Privacy policy

This privacy policy (the “Policy”) sets out how Docster S.à r.l. (“us,” “our,”, “we” or “Docster”) collect and use information from individuals who access or use https://docster.lu and its sub-domains and/or any of our other sites, products, or services that link to this Policy (the “Software”). By using our Software, you understand that we will collect and use your information as described in this Policy (collectively “you”).

If you or your organization has a contract with us, that contract may have privacy terms that also apply to the information you provide to us under that contract. Please review the terms in that contract as they may be different or more restrictive than the terms in this Policy.

Docster’s core product and services help users template, draft, collaborate, and analyze contracts. As part of our Software, users want us to collect and record information that helps the parties prove the validity of the documents that are e-signed on the Software. This information includes the persons who are involved in the creation and negotiation of the contracts and the devices those persons use.

1. Collection of data

To provide and improve our Software and to support marketing, we collect information about visitors to our sites, users of our Software, the devices they use, and sometimes their locations.
We collect certain information directly from you, such as when you fill out forms with a name or email address. We collect other information, usually about devices, browsers, or locations, automatically (without you typing it into a form).
You have choices about whether you visit our sites or provide information to us. However, if you do not provide us with certain information, you may not be able to use some parts of our Software. For the choices you may have, please see paragraph 5 of this Policy.

1.1 Collected information

We receive information from you and about yourself when you:

Register or log in to your account
Create or edit your user profile
Contact customer support

Examples of the information you provide are: name, email address, mailing address, phone number, or billing information.

You also provide us with information about others when you use parts of our Software, such as when you:

Add others as a member to an existing account or document
Leave comments

Your main choice for this type of information is simply not providing it, such as by not creating a profile on the Software. For other choices you may have, please see paragraph 5 of this Policy.

1.2 Information automatically collected about you

We automatically collect information from you and your devices when you use our Software, even when you visit our sites or apps without logging in. For the choices you may have on what information we automatically collect, please see paragraph 5 of this Policy.

The information we automatically collect includes:

Device, Usage Information, and Transactional Data, such as:
- IP address
- Precise geolocation information that you allow our apps to access (usually from your mobile device)
- Unique device identifiers and device attributes, like operating system and browser type

Usage data, such as:
- web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Software, the frequency of your use of our Software, error logs, and other similar information

Transactional data, such as:
- names and email addresses of parties to the document
- history of actions that individuals take on a document (e.g. draft, create template, generate document etc)
- information about those individuals or their devices, such as name, email address, IP address, and authentication methods

Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information that are downloaded on your device, or local shared objects and tracking pixels to store or collect information. Cookies can store your preferences, your username, and help tailor advertisements.

We use services like Google Analytics. They use Cookies to gather usage data and help us learn how people use the Docster website, such as the pages they visit and for how long and the website or page they were on before coming to an Docster website.

Adverts for our Software. We may also use services, like Google to serve tailored adverts about our Software to you on third party sites. We allow these third parties to use and access their own cookies on your computer or other device(s) you use to access our Software. We do not have access to these cookies or related technologies, and this Policy does not govern the use of those cookies and related technologies.

For the choices you have on cookies and related technologies, please see paragraph 5 of this Policy.

1.3 Information collected about you from third parties

We may collect information about you from others, such as:

Our customers may give us your information by drafting a contract for example.
We may combine the information we receive from other sources with information we collect from you (or your device) and use it as described in this Policy

1.4 Information collected and processed on behalf of our customers

When our customers use our Software, we process and store certain information on their behalf as a data processor. For example, when a customer creates a contract or other document, we act primarily as a data processor and process information on the customer’s behalf and in accordance with their instructions. In those instances, the customer as the data controller is responsible for most aspects of the processing of the information. If you have any questions or concerns about how information is processed in these cases, including how to exercise your rights as a data subject, we recommend contacting the relevant customer.

2. Use of information

In general, we collect, use and store or process your information to provide our Software, to fix and improve the Software, to develop new services, and to market our products and services. Here are some examples of how we use the information we process:

Provide you with the services and products you request
Market features, products, or special events using email or phone or send you marketing communications about third party products and services we think may be of interest to you
Record details about what happens with electronic documents, such as who viewed or signed, the devices used and when these events occur
Choose and deliver content and tailored advertising
Create and review data about our users and how they use our Software
Test changes in our Software and develop new features and products
Fix problems you may have with our Software, including answering support questions and resolving disputes
Prevent, investigate and respond to: fraud, unauthorised access to or use of our Software, breaches of terms and policies, or other wrongful behaviour
Meet legal retention periods

We normally collect or use information from you or others only where we have your consent to do so, where we need the information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. For example, when we:

Use information to create and manage an account, we need it in order to provide relevant services.
Gather and record data associated with use of a digital signature, it is to comply with law and regulations.
Gather usage data and analyse it to improve our Software, we do so based on our legitimate interest in safeguarding and improving our Software.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us using the contact details provided in the final paragraph of this Policy.

