Privacy Policy
Updated in September 2024
This Privacy Policy (“Policy”) sets out how Clicksign collects, stores, shares and deletes Personal Data obtained by Clicksign through the Site or Platform and is treated in accordance with the guidelines of Law No. 13,709/18 (General Personal Data Protection Law) and provisions of this Policy.
ATTENTION — Please read the content of this Policy carefully before providing any Personal Data to Clicksign. If you do not agree with any of its terms, we advise you to discontinue accessing and using the Site and Platform, as they prevail over any previous proposals, contracts, and understandings regarding privacy and protection of Personal Data.
Acceptance of the terms of this Policy is necessary to enjoy the functionality of the Site and the Platform in their entirety, in accordance with your User profile.
Clicksign may update this Privacy Policy, whenever necessary, to reflect changes in its privacy and data protection practices. When substantial changes are made, they will be informed to registered Users, through the Platform.
TERMS THAT WE USE IN THIS POLICY
“Clicksign” represents Clicksign Document Management S.A., registered with the CNPJ/MF under number 12,499,520/0001-70, with headquarters at Av. Marcos Penteado de Ulhoa Rodrigues No. 939, 8th floor, Tamboré, Barueri, SP 06460-040, Brazil.
“Customer”: individual or legal entity that creates an account on the Platform and acquires a license to use the Platform.
“Personal Data (s)”: means any information that can identify a natural person or that makes them identifiable.
“Data Protection Legislation” means all legislation applicable to the processing of Personal Data, which includes, without limitation, the LGPD, Law No. 12,965/14 (Civil Framework of the Internet) and Law No. 8,078/90 (Consumer Protection Code).
“Platform”: digital environment developed by Clicksign including the software, systems, applications, processes and networks administered by Clicksign and accessible through the site www.clicksign, com which offers electronic signatures and document management solutions.
“Signer”: person who uses the Platform to sign a document.
“Owner”: is the natural person to whom the Personal Data subject to Treatment belongs.
“Data Processing”: means any and all operations with Personal Data carried out by Clicksign, such as collection, storage, evaluation, classification, processing, modification, reproduction, sharing, transmission, extraction or deletion.
“User”: individual who uses the Platform to, depending on the profile and degree of access granted, create, upload, send, receive, access, sign, archive, delete, perform Download and manage electronic documents.
PERSONAL DATA PROCESSED BY CLICKSIGN
1. Collection of Personal Information. The Personal Data processed by Clicksign may vary according to the User's profile, whether an authorized User of a Client or a Signer, and their interaction with the Platform and Site. Each tool or feature of the Site and Platform has a purpose, which requires or enables the Processing of specific Personal Data. This Data may be collected directly from the User, obtained through third parties to authenticate the Signer, or may be collected automatically while browsing the Site, through cookies or other technologies.
2. Personal Data that we collect directly from Users. Clicksign may collect Personal Data directly from the User, when creating an account, signing a document and/or interacting with our service, for example. The data collected may include registration data such as full name, social security number, e-mail, telephone, address or financial data, such as the full name of the person responsible for the payment, information about payment methods, including bank details.
3. Personal Data that we collect and process on behalf of our Clients. Clicksign may receive, from Clients, Personal Data to authenticate Signatories, such as full name, social security number, e-mail, cell phone, date of birth, biometrics, photo, Internet Protocol (IP) address.
4. Personal Data that we collect automatically. Some Personal Data is collected automatically, such as: IP address, browser for accessing the Site/Platform, date and time of access, location of the User, the User's actions on the Site, information regarding the User's mobile device used to access the Site, connection provider, among others.
5. Personal Data of Children and Adolescents. As provided in our Terms of Use, to use the Platform, the User must be 18 (eighteen) years of age or older and/or be legally capable. Clicksign does not intentionally collect or request Personal Data from children under 18 (eighteen) years of age or who are not legally capable. It is the User's sole responsibility to verify the Data included in the Platform, guaranteeing the necessary parental permissions and authorizations for its Treatment.
6. Cookies. Information may be collected that is stored directly on the device that the Site visitor is using, called cookies. The collection of information such as browser type, time spent on the Site, pages visited, language preferences, and other anonymous traffic data are used by Clicksign to allow the customization of browsing preferences, providing a better experience for the User and visitor to the Site. If you wish to control which of your information is collected through cookies, you can choose your preferences on the cookie banner of the Site itself or reject them. However, this may cause inconvenience in the use of the Site or even make browsing impossible.
TREATMENT PURPOSES
7. Treatment Hypotheses. Clicksign processes Personal Data to enable the provision of services contracted by its Clients, including to personalize and improve the experience when using the Platform's features. In addition, Clicksign may also process Personal Data to comply with its legal or regulatory obligations, such as a data storage obligation; to exercise rights in judicial, administrative and arbitral proceedings, such as payment records; upon the provision of specific consent by the Owner; or, finally, for its own interests, which are lawful, adequate and proportional, such as certain marketing activities.
