With Effect from May 25, 2018.

1. Privacy Policy

At MSB (also known as MSBDocs), a product service of Taigle LLC, your privacy is our top priority. So we have developed a policy describing MSB practices of collecting, using, protecting, disclosing, transferring and storing user personal information or data. MSB here is mentioned as “we”, “us”, or “our”, and refers to the reader as “you”, “your” or “user”.

If you access or use our website “www.msbdocs.com”, and/or application- including MSB web and mobile application (with iOS and Android version 4.4 onwards), or services that link to this Privacy Policy (“Services”), you are agreeing that we may collect and/or use your information as described here, and that your information may be transferred to and stored in the United States and other countries.

Any service agreement signed by you, or signed on behalf of your organization with us, shall have the privacy clause mentioned which applies to the information your share with us as part of consent and agreement.

We are committed to responsible management of user information and abide by all ethical and legal rules regarding the collection, use and retention of personal data. We strictly adhere to industry guidelines and continually monitor and enhance how we manage the use and security of collected data.

In the following, we tell you which information we might collect and how we use it.

2. Our Privacy Policy defines:

  • What Information We Collect
  • How we use the Information Obtained
  • Disclosure of User information and/ or Sharing of Information
  • Your Use of Other User’s Information
  • Data Retention, Maintaining User’s Information, and Deactivation of Accounts
  • Enforcement
  • How We Secure User Information
  • Other Sites Services and Linkage
  • Use of Cookies and other Technologies
  • Opt-Out Policy
  • Minors’ Privacy
  • Privacy Rights by State Laws (California)
  • Non-United State Users
  • Amendment to Privacy Policy
  • Contact Us

2.1. What Information We Collect

When you choose to access the various parts of MSB Services, applications and the network website(s) accessible through our Services, it requires us to know certain information about you and other users that you interact with. The amount and types of information that we gather depends on the nature of the interaction with our services. Categories of information collected from you are described below.

I. Information Submitted by the User

Information that you may submit to us includes, but is not limited to: name, email addresses, user name, registration related details like mailing address, phone number, transaction-related information.

We may ask you to provide this information when you:

  • Request for information or a demo related to MSB services through our website.
  • Register or create user account with MSB web app.
  • Download our mobile app and register the application. Please note that registration with us is not mandatory however in this case you will be able to use only a few features offered by the application (like EasySign) and not others.
  • Start or sign a document sent to you by Document Custodians through MSB application.
  • Create and send signing requests (ePaks) – When users create signing request through our MSB applications and arrange for them to be sent to recipients, they provide information like name and email address of the recipients. When users want additional assurances about the identity of the individual signing their documents, they may require us to collect some additional information that we use to authenticate recipients before they are able to sign a document.
  • Capture & upload document from your mobile camera roll or document library.
  • Create or edit your user profile information within our web or mobile app.
  • Request certain features of MSB
  • Contact customer support and request training materials, a product demo, or more information on our products.
  • Provide a user testimonial

We use this information primarily to provide you with a safe, smooth, efficient, and customized signing experience. We use the acquired information in ways that are compatible with the purpose for which we originally requested it.

 

The decision to provide us with information is optional; however, if you elect not to provide certain information, you may not be able to access certain content or features available through MSB Services.

II. Information Collected and Stored Automatically

We automatically collect, track and store specific information about your use of MSB services, comprising when you use our website and application(s) without logging in.

We use this information for internal research on our users’ demographics, interests, and behavior to improve our product, its performance, our services, and advertising.

Device and Usage information – We may collect information about the computers/mobile devices you use to access our website and/or applications and how you use them. Examples of the information that we may automatically collect and analyze include, but are not limited to:

  • Unique Device Identifiers, including, but not limited to, IP Address, i.e. internet protocol address that can reveal a web user’s general location (city/state/country), MAC Address, IMEI etc.
  • Device attributes, including browser types, browser language, and operating system;
  • Usage data, including information related to the ways in which you interact with the services such as web log data, the date and time you used the services, the frequency of your use of the services, error logs, and other similar information; and
  • Transactional data related to the documents you upload or sign using MSB application services such as: signing request (ePak) metadata, ePak subject, authentication method used, and ePak history.

