1. Interpretation and Definitions
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
- “Account” means a unique account created for You to access our Service or parts of our Service.
- “Company” (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to RCDevs Identity SA. For the purpose of the GDPR, the Company is the Data Controller.
- “Country” refers to Luxembourg.
- “Cookies” are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- “Data Controller”, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
- “Device” means any device that can access the Service such as a computer, a cell phone or a digital tablet.
- “Personal Data” is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
- “Service” refers to the Website.
- “Service Provider” means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
- “Usage Data” refers to 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).
- “Website” refers to yumisign.com, accessible from https://www.yumisign.com/.
- “You” means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.
2. Collecting and Using Your Personal Data
Types of Data Collected
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Phone number
- Address, State, Province, ZIP/Postal code, City
- Usage Data
Usage Data is collected automatically when using the Service.
Usage Data may include information such as Your Device’s Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service 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 Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device’s 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.
We may also collect information that Your browser sends whenever You visit our Service or access the Service by or through a mobile device.
Tracking Technologies and Cookies
- Cookies or Browser Cookies
- Web Beacons.
Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.
We use both Sessions, and Persistent Cookies for the purposes set out below:
- Necessary / Essential Cookies
Type: Session Cookies
Administered by: Us
Purpose: These cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
- Cookies Policy / Notice Acceptance Cookies
Type: Persistent Cookies
Administered by: Us
- Functionality Cookies
Type: Persistent Cookies
Administered by: Us
Purpose: These cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time. You use the Website.
- Tracking and Performance Cookies
Type: Persistent Cookies
Administered by: Third-Parties
Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these cookies to test new pages, features, or new functionality of the Website to see how our users react to them.
3. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
- To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user;
- For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service;
- To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation;
- To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information;
- To manage Your requests: To attend and manage Your requests to Us;
- For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred;
- For statistical analysis and to get feedback from you about our products, websites, mobile apps, and other services and activities. For example, occasionally we may invite you to review a product or service you’ve bought or used from us. If we do, it’s possible that we’ll use independent research and feedback providers to act on our behalf;
- To power our security measures and services so you can safely access our website and mobile apps;
- Make available our products and services to you;
- Process your orders;
- Take payment from you or give you a refund;
- Help answer your questions and solve any issues you have;
- For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We may share Your personal information in the following situations:
- With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, for payment processing, to contact You.
- For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
- Legal rights: If we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk);
- With Your consent: We may disclose Your personal information for any other purpose with Your consent.
4. Retention of Your Personal Data
The Company will also retain 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 Service, or We are legally obligated to retain this data for longer time periods.
5. Transfer of Your Personal Data
On July 16, 2020, the Court of Justice confirmed the validity of the EU Standard Contractual Clauses for the transfer of personal data to processors outside the EU/EEA (“SCCs”), while invalidating the EU–U.S. Privacy Shield. Thus, the Court has ruled that international data flows under the European Union’s comprehensive data protection regime, the General Data Protection Regulation (GDPR), can continue to be based on EU Standard Contractual Clauses, while also further clarifying the conditions under which they can be used. Until the decision, Privacy Shield had served as an approved “adequacy” mechanism to protect cross-border transfers of personal data from the EU to the US under the EU General Data Protection Regulation (“GDPR”). Therefore, the standard contractual clauses (“SCCs”) can still be used as a mechanism for transferring data outside the EU.
Because we care deeply about privacy and information security, RCDevs Security SA does not transfer personal data to the US and hosts personal data exclusively within the EU. With all our sub-processors, we have specified the location where data will be processed to be within the EU. According to our agreements, once we have made this choice, they will not transfer data from the selected region except as; necessary to provide the services initiated by us, or necessary to comply with the law or binding order of a governmental body.
However, through the YumiSign workflow, you and your counterparts may in each separate case access the processed document remotely (via internet) from anywhere. We have no way of knowing where the recipient of the email and/or SMS notifications, push notifications (invitations, reminders, confirmations) sent through YumiSign will be located geographically. Some recipients may therefore be located in a region outside of the EU/EEA. Therefore, such transfer of personal data to third countries is necessary for the performance or conclusion of a contract (signing a document electronically) in the interest of a data subject or that a data subject is a party to.
6. Disclosure of Your Personal Data
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
- Comply with a legal obligation
- Protect and defend the rights or property of the Company
- Prevent or investigate possible wrongdoing in connection with the Service
- Protect the personal safety of Users of the Service or the public
- Protect against legal liability
7. Security of Your Personal Data
Data security is of great importance to RCDevs. We continuously educates staff on security. 2FA login, VPN, individual accounts, and activity logging are implemented as appropriate for employees with access to Our infrastructure and for employees with customer support tasks in the system. Access to systems is given to employees on a need-to-have basis and is governed by an approval process. Testing and production environments are separated, and data is never transferred between them.
To protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your collected data.
We take security measures to protect your information, including:
- Limiting access to our buildings to those that we have determined are entitled to be there (by use of passes, key card access, and other related technologies);
- Implementing access controls to our information technology
- We use appropriate procedures and technical security measures (including strict encryption, anonymization and archiving techniques) to safeguard your information across all our computer systems, networks, websites, mobile apps, offices and stores.
- Never asking you for your passwords;
- Advising you never to enter your account number or password into an email or after following a link from an email.
- For the actual servers, RCDevs has firewalls, anti-virus and encrypted communication, update servers regularly.
- All documents are individually encrypted with dedicated keys.
- The security of the system as a whole is regularly tested by means of penetration tests performed by a third party.
- The data centers used by RCDevs have appropriate levels of security and are certified with ISO-27001, amongst other standards.
8. Detailed Information on the Processing of Your Personal Data
The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process, and transfer information about Your activity on Our Service under their Privacy Policies.
We may use third-party Service providers to monitor and analyze the use of our Service.
We may use Your Personal Data to contact You with newsletters, marketing or promotional materials, and other information that may interest you. You may opt out of receiving any, or all, of these communications from Us by following the unsubscribe link or instructions provided in any email We send or by contacting Us.
We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing (e.g., payment processors).
Legal Basis for Processing Personal Data under GDPR
We may process Personal Data under the following conditions:
- Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
- Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
- Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
- Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
- Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
- Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.
In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Your Rights under the GDPR
The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.
- Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
- Request correction of the Personal Data that We hold about You. ou have the right to have any incomplete or inaccurate information We hold about You corrected.
- Object to processing of Your Personal Data.This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
- Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
- Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
- Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.
Exercising of Your GDPR Data Protection Rights
You may exercise Your rights of access, rectification, cancellation and opposition by contacting Us. Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.
You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.
10. Children's Privacy
Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. However, if You are a parent or guardian and Know that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.
11. Links to Other Websites
We have no control over and assume no responsibility for any third-party sites or services’ content, privacy policies, or practices.
13. Contact Us
- By visiting this page on our website: https://www.yumisign.com/contact-us/
- By sending us an email: email@example.com