Privacy Policy

Introduction

Your privacy is very important to all of us at Zava Global Partners LLC, d.b.a BlueInk (“BlueInk”). We have
created the following Privacy Policy to explain the data collection and use practices of BlueInk. This Privacy Policy lets you know what information we collect when you visit our Site, why we collect it and how it is
used.

Definitions. The terms “BlueInk,” “we,” “us,” and “our” refer to BlueInk and its subsidiaries and affiliates. The
terms “you,” “your,” “yours” refer to users of our Site. The term “Customer” refers to any customer/purchaser of our Services who has registered for a BlueInk account and entered into an agreement with BlueInk.
The terms “Site”, “Website”, “Application”, “Product”, and “Service” refer to the web site and services
provided by BlueInk. This Privacy Policy is governed by our Terms of Use / Terms of Service.

This Privacy Policy does not apply to any third-party websites and apps that you may use, including any that are linked to in our Service. You should review the terms and policies for third-party websites and apps before clicking on any links.

BlueInk provides electronic signature (eSignature), document management and document workflow services. BlueInk also provides application programming interfaces (APIs) that allow BlueInk’s services to be incorporated into your website, application or other software systems.

Information we collect

Information you provide to us. When registering for or using the BlueInk Service we collect personal information from you. For example, when you create a BlueInk account, we ask for your name, email address, company name and a password. We may also collect information such as your address for billing purposes, your phone number for delivery of documents and notifications via SMS message, or your electronic signature. You may also provide us with personal information about other individuals when you use our Service, such as when you send or receive documents for eSignature, share information about such transactions, or ask others to electronically sign documents.

Information that we collect automatically. We collect information from you and about your device. This includes data about your software, the operating system version you use when accessing our service, your Internet Protocol address, precise geolocation information, unique device identifiers, and your usage data (such as number of documents sent for eSignature, API usage, time spent on a URL, etc.). We also collect data related to eSignature transactions such as: names, addresses, email addresses and / or phone numbers of individuals who are a party to an eSignature request, and the events that occur as a user interacts with our Service while electronically signing documents (e.g. timestamp of when a document is sent, opened or submitted, when data is entered in a field in a document, etc.).

Information that we collect from third parties. We may share and/or collect additional information about you from third parties primarily to assist us in understanding how we can maintain and improve the services we offer to better serve you. For example:

• Analytics: We use services like Google Analytics and FullStory, which use cookies and other tracking technologies to gather usage data (including pages visited, links clicked, non-sensitive text entered and mouse movements) that allows us to improve our products and services.

• Advertising:

• We use certain Google advertising features including Google Analytics Demographics and Interest Reporting and Remarketing. Third-party vendors, including Google, may show this Site’s ads on sites across the Internet. You may opt out at any time by visiting https://www.google.com/settings/ads
• We and third-party vendors, including Google and Facebook, use first-party cookies and third-party cookies together to inform, optimize, and serve ads based on someone’s past visits to our website.
• We may from time to time partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies to provide you advertising based on your browsing activities and interests. If you wish to opt out of interest-based advertising, click http://preferences-mgr.truste.com (or if located in the European Union click http://www.youronlinechoices.eu). Please note you will continue to receive generic ads.

Information we collect and process on behalf of Customers. As a Customer, your use of information collected through our service shall be limited to the purpose for which you have engaged BlueInk. When you are a Customer and use our Services, we process and store certain information on your behalf as a data processor. For example, when you as a Customer upload a document for review or signature, we act as a data processor and process information on behalf and in accordance with your instructions. In this situation, you as the Customer are the data controller and are responsible for most aspects of the processing of the information. Furthermore, in these situations, BlueInk may have no direct relationship with the individuals whose personal data it processes. BlueInk acknowledges that these individuals have the right to access their personal information. An individual who seeks access, or who seeks to correct, amend, or delete data should direct their questions to BlueInk’s Customers (the data controller). If requested to remove data, we will respond within a reasonable timeframe. 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.

Cookies: Cookies are small text files stored by your browser on your computer when you visit our Site. We use cookies to help us understand how people use our Site to improve the experience of our Site users. Cookies permit us to recognize users and avoid repetitive requests for the same information. We mostly use “session cookies” that are automatically deleted after each visit. Cookies from our Site cannot be read by other Sites. Most browsers will accept cookies unless you change your browser settings to refuse them.

BlueInk and its partners use cookies or similar technologies to analyze trends, administer the Site, track users’ movements around the website, and to gather demographic information about our user base.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our Website or Service. To manage Flash cookies, please visit http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

Because there is no accepted standard on how to respond to “do not track” browser-based signals, we do not respond to such signals. For more detailed information about our use of cookies and local storage, and how to manage them, see our Cookie Policy at https://blueink.com/cookie-policy/.

How we use your information

We may use the information we collect through our products for a number of reasons, including to:

• provide, operate, optimize and maintain our products and services;
• provide customer support;
• understand how you use our products and customize your experience;
• create your account(s);
• send you records of your use of the service, including for purchases or other events;
• send you marketing communications (in accordance with your subscription preferences);
• record details about the electronic signature transactions executed in our platform (such as when documents were sent, opened, signed, and where these actions took place);
• respond to your inquiries and requests;
• fix issues or problems with our products and services;
• prevent abuse of the products and services we offer; and
• carry out other legitimate business purposes, such as to improve our products and services, as well as other lawful purposes about which we will notify our users and clients.