We never receive any of the following information unless you expressly choose to share it with us:

  • Your specific location: We will never gather or use your specific device location without first getting your explicit permission.
  • Your documents: We will only access documents that you specifically choose, and we will never scan or import your document library or camera roll. This allows you to choose individual pictures to change your profile picture or to capture and upload documents for electronic and digital signatures.
  • Your contacts: We will never scan or import your contacts unless you ask us to. If you choose to do so, we will only use your contact information to help you add them to the signing workflow.

III. Information collected from Other Miscellaneous Sources

We may collect information about you from other miscellaneous sources such as our marketers, partners, researchers, and others. For example, if you apply registration for MSB services (website, web and mobile application) on another website or third party tool or use a website that enables your activity on MSB Services, that website may provide information about you and your activities to our system.

2.2. How we use the Information Obtained

As a whole, we use the information we obtain to facilitate and manage the services you request. Precisely, we use your information to:

  • Deliver the services (including marketing-related newsletters) and support or carry out the transactions you have requested;
  • Customize, analyze and improve our products (including its effectiveness, usability and popularity), services (including the content and advertisements on our website), and technologies;
  • Send communications to you, such as records regarding our relationship, your transaction status (Signature requests, signature reminders etc.), and any customer surveys;
  • Test, develop and notify you about recent updates, new features and services from MSB;
  • Generate and review aggregate statistics about our customers, sales, traffic patterns and related site information;
  • Verify your identity, detect and protect the security or integrity of our website(s), our business (es), or our applications or services; against error, fraud and other illegal activities; enforce our User Agreement; and as otherwise described to you at the time of collection, use or disclosure.
  • Troubleshoot user problems and resolve disputes.

The Information collected may be stored and processed in the United States or any other country in which MSB maintains facilities. We may combine information that we collect or receive through our application and Services with information we obtain from other sources and use it as described in this Privacy Policy.

Note: For the EU data protection regulation laws, MSB acts as data controller or processor, legal lawful basis to gather and use personal information shall be relying upon the type and classification of information and the usage of it.

Information we collect after the consent is received from you, is required for contract purpose, or where the processing is in our appropriate interests and not superseded by your data protection interests or basic rights and choice. In some scenarios where we have any regulatory, statutory or legal requirement to gather or maintain personal information to safeguard your rights and choices viz:

  • To provide relevant services, we may use your information to create and manage user/ customer account.
  • To comply with legal and regulatory laws, we need to gather and record data associated with use of electronic and digital certificate or signature.
  • For sales and marketing purposes, we may use your information (e.g., your name, email address etc.) with a prior consent taken from you.
  • To improve and protect our services, we may need to collect and analyze the data use.

If you have any queries or information related to lawful basis to your personal information which we collect and use, you can contact us with contact details mentioned in section 2.15 of this Privacy Policy.

2.3. Disclosure of User information and/ or Sharing of Information

MSB does not sell, trade, or rent your information to others (unaffiliated third parties) except as described below for the mentioned purposes:

  • Other Users Designated by You: If you invite others to access, use, or edit content you create through MSB application, by view/ review, sign or delegate a document, we will make such content available to the individuals you invited.
  • Service Providers/ Third parties: We may share your information with companies who provide services such as information processing hosting and storage, authentication systems, fraud detection, search technology, advertising and fulfillment services, managing and enhancing customer data, providing customer service, assessing your interest in our product and services, and conducting customer research or satisfaction surveys. These companies are subject to confidentiality agreements with us and obligated to protect your information. They may be located wherever MSB operates or agrees to operate.
  • Social Media Features: Our website includes social media features, including Facebook, Twitter and LinkedIn icons/links. These features may collect your IP address, authenticate your identity and provide you the option to share certain personal information with us such as your name and email address, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing it.
  • Partners: We may share your information with other companies/partners under common ownership or control with MSB.
  • User Consent: We may use or share your information in other ways and for different purposes if you have asked us to do so or have agreed to such sharing. For example posting customer references on our website that may recognize you if we have received your consensus.
  • Choice: We propose individuals the opportunity to choose whether their personal information is (a) to be disclosed to a non‐third party, or (b) to be used for a purpose that is incompatible with the purpose for which it was originally collected or subsequently authorized.

