SignWell Privacy Notice for California Residents

This Privacy Notice for California Residents ("Notice") supplements the terms contained in SignWell's www.signwell.com/privacy/ and applies solely to the personal information that we process from all visitors, users, and others who reside in the State of California ("consumers" or "you"). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice. This Notice describes your rights under the CCPA, and explains how to exercise those rights with respect to any personal information that we process about you.

Notwithstanding any language to the contrary, this Notice is not intended to limit or to expand the scope of any rights that we have, or that you may have with respect to your personal information, under the CCPA. In the event of any conflict between this Notice and our Privacy Policy with respect to the processing of any personal information that you provide to us, this Notice shall control to the extent necessary to comply with applicable laws.

Information We Collect

This Notice applies to the personal information that we collect and process in connection with providing the Service. Under the CCPA, "personal information" refers to information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from Service Documents you complete or products and services you purchase.
• Indirectly from you. For example, we automatically collect information as you use our Service which may include IP addresses, and information collected through cookies, web beacons, and other tracking technologies that observe your actions on our Service.
• From our other Users, who may include information about you when creating or uploading Service Documents for electronic signature.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Service, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To personalize your Service experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Service, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Service, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Service, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• 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 information held by us about our Service users and customers is among the assets transferred.

To the extent that you submit any sensitive personal information for our collection, our use of such sensitive information will be limited to that use which is necessary to provide our services to you and/or for the uses to which you have consented. We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

We share your personal information with the following categories of third parties:

• Our other Users who use our Service to create Service Documents to be filled out by you and other Users.
• Service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, SignWell has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties in connection with the purposes described in this Notice:

• Our direct customers who use our Services to create documents and forums filled out by other users.
• Service providers.

Note that, in any case where we are providing services to you, we require that our service providers and contractors refrain from combining the personal information that such service provider or contractor receives from us with any personal information about you that the service provider or contractor obtains in any other manner, as required by the CCPA.

Retention of Personal Information

We review our data collection practices to ensure that our collection, use, retention, and sharing of personal information is reasonably necessary, proportionate, and consistent with what an average consumer would expect at the time of collection. We determine the retention periods applicable to any consumer personal information collected through the Service according to the purpose(s) for which the information was collected. Once the purposes for which the personal information was collected are no longer applicable, we will anonymize and/or destroy the relevant personal information.

Sales of Personal Information

California law requires that we provide transparency about personal information we "sell" or "share." "Sale" for purposes of the CCPA, broadly means scenarios in which we have disclosed personal information to third parties in exchange for valuable consideration, while "sharing" means we have disclosed information to a third party for cross-context behavioral advertising. In addition, the CCPA has been interpreted to deem this "sharing" to also be a form of "sale." We do not sell your personal information to other companies for money; however, we use your personal information for cross-context behavioral advertising to allow our advertising partners to collect certain information to show you targeted advertisements, which may be considered "sharing" under the CCPA. We do not knowingly sell or share personal information about consumers under the age of 16.

In the preceding twelve (12) months, SignWell has not sold personal information; however, SignWell has "shared" the following categories of personal information with the following categories of third parties:

Category of Personal Information	Category of Recipients
A. Identifiers	Advertising partners and service providers.
D. Commercial information, such as products or services purchased, obtained, or considered	Advertising partners and service providers.
F. Internet or other electronic network activity information	Advertising partners and service providers.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• The categories of personal information that we sold or shared about you.
• The categories of personal information that we disclosed about you for a business purpose.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties service providers, contractors, and/or third parties to whom your personal information was disclosed for a business purpose.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Correction and Deletion Request Rights

You have the right to request that we correct or delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will correct or delete (and direct our service providers to correct or delete, as requested) your personal information from our records, unless an exception applies.

We may deny your request if retaining the information in its prior form is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Help to ensure the security and integrity of the Service, to the extent the use of the personal information is reasonably necessary and proportionate for those purposes.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the personal information.
7. Comply with a legal obligation.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Emailing us at [email protected].
• Visiting https://www.signwell.com.
• Logging in to your password-protected account and submitting a request through the contact icon in your account.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
  • Your email address;
  • Full name;
  • Relevant account information; and/or
  • Any other information that may reasonably be used to verify your request.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We also reserve the right to refuse to fulfill any consumer rights requests for data that is not required to be provided under applicable laws.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

We may need to request specific information from you to help us confirm your identity and complete your request. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information related to your request to enable us to process your request more efficiently.

Only you, or a person registered with the Secretary of State of your applicable state that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child, if you believe that the Service has collected any information about your child.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. You are entitled to request that we provide information from beyond the twelve-month period, but we shall not be required to provide such information if providing such information proves impossible, would involve disproportionate effort, or is otherwise permitted by the CCPA. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out, and Opt-In Rights

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us through one of the two methods provided below:

1. By visiting the following Internet Web page link: Do Not Sell or Share My Personal Information.
2. By submitting your request via e-mail to [email protected].

You may also exercise your right to opt-out by sending us an opt-out preference signal that meets the following requirements: (1) the signal is in a format commonly used and recognized by businesses; and (2) the platform, technology, or mechanism that sends the opt-out preference signal makes clear at the time of opting out that the use of the signal is meant to have the effect of opting you out of the sale and sharing of your personal information on the Service. Acceptable opt-out preference signals may include browser settings implemented by Global Privacy Control.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• Otherwise retaliating against you, if you are our employee or independent contractor, or if you have applied to work for us.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Service that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Service and update the notice's effective date. Your continued use of our Service following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this notice, the ways in which SignWell collects and uses your information described here (and in the Privacy Policy), your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: (503) 908-4143
Website: https://help.signwell.com/
Email: [email protected]

Postal Address:
Docsketch, LLC (DBA SignWell)
12042 SE Sunnyside RD
Suite #546
Portland, OR 97015