Effective Date: March 26, 2024
Last Updated on: March 26, 2024
This privacy policy (“Policy”) explains how Whizpool or any of its affiliates
or subsidiaries. (“We”, “Us”, “Our”) Processes Personal Data collected from You. Terms not specifically
defined here in shall have the meaning a scribed there to in the Terms of Service.
1.1. “Controller” means the natural or legal person,
public authority, agency, or otherbody which alone or jointly with others, determines the purposes and
means of the processing of Personal Data.
1.2. “End-User” means any
person or entity with whom the Subscriber interactsusing eZy
Sign.
1.3. “Personal Data” means any information relating to an
identified or identifiable natural person; an identifiable natural person is one who can be
identified, directly orindirectly, in particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or more factors specific to the
physical, physiological, genetic, mental, economic, cultural or social identity of that natural
person.
1.4. “Process” means any operation or set of
operations which is performed on Personal Data or on sets of Personal Data, whether or not by
automated means, such as collection, recording, organization, structuring, storage, adaptation or
alteration,retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making
available, alignment or combination, restriction, erasure or
destruction.
1.5. “Processor” means a natural or legal person, public
authority, agency, or otherbody which Processes Personal Data on behalf of the
Controller.
1.6. “eZy Sign” shall have the meaning ascribed to it in
the Terms of Service.
1.7. “Terms of Service” means the binding
contract between Us and You which governs the access and use of eZy Sign by You available at https://ezysign.com/terms
1.8. “You”
and “Your” means an identified or identifiable natural person whose Personal Data We
process as a Controller.
2.1. You directly provide Us with most of the data We collect. We collect
PersonalData from You directly as follows: a) When You subscribe to eZy Sign by agreeing to the Terms
of Service and create an account, We collect sign-up and account information including Your name (or
the name of Your organization/company), Your phone number, Your email address and Your electronic
signature; b) When You subscribe to a plan, We collect commercial information including billing and
payment information (e.g., credit card number, expiration date, visual cryptogram), products
orservices purchased; c) When You submit web forms on Our Website(s) or as You useinteractive features
of the Website(s), including providing feedback or suggestions,making requests, or participation in
surveys, contests, webinars, events, podcasts,promotions, sweepstakes, requesting customer support, or
otherwise communicatingwith Us; c) When You provide testimonials, forms or information to Us in other
contexts;or d) When You authorize Us to connect with a third-party service, We will access andstore
Your Personal Data that the third-party service makes available to Us, which may include Your email
address, location or profile information;
2.2. We may also receive Your Personal Data
indirectly as follows: a) from third party sources like marketing lists, databases and social media
but only where We have checked that these third parties either have Your consent or are otherwise
legally permitted or required to disclose Your Personal Data to Us; b) When You download and/or use
eZy Sign, We automatically collect information on the type of device You use, and the operating system
version, to perform Our agreement with You; c) When You use or view Our Website(s), information is
collected via Your browser’s cookies as described in clause 10 herein;
d) We may also collect or
receive Your Personal Data from other sources such as Our business or channel partners through whom
You create or access Your Account, publicly available sources, email add-ons and/ or through the
combining of information We obtain from third parties along with the Personal Data You provide to
Us.
2.3. The Website(s) includes social media features and widgets that are either hostedby
a third-party or hosted directly on the Website(s) and Your interaction with thesesocial media
features and widgets is governed by the privacy statement of the companies that provide them. You
should check Your privacy settings on these third party services to understand and change the
information sent to Us through these services.
We Process Your Personal Data to: a) facilitate Your access to the
Website(s) andService(s); b) process and complete payment transactions; c) provide customer serviceand
support; d) send You communication on Your use of the Service(s), updates on OurTerms of Use or other
policies; e) send You communication on new features in theService(s) or new service offerings; f)
conduct research, analysis and developmentactivities (including but not limited to data analytics,
surveys and/or profiling) toimprove Our Service(s) and facilities in order to enhance Your
relationship with Us orfor Your benefit, or to improve any of Our Service(s) for Your benefit; e)
Organizeevents or for other marketing/ promotional activities; f) investigate and preventfraudulent
transactions, unauthorized access to the Websites and Service(s), and otherillegal activities; g)
personalize the Websites and Service(s); and for other purposes forwhich We obtain Your consent.
4.1. You acknowledge that We will share Your Personal Data with Our
groupcompanies and third-party service providers so that they may offer You Our Service(s)and/or to
send information or updates on the Service(s) if You are a Subscriber.
4.2. When We Process
Your order where You are a Subscriber, we may send YourPersonal Data to and also use the resulting
information from credit reference agenciesto prevent fraudulent purchases. We use PCI-DSS compliant
services of third partyvendors to manage payments and We don’t have access to Your personal account
datain transit or at rest.