For Sensitive information, individuals should positively and clearly consent to the disclosure of the information to a non‐third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized, unless such new use or transfer is (a) in the vital interests of the individual or another person where the information subject is physically or legally incapable of giving his consent; (b) needed for the construction of our legal claims or defenses; (c) required to provide the information under national law or rules established by national competent bodies to the obligation of professional secrecy or by another person also subject to an equivalent obligation of secrecy; (d) necessary to carry out our obligations in the field of employment law in so far as it is authorized by applicable national legislation providing for adequate safeguards; or (e) related to information that is manifestly made public by the individual.

  • Others: It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for us to disclose your information. We may release your information when we believe, in good faith, that such a release is reasonably necessary to (i) comply with laws, (ii) enforce or apply the terms of our Privacy Policy or any of our user agreements, (iii) protect the rights, property or safety of MSB, our employees, our users, or others, (iv) respond to the claims of violation of the rights of third parties.

Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

We may be required to release user’s information to third parties in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Affiliated third parties may receive user data in fulfillment of our service. We maintain specific contract agreements with these companies to ensure that they use the data only for intended purposes and protect the information as we would. If this practice were to change, we would specifically provide you with the opportunity to choose to “opt in” or “opt out” of the sharing of user information.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Privacy Shield, MSB is essentially liable.

2.4. Your Use of Other User’s Information

By entering into our User Agreement, you agree that, with respect to other user’s personal information that you obtain through MSB Services or MSB-facilitated transaction, MSB hereby grants to you a license to use such information only for: (a) MSB-related communications that are not unsolicited commercial messages, and (b) any other purpose that such a user expressly agrees to, after you tell them the purpose you would like to use it for. In all cases, you must give users an opportunity to remove themselves from your database and a chance to review what information you have collected about them. In addition, under no circumstances, except as defined in this Section, can you disclose personal information about another user to any third party without our consent and the consent of that user. You agree that other users may use your personal information to communicate with you in accordance with this Section.

MSB and our users do not permit spam. Therefore, without limiting the foregoing, you are not licensed to add a MSB user to your mail list (email or physical mail) without their express consent.

2.5. Data Retention, Maintaining User’s Information, and Amendments of Accounts

User Information Retention: We shall preserve your information for the duration based on your consent and contractual requirement or as compulsory for legal business commitments.

User Information Review and Amendment: We provide you the capability to review and update specific information (such as user profile details, contact information, signature configuration, password and user settings and preferences) by logging into the MSB services (website and mobile app) and entering the new information into your user profile page. Upon request, we provide individuals with access to their personal information. Individuals may request corrections, deletions, or additions, as appropriate, except where the burden or expense of providing such access would be disproportionate to the risks to the individual’s privacy or would violate another individual’s rights.

You must promptly update your information if it changes or is inaccurate. You can also make a request to modify information that cannot be amended or deleted through the application by contacting us at support@msbdocs.com. We will take reasonable steps to modify information that is inaccurate or incomplete. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by law.

User Account related Queries: If you have any queries related to your account, you should contact your supervisory authority/ GDPR contact point who will further confirm and communicate with us at support@msbdocs.com to take the required action to resolve the queries or requests wrt user accounts. We shall process the resolution of queries.

2.6. Enforcement

We conduct a self‐assessment of relevant privacy practices to verify adherence to this policy annually for any violation of this policy which will be subject to disciplinary actions.