We may also combine the information we collect (or that is otherwise provided to us) through aggregation and other means to limit the identification of any particular individual to help with our business goals (such as research and marketing).

Legal Basis for processing your information. If you are a user or Customer located in the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate business interests. In some cases, we may also have a legal obligation to collect personal information from you. If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the “How to Contact Us” heading below.

How we may share your information

We may use your personally identifiable information as described below:

• Vendors and other third-party service providers. We may share your information with third parties that we use to provide and support our Services. These parties provide services such as data storage, email delivery, sms delivery, billing and collections, and customer support. We enter into legally binding agreements with these third- party service providers that permit the processing of personal information only to deliver the services that we have retained them to provide and prohibit the use of personal data for any other purposes.
• Compliance with Law, Safety, Security, Business Transactions: We may also disclose your information to third parties: (a) where required by law or regulatory requirement, court order or other judicial authorization, (b) in response to lawful requests by public authorities, including for the purposes of meeting national security and law enforcement requirements; (c) in connection with the sale, transfer, merger, bankruptcy, restructuring or other reorganization of a business; (d) to protect or defend our rights, interests or property, or that of third parties; (e) to investigate any wrongdoing in connection with our products and services; and (f) to protect the vital interests of an individual.
• To other persons with your consent (e.g. fulfilling your eSignature requests)
• If you choose to opt-in to BlueInk updates, we will email you technical updates or inform you about other services and features.

Retention of information

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other lawful purposes.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How we protect your information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at privacy@blueink.com.

Your choices about your information

General. Upon your written request (for which email is sufficient), BlueInk will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by logging into your account, or by contacting us using the contact details below. We will respond to your request within a reasonable timeframe.

European Economic Area (EEA) or Switzerland: If you are based in the EEA or Switzerland you have other rights as provided below:

• Access: If you wish to access your personal information that BlueInk collects, you can do so at any time through the Service or by contacting us using the contact details provided below.
• Correction, update or deletion: You can correct, update or request deletion of your personal information through the Service interface, or by contacting us using the contact details provided below.
• Object to processing: When we reply on your consent to process your personal information, you may withdraw consent at any time by contacting us using the contact details provided below. This will not affect the lawfulness of processing prior to the withdrawal of your consent.
• Data Protection Authority: You have a right to raise questions or complaints with your local data protection authority at any time.
• Marketing: You have the right to opt-out of marketing communications we send you at any time. You can do this by clicking the “unsubscribe” link in the marketing e- mails we sent you or by contacting us using the contact details provided below (if using the contact details please provide your complete name, e-mail address, and any other relevant information that may be required to address your request). Please note that such marketing opt-out does not impact any transaction or operation notices that we may need to send you.

Cookies. Users of https://blueink.com can control their cookie preferences by using the consent mechanism available on that website.

Children’s privacy

This site and our Services are not intended for or directed to persons under the age of 18. We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use our Services. Any person who provides their information to BlueInk through the Account Registration page for new customers, Login Page, or any other part of the BlueInk Site represents to BlueInk that they are 18 years of age or older. We will delete any information we discover is collected from a minor. Please contact us using the contact details below if you believe we might have information about a minor.

Users from outside of the united states

General: By using the BlueInk Services you acknowledge and agree that: (i) your information will be processed as described in this Privacy Policy; and (ii) you consent to have your information transferred to us and our facilities in the United States or elsewhere, including those of third parties as described in this Privacy Policy.

European Economic Area (EEA) or Switzerland: If you are based in the EEA or Switzerland, you acknowledge and agree that BlueInk may transfer your information (including personal information) to us and our facilities in the United States or elsewhere, including those of third parties as described in this Privacy Policy. In order to meet the requirements of the EU General Data Protection Regulation (“GDPR”), BlueInk’s Terms of Use / Terms of Service for Customers include a Data Protection Addendum with Standard Contractual Clauses approved by the European Commission (“SCCs”) to ensure the adequate protection of Personal information.

EU-U.S. privacy shield and swiss-U.S. privacy shield

BlueInk complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Frameworks (each a “Privacy Shield Framework” of “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 and Switzerland, respectively, to the United States. BlueInk 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/.

BlueInk is responsible for the processing of personal information it receives, under each Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. BlueInk complies with the Privacy Shield Frameworks for all onward transfers of personal information from the EU and Switzerland, including the onward transfer liability provisions. In certain situations, BlueInk may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

With respect to personal information received or transferred pursuant to the Privacy Shield Frameworks, BlueInk is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In compliance with the Privacy Shield Principles, BlueInk commits to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact BlueInk at privacy@blueink.com.

If you have an unresolved data use or privacy concern that we have not addressed satisfactorily, you may contact our U.S.-based third-party dispute resolution provider (free of charge) at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.

Under certain conditions, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. For additional information see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction

Changes to this policy

If we change our privacy policies and procedures materially, we will post those changes to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on this page. When we change the policy in a material manner, we will update the “effective date” at the top of this page, and we may also notify you of the change via email or other prominent notice posted on this site or the Service.

How to contact us

For questions or concerns regarding the collection, use, or disclosure of your information, you can contact us by sending an email to privacy@blueink.com or by contacting us at:

Zava Global Partners LLC (dba BlueInk)
7373 E. Doubletree Ranch Road
Suite 200
Scottsdale, Arizona 85258