eOriginal Privacy Policy
In this Privacy Policy, “Personal Information” means information that identifies you or characteristics or attributes about you, or that would enable a person or business to contact you, but at a minimum, includes information that is defined as personal information in the state or country in which you reside. Personal Information does not include anonymized information or information that cannot reasonably be used to identify or describe you.
The privacy of your Personal Information is very important to us. This Privacy Policy describes the Personal Information and other information we collect via our website and services and how we use and disclose that Personal Information and other information we collect. By making use of our website or services and/or providing information to us, you agree and consent to our use and disclosure of your Personal Information and other information in accordance with this Privacy Policy. This Privacy Policy is incorporated into the eOriginal Website Terms and Conditions. Use of eOriginal software and services are governed by applicable agreements between the parties.
INFORMATION WE COLLECT AND TRACK – DIRECTLY. The following information is collected when a person visits our web page or visits or uses our web applications:
AUTOMATICALLY COLLECTED INFORMATION:
Meta Data
When you use our website or services, we collect certain information that is automatically generated by the fact that your browser is communicating with our server, such as: your internet protocol address, browser type and version, device type and version (i.e. mobile device, mobile operating system), browser capability (i.e. whether it is touch capable, screen size, whether it can perform certain actions), from which site you were referred, and to which site or page you then visit, and other similar information generated by the communication between your computer and our server (collectively “Meta Data”).
Cookies
We use “cookies” on some pages of our site to track what pages you have visited, and to measure your activity on our sites and services. A cookie is a small file stored on your device that contains a small amount of data, which often includes an anonymous unique identifier. A cookie can be used to store information such as a unique identifier related to your browser session so that we can detect whether you are logged in, whether you have returned to our site or service, and it can make your experience on the site or service more customized. A cookie can contain any information, although we do not use it to store any sensitive information such as your password. You can configure your browser to accept all cookies, reject all cookies or notify you when a cookie is set. If you set your browser to turn off cookies, your access to some areas of our site might be limited or not function correctly.
Third party tools and automated data collection
Our website and services use tools and functionality provided by third parties described below, which collect certain information about your use of our site and services:
Social Media
We provide links to our Facebook, Twitter, LinkedIn and YouTube pages (“Social Media Sites”), which are pages hosted on those respective services which we do not control. When you click on those links, we retain information that you have clicked on those links, and then when you arrive on those pages at the applicable Social Media Site, those services may track your activity that was referred from us. We are able to track your use of our pages on those Social Media Sites. These Social Media Sites may allow you to post comments or submit content for others to see, or to communicate with us. Sometimes you might be able to limit who can see what you share, but some of the Social Media Sites either limit your ability to restrict access, or allow access to the general public or other members, of that Social Media Site. To remove content you have shared on these Social Media Sites, please consult with the Social Media Site documentation. WE DO NOT CONTROL THE DATA COLLECTION, USE AND DISCLOSURE POLICIES OF SOCIAL MEDIA SITES. If you choose to use Social Media Sites, please review their privacy policies. If you do not agree with their policies, please do not use those Social Media Sites.
Customer relationship management tools
We currently use the following third-party customer engagement, relationship and management tools:
adroll.com – provides targeted advertising and marketing services which permits us to more effectively determine your needs and get you faster more accurate responses.
googletagmanager.com, google.com and doubleclick.net – allows us to easily tag pages and resources to track what pages you have visited both on our site, and on our social media pages listed above.
marketo.net – a service that allows us to track user preferences through communications with us, such as by email, messaging services and mobile engagement
salesloft.com – a service that lets us manage our email and communication lists with customers.
Youtube – a service that displays videos.
The above tools (collectively, the “Customer Engagement Tools”) include scripts and other technology that allows us to track your use of our services, sites and content. Each of the Customer Engagement Tools collects certain automated data about you based on your visit to our sites and services and to pages we manage on the Social Media Sites.
Site protection and performance
We currently use the Cloudflare service for site protection and performance (“Site Management Tool(s)”). The Cloudflare service may collect automated information about your use of our sites, services and content, and that data may be used to cache (keep a temporary copy) of data you regularly access, as well as permit us to resolve site performance and availability issues. We may use other Site Management Tools in the future.
Collectively, all Meta Data, Cookies and information we may automatically obtain from use of Customer Engagement Tools and Site Management Tools are referred to as “Automatically Collected Information.” Automatically Collected Information is not Personal Information, unless it (a) is associated with Personal Information or (b) otherwise meets the definition of Personal Information above.