We investigate and attempt to resolve complaints regarding use and disclosure of personal information in accordance with this Policy. For complaints that cannot be resolved between us, we will comply with the requirements in the applicable standard clauses of this policy.

MSB is subject to the investigative and enforcement authority of the United States Federal Trade Commission (FTC).

You have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms – Refer to Annex I for additional information: https://www.privacyshield.gov/article?id=ANNEX-I-introduction

2.7. How We Secure User Information

MSB takes all reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure. We employ physical, electronic, and administrative procedures based on the sensitivity of the information that we collect. While we make every effort to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-parties from illegally obtaining this information, especially when accessing third party sites.

I. Security

We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. The ways we do this includes:

  • using encryption when collecting or transferring sensitive information;
  • limiting physical access to our premises;
  • limiting access to the information we collect about you to authorized personnel who need to know that information in order to operate, enhance or improve our MSB website and applications;
  • where required by law, destroying or de-identifying Personal Information;

II. Password protection

While collecting or transferring sensitive information such as passwords and other personal information, MSB uses encryption methods like Transport Layer Security (TLS). This protects information as it crosses the Internet.

As a user, you need to work against unauthorized access to your account, passwords and to your device by signing off once you have finished using MSB applications. You are responsible for all actions taken with your account. Therefore we recommend that you do not disclose it to any third parties. However if you choose to share this or any of your personal information with them, you should review that third party’s privacy policy. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf such as someone using your User ID and password to forward libelous material or sign documents through MSB Services. Therefore, if your password has been compromised for any reason, you should immediately change your password.

2.8. Other Sites Services and Linkage

Our MSB services may contain links to third-party websites or applications whose privacy practices may differ than ours. Your use of such site or app may result in the collection, processing, or sharing of information about you. We are not responsible for the content or privacy practices of other websites or services which may be linked on our services. We do not endorse or make any representations about them. We encourage you to carefully read the privacy statement of any such third parties.

2.9. Use of Cookies and other Technologies

A cookie is a simple text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Every cookie is unique to your particular web browser. It will contain some anonymous information such as a unique identifier and the site name with some digits and numbers. It allows the website to remember your browsing behavior & show you relevant ads based on the browsing pattern.

MSB services uses cookies to capture following information –

  • Source of visit to the website
  • Authentication and security
  • Time spent on the website
  • Pages viewed on the website
  • Storing your username

They are used to

  • Authenticate your access to our MSB website and application and prevent unauthorized parties from accessing your accounts.
  • Detect and fight spam, abuse, and other activities that violate MSB’s user agreements and terms.
  • Help us understand and improve how people use our MSB website and application.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to use some of the interactive features of MSB services.

Please note that the scope of this tracking is limited to the msbdocs.com domain. MSB does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

2.10. Opt-Out Policy

MSB offers its individuals (visitors and users) with reasonable mechanisms to exercise their choice or means to choose how they can use information provided. You can stop all collection of information by requesting deactivation of your registered account/profile or uninstalling MSB app. You may use the standard uninstall procedure as may be available as part of your mobile device or via the mobile apps marketplace or network. If, at any time you change your mind about receiving information from us or about sharing your information with third parties as outlined in this privacy policy, simply send us a request at support@msbdocs.com and privacy@msbdocs.com.

In case if you belongs to European Economic Area (“EEA”), please read the section 2.13 of this Privacy Policy.

2.11. Minors’ Privacy

MSB services takes children’s privacy seriously. Our products and services (including our website) are not designed for or marketed to minors. Accordingly, we do not knowingly collect, use or disclose personal information from minor’s or allow them to use our services. If you are a minor, please do not attempt to use the MSB services or submit any personal information through our websites without the express consent and participation of a parent or guardian. Any personal information collected from a minor without verified parental consent, will be deleted as quickly as possible. If you believe that we might have any information from or about a minor, please contact us using the contact information below in Section 2.15.

