Accordium Privacy Policy Last updated: May 24th, 2018

Introduction

At Accordium, we (the “Company”) are committed to protecting your privacy. We have prepared this Privacy Policy to describe our practices regarding the Personal Data (as defined below) we collect from users of our website (the “Site”), our web application, and associated services (collectively the “Service”) provided through www.accordium.com

To the extent that Accordium’s processing of your Personal Data is subject to the General Data Protection Regulation, Accordium relies on its legitimate interests, described below, to process your data.

Where given permission via opting in, Accordium may also process Other Information that constitutes your Personal Data for direct marketing purposes. You have a right to object to Accordium’s use of your Personal Data for this purpose at any time.

1. Use Consent

Where you have expressly consented to the submission of Personal Data through our Service, you agree to the terms of this Privacy Policy and the collection, use and disclosure of your Personal Data thereof. We always link back to this policy, and describe the purpose of the data processing, with the option to consent or object, at the point of collection. 

2. A Note About Children

We do not intentionally gather Personal Data from visitors who are under the age of 18. If a child under 18 submits Personal Data to Company and we learn that the Personal Data is the information of a child under 18, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 18, please contact us at legal@accordium.com

3. Types of Data We Collect

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

1. Information You Provide to Us
  • We may collect Personal Data from you, such as your first and last name, company, job position, e-mail, and password when you create an account to log in to our service (“Account”)
  • This information is used both to identify your account to our service, and also to generate identifying information for electronic signatures, approvals and audit events. Such information may be embedded in documents you participate in, as part of an audit trail.
  • We may collect Personal Data from a third party, such as your first and last name, and email address, where that third party invites you to participate in an auditable event on our Service, such as signing or approving a document electronically.
  • Certain Services, such as 2-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
  • We retain information on your behalf, such as files and messages that you store using your Account.
  • If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
  • We may also collect Personal Data at other points in our Application that state that Personal Data is being collected.
2. Information Collected via Technology
  • Information Collected by Our Servers: To make our Services more useful to you, and to secure legal documents signed or approved through our Service, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit. This information may be embedded in documents you participate in, as part of an audit trail.
  • Log Files: As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Site or the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
  • Cookies: Like many online services, we use cookies to collect information. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
  • Pixel Tags: In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
  • Google Analytics: We use Google Analytics to help analyze how users use the Site. Google Analytics uses Cookies to collect information such as how often users visit the Site, what pages they visit, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics only to improve our Site and Services. Google Analytics collects only the IP address assigned to you on the date you visit the Site, rather than your name or other personally identifying information. We do not combine the information generated through the use of Google Analytics with your Personal Data. Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Site, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

4. Use of Your Personal Data

Accordium uses Personal Data in furtherance of our legitimate interests in operating our Site and Services. More specifically:

1. General use

In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:

  • facilitate the creation of and secure your Account on our network;
  • identify you as a user in our system;
  • provide improved administration of our Site and Services;
  • provide the Services you request;
  • identify you to other users of the system who requested your personally identifying information to be embedded in a legal contract or document, and its audit events;
  • improve the quality of experience when you interact with our Site and Services;
  • send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
  • send you administrative e-mail notifications, such as security or support and maintenance advisories;
  • make telephone calls to you, from time to time, to solicit your feedback; and
  • send newsletters, surveys, offers, and other promotional materials related to our Services and for other marketing purposes of Company.
2. User Testimonials and Feedback

We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name, and may also supply additional data such as their home city, professional experience, and education. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.

3. Creation of Anonymous Data

We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

4. Retention policy

We retain your information for as long as is necessary to provide our Services. Where your details have been embedded in a contract to which you have been a participant, or you maintain an account with us, the retention period is indefinite. This is because one basis of our Service is to provide archival of legal documents on behalf of third parties. As per section 7.3, you may requested deletion of your Personal Data from such documents by contacting those third parties directly.

5. Disclosure of Your Personal Data

We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.

1. Third Parties Designated by You

When you use the Services, the Personal Data you provide will be shared with the third parties that you designate to receive such information. Depending on the type of access you grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information.

2. Users

We will share your Personal data with other Users solely for the purpose of providing the Services.

3. Third Party Service Providers

We may share your Personal Data with third party service providers to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to the Company. These third party service providers are required not to use your Personal Data other than to provide the services requested by Company.

4. Affiliates

We may share some or all of your Personal Data with our subsidiaries, joint ventures, or other companies under a common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

5. Other Disclosures

Regardless of any choices you make regarding your Personal Data (as described below), Company may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (c) to protect or defend the rights or property of Company or users of the Site or Services; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.

6. Third Party Websites

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site and go to another site, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

7. Your Choices Regarding Information

You have several choices regarding the use of information on our Service:

1. Email Communications

We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Alternatively, you may opt-out by changing your email preferences in your Account settings at app.accordium.com/user-profile

Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy.

2. Cookies

If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.

3. Changing or Deleting Your Personal Data

You may change any of your Personal Data in your Account by editing your profile within your Account by visiting or by sending an e-mail to us at legal@accordium.com

You may also request deletion of your Personal Data by us, and we will use commercially reasonable efforts to honor your request. Please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud-prevention or similar purposes.

Note also that your Personal Data may be used with, or embedded into, documents that have received your signature or approval as requested by third parties; who are the data controller for this information. You may requested deletion of your Personal Data from those documents by contacting those third parties directly.

3. Portability

You may request that your Personal Data be delivered to a third party for processing by sending an email to us at legal@accordium.com

8. Security of Your Personal Data

Accordium is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account information. Please do not disclose your Account password to unauthorized people. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while the Company uses reasonable efforts to protect your Personal Data, we cannot guarantee its absolute security.

In the unlikely event of a data breach, we shall report the particulars to our local Data Protection Authority within 24 hours.

9. A Note to Users Outside of the United States

If you are a non U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings provided in your account, or by contacting us at legal@accordium.com

10. Data Protection Authority

Datatilsynet has been appointed as Accordium’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. Datatilsynet can be contacted in addition to legal@accordium.com, only on matters related to the processing of personal data.

To make such an inquiry, please contact Datatilsynet at

Datatilsynet
Borgergade 28, 5
1300 Copenhagen K
Tel. +45 33 1932 00
Fax +45 33 19 32 18
E-mail: dt@datatilsynet.dk
Website: http://www.datatilsynet.dk/

11. Questions; Contacting Company; Reporting Violations

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, or to communicate with our Data Protection Officer, please contact us at the following address or phone number:

Address
Accordium ApS
Købmagergade 53, 2 sal.
1150 København

Telephone
+44 20 7193 7740

E-mail address
legal@accordium.com

12. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and we will change the “Last Updated” date. You should consult this Privacy Policy regularly for any changes.

Accordium ApS

Købmagergade 53,1150 København K, Danmark

CVR: 38378295

Email: sales@accordium.com

Designed in Copenhagen, engineered in Kuala Lumpur

© Accordium 2017. All Rights Reserved.