Updated June 2023
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).
1.1 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
1.2 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:
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.
1.3 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.
1.4 Information you send to other Users
2. How we use and share information
2.1 General Use
- 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 or using the unsubscribe link provided in the email.
- 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.
2.2 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. Users and third parties may share forms, templates, and other documents that you can download and use through the Countersign Services (such sharing parties, “Providers”). The Providers of these documents may receive a notification identifying you by name as a user that has downloaded or used their document. These Providers may also receive your email address and contact you directly about their products or services. You acknowledge and agree that Countersign shall have no responsibility or liability relating to the usage of your email address and name by these Providers or the contents of their communications with you.
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.
2.4 Business Transitions
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 firstname.lastname@example.org.
- 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 email@example.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 firstname.lastname@example.org 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 email@example.com.
5. Service Eligibility and Changes
5.1 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.
6. Other Services and services
7. How we protect information
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.
8.1 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.
8.3 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.
8.4 Data transfers
8.5 Recourse, Enforcement and Liability
10. How to contact us