8. Purposes. Clicksign processes Personal Data for the following purposes: a. To provide and improve the Platform, such as creating your account on the Platform; receiving payment; providing support activities; promoting improvements to the Platform, offering new features and improving the Users' experience; sending messages about your activities and account; allowing documents to be saved and archived in your account; archiving subscription history and account activities, such as who initiated, viewed and signed the signed document, the IPs of users and Signatories, date and time of signature, among others; improve the acceptance of electronic signature and formalization of documents and content in the country, with the consent of the Customer. b. Comply with regulations, and/or laws applicable to Clicksign services; c. Exercise or defend rights in administrative or judicial actions; d. Improve the security and efficiency of the Site and Platform; e. Perform financial management; f. Perform marketing activities, such as supporting and promoting Clicksign's activities, including for personalization and display advertisements on paid media, such as Google Ads and Facebook Ads; send commercial, promotional communications and periodic updates related to the services, respecting the Owner's right to choose to stop receiving marketing communications at any time; carry out statistical analyses, studies and market research; send communications and newsletters about the functionalities and resources of the Platform, as well as educational information.
DATA SHARING
9. Blogs and social networks. Any Personal Data that the Owner chooses to share on Clicksign blogs, forums, or social networks may be processed by anyone who has access, without any control or interference from Clicksign. Clicksign will have no responsibility for this information.
10. Data Sharing with Third Parties. To achieve the purposes described in this Policy, Clicksign may share Personal Data with certain third parties, operators or sub-operators of Personal Data. Clicksign does not sell or disclose the Personal Data it collects for monetary purposes. All third parties that receive Personal Data from Clicksign are subject to contractual obligations to protect this Data, such as implementing technical and organizational security measures to ensure an adequate level of security. Some of the third parties that have access to Personal Data may be located in other countries or may process data outside Brazil. Sharing can be done with: a. Consultants and technology and IT companies authorized to manage the Platform or Site, hosting providers and service providers, including cloud data storage companies; b. Companies providing Clicksign support services, including billing, risk and credit analysis companies, auditors, communication, marketing, and events; c. Financial companies, payment methods and banks, to operationalize payment or collection operations; d. Regulators, authorities and other third parties, if necessary, to comply with legal obligations or to exercise Clicksign's or third party rights; e. Clicksign partners, in the case of services integrated with Clicksign services or holding joint events; f. Companies in the same corporate group of which Clicksign is or will be a part; g. Clicksign suppliers, for database administration, IT system support and support Clicksign's organizational activities.
INTERNATIONAL DATA TRANSFER
11. International data transfer. Clicksign uses AWS servers in the United States and Brazil with the best security standards available in the market and undertakes to observe the mechanisms and controls provided for in the Privacy and Data Protection Legislation for the international transfer of Personal Data.
DATA RETENTION AND DELETION
12. Data Deletion. When you request the deletion of a data, a document uploaded to the Platform or even your account, the data is stored for a certain period for security, if it has been unduly deleted, and then it is permanently deleted.
13. Data Storage and Retention Time. Clicksign will keep the Personal Data stored on the Platform as long as necessary to (i) license the software to Users, such as maintaining accounts; (ii) meet the requirements or authorizations of current legislation, such as a legal obligation, investigation, or judicial or administrative action; (iii) protect Clicksign's interests, such as mitigating damages, investigating violations of the Terms of Use, promoting the security of the Platform and preventing fraud. We may store Personal Data as described in this clause, even after requests to delete information or cancel the Account, according to our documentation.
SAFETY
14. Pseudonymization of the Data. The personal data of Document Signers may be pseudonymized in the Clicksign production environment and to provide support.
15. Anonymization of Data. At the end of the treatment, Clicksign may anonymize the Data, if it decides to store it.
16. Safety. Clicksign adopts market standards to protect Personal Data from misuse or destruction, loss, alteration, disclosure, acquisition, or accidental, illegal or unauthorized access, including the establishment of varying levels of access permissions to its systems and appropriate password controls. For more information about the Security measures implemented on the Clicksign Platform, see our Cyber Security Policy. The security of your Data also depends on the adoption of reasonable measures by you when using your devices and software, including keeping your access password in a secure place, not sharing it with third parties.
RIGHTS OF THE OWNERS
17. Rights of the Holders. The Personal Data Subject has the following rights guaranteed by Data Protection Legislation: a. Right to Confirmation: right to confirm that Clicksign processes your Personal Data; b. Right to Access: right to access the Personal Data that Clicksign maintains; c. Right to Rectification: right to request the correction of Personal Data when they are incomplete, inaccurate or out of date; d. Right to Anonymization, Blocking or Elimination: right to request the anonymization, blocking or elimination of unnecessary, excessive data or treated in non-compliance with the provisions of the law; e. Right to Personal Data Portability: right to request the portability of your Personal Data to another Platform, in accordance with current legislation, as long as this does not affect our industrial and commercial secrets; f. Right to Delete Personal Data: right to delete Personal Data processed with your consent, to the extent permitted by law; g. Right to Information: right to receive information from Clicksign about the public or private entities to which your Personal Data has been shared and direct to know the consequences when you do not consent to the processing of your Personal Data; h. Right to Revoke Consent: right to ask Clicksign to revoke your consent.
TALK TO US
18. Data Subject Requests. If you have a request related to your rights regarding the Processing of your Personal Data, please contact us through our Service Channel for Personal Data Subjects. When Clicksign processes your Personal Data on behalf of a Customer or third party, they are responsible for defining how your Data should be Treated and for fulfilling your requests as a Data Controller. In this sense, requests involving Personal Data received from third parties or from our Clients will be forwarded to the respective third party/client for an appropriate response.
19. Personal Data Protection Officer. Clicksign has a formally appointed Personal Data Officer (DPO). If necessary, contact Livia Pazianotto Torres via e-mail dpo@clicksign.com.