2.12. Privacy Rights by State Laws (California)

If you are a California resident, California laws permits you to request and collect from us once a calendar year, free of cost, information about the personal information we shared, if any, with third parties and other businesses for their own direct marketing uses. To make such a request, please send an email to privacy@msbdocs.com or mail a written request to us at 1 Park Plaza, Suite 600, Irvine, CA 92614.

2.13. Non-United States Users

Once you use our product and services, you:

  1. accept that your information will be processed and stored in accordance with this policy.
  2. agree to your information transferred to use and our partners, in USA or to the partners’ sites with whom we share it as per this policy.

If you as part of EEA, will have the following additional rights as per data protection laws:

  • You accept and agree that MSB may transfer your personal data outside of US and the EEA for processing purpose. With your prior written request, we may perform regular contractual agreements approved by the European Commission to ensure appropriate protection for the Personal Information as per the requirements of EU GDPR.
  • You acknowledge that MSB has been approved for Binding Corporate Rules (“BCRs”) for Processors and that, with effect from the date that our BCRs are adopted and upon notice from MSB, all personal data transfers resulting from the use of MSB signature made by or to MSB from EEA shall be conducted under, and in full compliance with, our BCRs, and any applicable Customer Agreements shall immediately terminate. The terms “Personal Data,” “Process/Processing,” “Controller,” “Processor,” “Subprocessor,” and “Data Subject” will have the meanings ascribed to them in the EU Data Protection Directive.
  • You always have right to request the access and verify your information (e.g. user account and profile) anytime ; knowing about what information we collect and use; why and how we collect and use information; duration till we retain information and with whom we share information.
  • You always have the right to rectify your personal data and to check that your information we stop using, delete or transfer.
  • You always have the right to reject/withdraw consent to process your personal data without impacting legitimateness of data processing before your consent is withdrawn and you can anytime request us to stop processing and storing your information for any state purpose defined in this policy. Refer section 2.2 and 2.3 of this policy.
  • You always have right to share any suggestion/ feedback to us to use, store, delete your personal data upon expiry of contracts/ closure of your organizations etc.
  • You always have a right to log any complaints to your local data protection jurisdiction.

In addition to MSB’s other data protection measures, we are self-certified with the EU-US Privacy Shield program – the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of the confidential and sensitive information from European Union member countries. MSB adheres to Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For more details on privacy shield program, please access the link https://www.privacyshield.gov.

MSB complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. MSB has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, MSB commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact MSB at privacy@msbdocs.com or 1 Park Plaza, Suite 600 Irvine, CA 92614.

Within the scope of this Privacy Policy, if a privacy complaint or dispute cannot be resolved through MSB’s internal processes, MSB has agreed to participate in the VeraSafe Privacy Shield Dispute Resolution Procedure. Subject to the terms of the VeraSafe Privacy Shield Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe under the Privacy Shield Dispute Resolution Procedure, please submit the required information to VeraSafe here: https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/

Should you have any questions/complaints regarding this Privacy Policy, please contact us at privacy@msbdocs.com.

By using our Services, you consent to your information being transferred to our facilities, in the United States or elsewhere, and to the facilities of those third parties with whom we share it as described in this Privacy Policy, except in the case of data transfers from the European Economic Area (EEA), which are covered under our EU-US Privacy Shield certification detailed above.

2.14. Amendments to Privacy Policy

MSB reserves the right to revise, amend, or modify this Policy from time to time, in any manner. Our use of the information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will post the changes at our website and/or may notify you by email or other means before the change becomes effective. We encourage you to periodically review this statement to be informed of how we are protecting your Personal Information. Your continued use of our Services following the posting of changes to this Privacy Policy will mean you consent to and accept those changes.

2.15. Contact Us

If you have any query/suggestion regarding our Privacy Policy or practices, you may contact us at privacy@msbdocs.com or via postal mail at 1 Park Plaza, Suite 600 Irvine, CA 92614.