercise your right to opt-out, please contact us at admin@countersign.com.
    • To not receive discriminatory treatment by the business for exercising any of the privacy rights conferred under the CCPA.

    Exercising Your Rights Under the CCPA

    How to make a disclosure request: You may request these disclosures by contacting us at admin@countersign.com. You have the right to make a free request two times in any 12-month period. We will make the disclosure within 45 days of receiving your request, unless we request an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period.

    Right of deletion: You have the right to request that we delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information, unless an exception applies. Contact us at admin@countersign.com to delete your data.

    The CCPA permits using a designate an authorized agent to make a request on a consumer’s behalf. You may designate an agent by filling an agent-designation form. Both the designated agent and the consumer are subject to verification before accepting a consumer rights request.

    All consumer rights requests are subject to verification by us. We verify requests by matching the information provided by the consumer to the personal information of the consumer already maintained by the business. In some instances, we may use your contact information to contact you in order to verify your identity.

    Residents of the state of California have the right to request certain information from us with respect to the types of personal information we share with third parties for their direct marketing purposes, as well as the identities of the third parties we have shared such information with during the immediately preceding calendar year. To exercise your choices, please contact us at admin@countersign.com.

  5. Service Eligibility and Changes

    1. Children and Minors

      CounterSign does not knowingly collect personally identifiable information from children under the age of thirteen (13). If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us Personal Information, please contact us at admin@CounterSign.com.

      By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase the goods and/or services through the Services.

    2. Changes to Privacy Policy

      In general, changes will be made to this Privacy Policy to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Policy at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Services after any modification to this Privacy Policy will constitute your acceptance of such modifications and/or updates. You can determine when this Privacy Policy was last revised by referring to the date it was last “Updated” above.

  6. Other Servicess and services

    We are not responsible for the practices employed by any Servicess and/or services linked to and/or from our Services, including the information and/or content contained therein. Please remember that when you use a link to go from our Services to another website and/or service, our Privacy Policy does not apply to such third-party websites and/or services. Your browsing and interaction on any third-party website and/or service, including those that have a link on our Services, are subject to such third party’s own rules and policies. In addition, you agree that we are not responsible and do not have control over any third-parties that you authorize to access your Personal Information. If you are using a third-party website and/or service and you allow them to access your Personal Information, you do so at your own risk.

  7. How we protect information

    1. Security

      We implement security measures designed to protect your information from unauthorized access. Your account is protected by your account password and we urge you to take steps to keep your Personal Information safe by not disclosing your password and by logging out of your account after each use. We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. We may further protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. Because the internet is not a completely secure environment, CounterSign cannot warrant the security of any information you transmit to CounterSign or guarantee that information on the Services may not be accessed, disclosed, altered and/or destroyed by breach of any of our physical, technical and/or managerial safeguards. In addition, while we take reasonable measure to ensure that Service Providers keep your information confidential and secure, such Service Provider’s practices are ultimately beyond our control. We are not responsible for the functionality, privacy and/or security measures of any other organization. By using our Services, you acknowledge that you understand and agree to assume these risks.

  8. International Data

    Personal Information may be transferred abroad (including outside the EU, UK or Switzerland for any users in those jurisdictions) in connection with CounterSign’s provision of hosted application services and related support services to our users. CounterSign strives to collect and use Personal Information in a manner consistent with the laws of the countries in which we do business.

    1. Data Integrity Purpose Limitation

      CounterSign will use Personal Information and User Content only for purpose of delivering the services made available in the Services, which is in the confines of document generation and electronic execution, and to facilitate the services you request related thereto. CounterSign will take reasonable steps to ensure that Personal Information is reliable for its intended use, accurate, complete and current. We may occasionally contact you to determine that your data is still accurate and current.

    2. Access

      We acknowledge the right of EU, UK and Swiss individuals to access their personal data. Upon request, we will grant you reasonable access to Personal Information that we hold about you. CounterSign may deny requests where legitimate rights of persons other than you would be violated or where disclosure would interfere with national security, defense, or public security. For security purposes, CounterSign may require verification of identity before providing access to Personal Information. Further, CounterSign will allow the individual to correct, update, or delete information. Individuals who wish to make an access request or remove Personal Information from our records, or if you have any questions in regard to this Privacy Policy or believe that CounterSign has not complied with the provisions of this Privacy Policy, should send an email to us at admin@CounterSign.com.

    3. Onward Transfers

      CounterSign will offer users in the EU, UK or Switzerland whose Personal Information has been transferred to the United States the opportunity to opt out from: (a) the disclosure of personally identifiable information to a non-agent third party (other than Service Providers); and (b) the use or disclosure of Personal Information for a purpose other than the purposes for which the information originally was collected or subsequently authorized by the individual or a compatible purpose. If CounterSign were to receive “sensitive Personal Information” (which includes, without limitation, Personal Information specifying medical and/or health conditions, racial and/or ethnic origin), CounterSign will request and obtain affirmative consent before disclosing such information to a non-agent third party and before using such information for a purpose other than the purpose originally disclosed and/or a similar purpose. CounterSign will provide you with reasonable mechanisms to exercise your choices should such circumstances arise. We will only transfer data to our agents, resellers or third party Service Providers who need the information in order to provide services to or perform activities on behalf of CounterSign, including without limitation in connection with the delivery of services or products, CounterSign management, administration and/or legal responsibilities.

    4. Data transfers

      Please be aware that our Services are subject to United States laws, including laws governing privacy and security of your information. By using our Services, you agree and consent (and represent that you have the authority to provide such consent) to the information collection, use and/or sharing practices described in this Privacy Policy and understand that the laws of the United States and other countries and territories related to the foregoing may differ from those of other countries and may not be as protective as the laws in the country where you reside. Regardless of the laws in place in such countries, we will treat the privacy of your information in accordance with this Privacy Policy.

    5. Recourse, Enforcement and Liability

      CounterSign uses a self-assessment approach to assure compliance with this Privacy Policy and periodically verifies that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible. We encourage you to raise any concerns to admin@countersign.com and we will investigate and attempt to resolve any disputes regarding use and disclosure of Personal Information.

  9. Language

    The governing language of this Privacy Policy is English, which shall prevail over any other languages used in any translated document.

  10. How to contact us

    If you have questions and/or comments about this Privacy Policy, please email us at admin@CounterSign.com.

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