Do Not Track options
Our services and sites do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of any of the Automatically Collected Information. For information about do not track, visit www.allaboutdnt.org. You have options to minimize or in some cases opt out of providing Automatically Collected Information by using plugins (such as using the Google Analytics Opt-out Browser Add-on, see https://tools.google.com/dlpage/gaoptout/), settings or third party software or services, and in some cases, by making elections on third party sites (see, e.g. http://optout.networkadvertising.org). Some of our services or sites may not function correctly if you engage one or more of these tools or options.
MANUALLY COLLECTED INFORMATION.
Contact information
We may ask you to provide personal information such as your name, address, e-mail, fax, phone numbers, and company’s name. Some instances may include requesting contact information to send you a newsletter or asking you to give us information about you so we can furnish you with additional information about us or our products and services. In some cases related to our Smart Sign Web service, this information is mandatory so that we can verify your identity, which is required for legal compliance.
Communications
If you send us e-mails, letters, messages via any Social Media Sites or using any messaging service, or otherwise communicate with us, or if other users or third parties send us information about your activities or postings, we may collect and store such information.
eOriginal SmartSign®
If you use our eOriginal SmartSign® service, we may collect information as displayed in the form to verify your identity, which may include your social security number, address, SMS address/mobile number, and other personal information you will see on the form you fill out. Depending on the options selected by our customer who requested that you use the eOriginal SmartSign® service, we may store this information, we may transmit it to a third party for certain identity verification services described below, or simply transfer it to our customer. Some information (such as your SMS/mobile number and social security number) may be transmitted to third parties for identity verification purposes if our customer has requested such services. eOriginal currently uses Twilio (www.twilio.com) and Electronic Verification Systems (EVS) (https://www.electronicverificationsystems.com) for some authentication purposes. If our customer makes use of these services, we will have obtained your SMS/mobile number and/or social security number and address from our customer (or we may get it from you on the form) and we will transmit it to the applicable service provider for authentication verification purposes. eOriginal stores this information on behalf of its customers in conjunction with the record that is being signed. In such case we save the information you provide in a document (which may include your identity verification data), which is added to the transaction in the data vault where the instrument that was signed is stored. These documents we store for our customers are encrypted.
INFORMATION WE COLLECT AND TRACK – THROUGH OUR SERVICES. The following information is collected by us when a person uses one of our clients such as a financial institution, which uses our service to vault, store or process documents with us:
MANUALLY COLLECTED INFORMATION:
Document Meta Data
When our client, such as a financial institution, stores or processes documents using our service, we collect certain information a client manually associates with the document, such as the title of the document, the names of the parties to the document, their email or other contact information, and other information the client determines to store inside the fields that constitute document meta data.
AUTOMATICALLY COLLECTED INFORMATION
Our system creates an automated audit log of every transaction that occurs on our system, in case there is a question as to a particular transaction. This audit log includes unique document identifiers, data regarding the person who initiated the document event (i.e. store, update, delete etc), document title/name, and other document meta data which typically includes a person’s first and/or last name, email address, browser agent and SMS phone number if multifactor authentication was enabled. The log may also contain the loan or other document number.
How we use and disclose Personal Information and Automatically Collected Information:
AUTOMATICALLY COLLECTED INFORMATION: We use Automatically Collected Information solely for our internal analytical and data auditing purposes. Except in connection with our audit log described above, we do not associate Automatically Collected Information with your Personal Information in any data we store.
MANUALLY COLLECTED INFORMATION: We use Manually Collected Information to (a) interact with you and provide our services to you; and (b) to notify you about ancillary events and services we or our third party partners may provide, such as user group meetings ad events, information generally related to our industry, and information regarding products and services of third parties that we have a business relationship with, that are complementary to our services (e.g. Docusign).
GENERAL DISCLOSURE:
Except in connection with our eOriginal SmartSign® (where no information we collect from you is shared except with certain service providers as discussed above and/or the customer who requested you to use such service), Automatically Collected Information and Manually Collected Information (which may include Personal Information) is shared with the Social Media Sites and the providers of the Customer Engagement Tools and Site Management Tools, but solely to enable us to provide a better experience for our customers, such as:
- to provide you with any products, services, support, or information you have requested;
- to assist us with our internal research and marketing efforts;
- to assist us in creating and providing content and information that is relevant to you;
- to better understand how you use our sites and services so we can improve them and engage and retain you as a user;
- to help you quickly find information about our services or products that is important to you; and
- to assist us in creating better products and services to meet your needs.