3. Information sharing

We do not rent, sell, or share your information with third parties except as described in this Policy.

We share information as follows:

Service Providers. We share your information with other companies we use to support our Software. These companies provide services like search technology, advertising and authentication systems. Our service providers are bound by confidentiality undertakings with us to protect your data.
Safety, security, and compliance with law. We may share your information to follow applicable law, or to respond to legal process. We also may share your information when there are violations of this Policy or other agreements, or to protect the legal rights of third parties, including our employees, users, or the public.
We may share your information in other ways if you have asked us to do so or have given consent.

Your information may also be shared as described below:

Other users. When you allow others to access, use, or edit content in your account, we share that content with them. For example, if you create a document which is not protected by a password or restrained to a group, we make the contents of the document available to the other users of your company.
Your employer. When you create an account or user role with an email address assigned to you as an employee, contractor or agent of an organisation, that organisation can find your account and take certain actions that may affect your account.

4. Retention of information

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where there are technical limitations that prevent deletion or anonymisation, we safeguard personal data and limit active use of it.

5. Your actions

This paragraph describes many of the actions you can take to change or limit the collection or use of your information.

You are not required to fill out a full profile but you do need to create a password. You can access and review your profile information from the “Account” page. If any information is inaccurate or incomplete, you can make changes from this page, too.
Cookies and Other Related Technology. You can choose to decline cookies through your browser settings. However, if you decline cookies, you may not be able to use some parts of our Software.
To change how Google Analytics collects and uses your information, you may install the Google Analytics Opt-Out Browser by clicking here.
Device and Usage Information. If you do not want us to see your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.
Closing Your Account. If you wish to close your account, please go to your account settings. You may also email us at the email address listed in Section 11 to close your account.
We are committed to resolving valid complaints about your privacy and our collection or use of your personal data. For questions or complaints regarding our data use practices or Policy, please contact us using the email address listed in Section 11 of this Policy.
If you are in Switzerland or the European Economic Area (“EEA”), please also refer to paragraph 6 of this Policy.

6. Rights of those resident / established in the EEA

The terms “Personal Data,” “Process/Processing,” “Controller,” “Processor,” “Sub-processor,” and “Data Subject” will have the meanings ascribed to them in the Luxembourg law dated 1st August 2018 as amended from time to time and the General Data Protection Regulation (2016/679), as amended or replaced from time to time, and any applicable laws or regulation implementing it.

By using our Software, you:

acknowledge that your information will be processed as described in this Policy; and
consent to having your information transferred to certain Sub-processors in the EEA. These sub-processors provide our email, website and saas hosting platforms as well as editors.

Other Rights

You can access and review information associated with your account at any time.

You also can request the following information:

how we collect and use your information and why;
the categories of personal data involved;
the categories of recipients of your personal data;
how we received your personal data; and
how long we use or store your personal data or the manner in which we determine relevant retention periods.

You also have a right to correct your personal data. In certain situations, you can ask that we erase or stop using your information (and object to use of your personal data) or export your data.

Where we rely on your consent to process your personal data, you have the right to decline consent and/or if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your information for direct marketing purposes.

You have a right to provide us with guidance on the use, storage, and deletion of your personal data after your death.

You have a right to raise questions or complaints with your local data protection authority at any time.

If you wish to exercise these rights, please contact us at info@docster.lu.

7. How your information is protected

To keep your information safe, we use physical, electronic, and managerial tools. We apply these tools based on the sensitivity of the information we collect, use, and store, and the current state of technology. Although we take steps to prevent unauthorised access to or use of personal information, the Internet and our Software are not 100% secure. For this reason, we are not able to guarantee that information we collect or store will always be protected from unauthorised access, or that it will only be used as described in this Policy.

8. Changes to this policy

We may amend this Policy to reflect changes in the law, our Software, our data collection use and practices, or advances in technology. Our use of the information we collect is subject to the Policy in effect at the time such information is used. Depending on the type of change, we may notify you of the change by posting on this page or by email. Please carefully review any changes made to this Policy.

9. How to contact us

For questions or complaints regarding our use of your information or this Policy, please contact us.