ONESPAN PRIVACY NOTICE
SCOPE AND CONSENT
OneSpan is committed to protecting your privacy. This privacy notice (“Privacy Notice“) describes OneSpan’s practices with respect to the collection, use, disclosure, retention and protection of your information in your use of the Service. It applies to the apps.esignlive.com, apps.esignlive.ca, apps.esignlive.eu and apps.esignlive.com.au websites (together, the “Site“), and to any related application, service, or tool (collectively the “Service“) regardless of how you access or use it, including through mobile devices. By using our Service and/or registering an account with us, you are accepting the terms of this Privacy Notice and you are consenting to our collection, use, disclosure, retention, and protection of your information as described in this Privacy Notice.
OneSpan may update this Privacy Notice from time to time. We will notify you of any changes by posting the updated Privacy Notice on the Site. You are advised to review this Privacy Notice periodically for any changes.
COLLECTION OF PERSONAL DATA
In order to benefit from the Service, OneSpan may require or you (and your devices, including mobile devices) may provide us with certain personally identifiable information (“Personal Data“) that can be used to:
· contact or identify you;
· register an account with us;
· provide information on a web form;
· update or add information to your account;
· complete a Transaction you are a party to;
· correspond with you regarding the Service.
Personal Data may include, but is not limited to, your name, title, company name, email address and phone number. We endeavor to limit our requests for Personal Data to information we believe is minimally necessary to achieve our stated collection purposes and, as applicable, we take reasonable steps to ensure data is reliable for its intended use, accurate, complete and current.
If you use or subscribe to a European instance, OneSpan collects, uses, and processes your Personal Data without your consent based on OneSpan’s legitimate interest or based on the Contracts concluded between you and OneSpan:
Contracts: we may process Personal Data as far as the processing is necessary for the establishment and the fulfillment of OneSpan’s obligations under any contract with you as well as for billing or reporting purposes.
Legitimate interests: we may process Personal Data if we have a genuine and legitimate reason (including commercial benefit), unless this is outweighed by harm to the individual’s rights and interests.
OneSpan strives to handle your Information in a manner consistent with the local privacy laws that apply to you and in the jurisdictions where OneSpan operates.
COLLECTION OF OTHER INFORMATION
We also collect other technical information (“Technical Information“) that is sent by your browser whenever you visit our Site and use our Service. This may include information such as:
· your computer’s Internet Protocol (“IP“) address;
· browser type and version;
· device information;
· log information;
· location information;
· the time and date of your visit;
· the pages that you visit on our Site;
· the time spent on web pages and other similar statistics.
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive. Our Service makes use of use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of the Service.
Note that the “Do Not Track” privacy preference (that users can set in their browsers to prevent tracking of their use of a website) is not supported on the Site or Service.
ACCESS AND CORRECTION TO PERSONAL DATA
Should you wish to access your Personal Data collected and held by OneSpan, you may log into your Site account and modify, delete or correct such information in your account profile, unless we have to keep that information for legitimate business or legal purposes. OneSpan acts as a data processor for the benefit of Senders (data controllers) in the course of providing the Service. Consequently, should you wish to request for access, correction, restriction of use or deletion of your Personal Data collected by Sender and provided through the Transaction process, or otherwise held by Sender, please make such request directly to the Sender.
USE AND RETENTION OF INFORMATION
OneSpan uses the Personal Data and Technical Information collected through the Service primarily for the following purposes:
· to create a contract and to carry out our obligations arising from any contracts entered into between you/ your company and OneSpan;
· To enable the completion and electronic signature of documents that are submitted for that purpose;
· To provide evidence of the Transaction;
· To send you notifications about documents requiring your signature, or about Transactions that are complete;
· To send you notifications about the Service’s availability or planned maintenance;
· To send you notifications about Service enhancements, new or upcoming features or promotions;
· To contact you in response to forms such as “Contact Us“;
· For aggregation and business intelligence purposes, including for OneSpan to develop new features or functionality that will benefit users of the Service, while maintaining the confidentiality of the Personal Data.
With the exception of information you personally provide to Senders through the Documents, OneSpan will not sell, rent, share or otherwise disclose your Personal Data to any third party without your permission, except if disclosure is required by law, if said information is already publicly available, or in the event of any corporate reorganization process including, but not limited, mergers, acquisitions, and sales of all or substantially all of our assets.