In addition to the above, we may share your Manually Collected Information with businesses with whom we have a complementary business relationship, to notify you of those services, and to provide you with newsletters and informative emails regarding us and our products and services (and the products and services of those partners).
We may also disclose any information we have (including any Automatically Collected Information, Manually Collected Information and/or Personal Information) to the government or third parties under circumstances that require us to do so to comply with applicable law, such as under a court order, warrant, statute, or under a subpoena or other legal compulsion. Therefore, we cooperate with law enforcement inquiries, as well as other third parties to enforce laws, such as intellectual property rights, fraud and other rights. We may disclose any information about you to law enforcement or other governmental officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, intellectual property infringements or other activity that is illegal or may expose us or you to legal liability.
We do not sell or rent any Personal Information about you to any third party without your express consent.
ELECTRONIC COMMUNICATIONS. eOriginal currently uses Amazon Simple Email Service (AWS SES) to send electronic mail. When we email you, some of your Personal Information (such as your email address) is used by AWS SES to deliver those messages to you. AWS SES also may obtain other information such as return receipts, delivery receipts, IP address and other information contained in the message, and AWS SES uses some information it obtains about the electronic message to provide us information about statistics and performance, such as open and click rates, time to deliver and other similar data. eOriginal considers the email and its content as confidential and we do not disclose or use it outside of the provision of and monitoring and enhancement of our services or to provide services to our customers. eOriginal will not send you an email that includes sensitive information (such as your social security number, bank account number or other non-public data).
CHOICE / OPT-OUT. We give you the opportunity to “opt out” of having your information used for purposes not directly related to our site or services at the point where we ask for the information. If you do not wish to continue receiving our newsletters or bulletins, you can opt out of receiving these communications by sending an e-mail to [email protected] with the subject line of “UNSUBSCRIBE” – or click on any unsubscribe links in emails sent to you.
Personal Information Security Measures
We will protect the security, integrity and confidentiality of your Personal Information by maintaining appropriate safeguards and security measures, but at a minimum, we will comply with our legal obligations with respect to such Personal Information. Our safeguards and security measures have been designed to protect your personal information against unauthorized or unlawful access and use, and against accidental loss, destruction or damage. Please be advised, however, that although we have endeavored to create a secure and reliable site and service, the confidentiality of any communication or material transmitted to or from us via email or the site or service cannot be guaranteed. Accordingly, we are not responsible for the security of information transmitted via the internet.
Compliance with applicable state and foreign data protection requirements.
Information we gather under this Privacy Policy is stored on eOriginal controlled servers or resources located in the United States. To update or request deletion of any personal information you have provided to us via our website, please contact us at [email protected]. Please be aware that most of the data we store is stored at the direction of, and for use by, our customer, and we may not be able to delete that information unless you make that request to our customer; however, in any event, we will comply with any legal obligations we have regarding deletion of data.
If you are a resident of a country that is subject to Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the Processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC – commonly referred to as the General Data Protection Regulation or GDPR, the disclosures made here are incorporated into this Privacy Policy solely in respect of your Personal Data as that term is defined under the GDPR.
If you are a resident of a State in the United States, you may have specific privacy rights under local State law. For example, see California Civil Code Section § 1798.83 which permits users of our sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.
If you have additional rights under applicable local or other country laws, we will comply with our obligations under such laws.
Children’s Privacy
Our website is not intended for use by children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If we learn that we have personally identifiable information about a child under the age of 13, we will delete that information.
Testimonials
We may display personal testimonials of satisfied customers on our website in addition to other endorsements. If you provide us with an email or other communication regarding our services, you automatically hereby consent to our use of all or a part of such email or other communication for marketing our goods and services, provided that we use only your first name. We will not use your image or likeness without specific authorization from you. If you notify us in writing to cease such use, we will do so within a reasonable time of receipt of such request.
Notice of Changes to Privacy Policy
In the event there is a major change to our privacy practices, a prominent notice will be posted on our website. We recommend that you review this Privacy Policy periodically as we may update it from time to time.
Links
Our sites may contain links to other sites and services. We are not responsible for the privacy practices of these other sites or services, and any information collected by those sites or services is subject to the privacy policies posted by the owners or operators thereof. We encourage you to read the privacy policy of each and every website you visit. This privacy policy applies solely to information collected by our sites and services.
Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us [email protected].
©2006 – 2020 eOriginal, Inc. All rights not expressly granted herein are reserved.
Effective Date: March 12, 2020