OneSpan provides you the opportunity to exercise an opt-out choice if you do not want to receive emails from us or updates regarding Service enhancements, new or upcoming features or promotions. The opt-out choice may be exercised upon receipt of an email from OneSpan or by emailing email@example.com with the subject line: “Opt-out“. We will process your unsubscribe as soon as possible, but please be aware that in some circumstances you may receive a few more messages until the unsubscribe request is processed.
INFORMATION PROVIDED TO THIRD PARTIES
The security of your Personal Data is important to us. OneSpan applies appropriate administrative, technical and physical safeguards to protect it from loss, misuse, unauthorized access, disclosure, alteration or destruction. Safeguards include the use of encryption for data at rest and in transit and the application of strict system security and processes. Access to Personal Data is strictly limited to our employees who have a need to access in the course of their assigned duties. The System is the object of continuous monitoring for any new vulnerability or possible malicious attack, and its security and related processes are tested and reviewed regularly. However, we do not warrant or represent that your Personal Data is completely safe from hackers and other security threats. If you have any questions about the security on this site, you can send an email to firstname.lastname@example.org.
STORAGE, TRANSFER, AND DISCLOSURE OF PERSONAL DATA
OneSpan in its role as data controller may store and process your Personal Data for maintaining the contractual relationship and performing its contractual obligations (such as name, e-mail, phone number, IP address, position and other related business information of you and your representatives (e.g. employees, users, business partners and agents)) in a country where OneSpan and its affiliates operates. You also acknowledge or consent to the transfer of such Personal Data across OneSpan’s subsidiaries in countries outside of your country of residence, including the United States, EU, Switzerland, Canada, or other locations which may have different data protection rules than those of your country.
OneSpan hosts the Site or Service on its servers in various locations worldwide. If you are the Sender (data controller) who elects Personal Data to be hosted in a specific region, OneSpan hosts the Site or Service on servers in a country of such region (e.g. European Union, Australia etc.). You agree that by contacting OneSpan for support or troubleshooting purposes, Personal Data provided by you or your representative in the course of the performance of such support or troubleshooting may be transferred to Canada, EU or Switzerland.
Personal Data may be transferred, processed, and stored at facilities of service providers engaged by OneSpan, as necessary for the provision of the Services. A data recipient that qualifies as a sub-processor of the Personal Data will be required to process the Personal Data in accordance with OneSpan’s instructions and the applicable data privacy laws.
OneSpan will not retain your Personal Data collected and held by OneSpan longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. Provided, and to the extent that it is not contrary to any legal or contractual requirements, OneSpan will delete or restrict the use of your Personal Data as soon as Sender (data controller) informs OneSpan that Sender does not wish OneSpan to process its personal data any longer. Please send the appropriate request to email@example.com. Upon termination of the Agreement, OneSpan will remove customer Personal Data in accordance with the contractual obligation or in accordance to OneSpan internal data removal procedures, which is not later than 60 days.
COMPLAINT TO A DATA PROTECTION SUPERVISORY AUTHORITY
If you have any questions with regards to the processing of your Personal Data, please contact us by sending an email to firstname.lastname@example.org.
If you are an individual with residency in the EU and you do not agree with how OneSpan processes your Personal Data you may submit your complaint to your competent European Data Protection Authority.
This website is not intended for children under the age of 16. OneSpan does not target services at children under the age of 16, nor does it knowingly collect any Personal Data from children under the age of 16.
In this Privacy Notice:
· “OneSpan“, “we“, “our” and “us” refers to OneSpan Canada Inc. and its affiliates.
· “You” and “your” refers to the users of the Service.
· “Transaction” means the electronic processing of one or more documents through the Service, where such document can be viewed, e-signed, sent or received.
· “Sender” means any customer of OneSpan who uses the Service to initiate Transactions.
If you have any questions or complaints about this Privacy Notice, please contact us at 1-855-MYESIGN, via email at email@example.com, or via postal mail at OneSpan Canada Inc., 8200 Decarie Blvd. Suite 300, Montreal, Quebec, Canada H4P 2P5.
Last revised: May 25, 2018