4.3. We share Personal Data with Our third-party service
providers that host andmaintain Our Website(s), applications, backup, storage, payment processing,
analyticsand other services. These third-party service providers may have access to or ProcessYour
Personal Data for the purpose of providing these services to Us.
4.4. We may share Your
Personal Data with third-party providers who assist Us inmarketing and promotions in compliance with
applicable laws.
4.5. We may be required to disclose Your Personal Data in response to: a)
lawfulrequests by public authorities, including to meet national security or law
enforcementrequirements and/or b) subpoenas, court orders, or legal process, or to establish
orexercise Our legal rights or defend against legal claims.
4.6. We may also share Personal
Data to assist investigation and prevention of illegalactivities, suspected fraud, situations
involving potential threats to the physical safetyof any person, violations of Our Terms of Use, or as
otherwise required by law.
5.1. We mainly Process Personal Data in the US. However, We may transfer
Personal Data outside the US for the purposes referred to in Section 4. We will ensure that the
recipient of Your Personal Data offers an adequate level of protection that is at least comparable to
that which is provided under applicable data protection laws.
6.1. We retain the Personal Data collected where an ongoing legitimate
businessrequires retention of such Personal Data.
6.2. In the absence of a need to retain
Personal Data under Section 6.1. above, We will either delete it or aggregate it, or, if this is not
possible then We will securely store Your Personal Data and isolate it from any further Processing
until deletion is possible.
We use appropriate technical and organizational measures to protect the
Personal Data that We collect and Process. The measures We use are designed to provide a level of
security appropriate to the risk of Processing Your Personal Data. If You have questions about the
security of Your Personal Data, please contact Us immediately asdescribed in this Policy.
You are entitled to the following rights:
8.1. You can request
Us for access, correction, update or request deletion of Your Personal Data.
8.2. You can
object to the Processing of Your Personal Data, ask Us to restrict processing of Your Personal Data or
request portability of Your Personal Data.
8.3. You have the right to opt-out of marketing
communications We send You at anytime. You can exercise this right by clicking on the “unsubscribe” or
“opt-out” link inthe marketing emails We send You. To opt-out of other forms of marketing (such
aspostal marketing or telemarketing), please contact Us.
8.4. Similarly, if We have
collected and processed Your Personal Data with Your consent, then You can withdraw your consent at
any time. Withdrawing Your consentwill not affect the lawfulness of any processing We have conducted
prior to Your withdrawal, nor will it affect processing of Your Personal Data conducted in reliance on
lawful processing grounds other than consent.
8.5. You have the right to complain to a data
protection authority about Our collectionand use of Your Personal Data. For more information, please
contact Your local data protection authority.
8.6. If You seek access to, or wish to
correct, update, modify or delete Your Personal Data that We process, please contact Us at the details
provided in clause 12. We respond to all requests We receive from individuals wishing to exercise
their data protection rights within a reasonable timeframe in accordance with applicable data
protection laws.
9.1 This section provides additional details about the personal information
we collectabout California consumers and consumers' rights under the California Privacy Rights
Act, ( “ CPRA ” ) amending the California Consumer Privacy Act ( “ CCPA ” ) and the Virginia residents
under the Virginia Data Protection Act (“VDPA”). This section appliesonly to California residents and
Virginia residents and their personal information we collect as a Business (as defined in the CPRA and
VDPA).
9.2. Collection of Personal Data. The categories of
personal information We havecollected in the twelve (12) months prior to the Effective Date and that
We may collect include:
A) Identifiers such as a real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address, account name, a device
identifier; an Internet Protocol address; cookies, beacons, pixeltags, mobile ad identifiers or
similar technology; customer number, uniquepseudonym or user alias; telephone numbers, or other forms
of persistent or probabilistic identifiers that can be used to identify a particular consumer
ordevice;
B) Signature, physical characteristics or description, telephone number,
state identification card number, insurance policy number, employment, employ menthistory, bank
account number, credit card number, debit card number or anyother financial information, medical
information or health insurance information;
C) Internet or other electronic network
activity information, including, but notlimited to, browsing history, search history, and information
regarding aconsumer's interaction with an internet website, app or
advertisement.
D) Geolocation data;
E) Audio, electronic, visual, thermal,
ol factory or similar information.
We collect this personal information for business
purposes as described in the"PURPOSES FOR WHICH PERSONAL DATA WILL BE PROCESSED " section of
our general privacy policy above.
9.3. Disclosure of Personal Data. We have disclosed the
categories of personal information listed in clause 1 above for a business purpose in the twelve (12)
monthsprior to the Effective Date and may disclose such personal information to service providers or
contractors or to any other third parties who support our business provided (a) they do not sell or
share (as defined under the CPRA) such personal information or (b) retain, use or disclose such
information for any purpose other than for the specific purpose of performing the services specified
in our contract with themor (c) combine such information with any other information received directly
by them .We do not sell or share (as the terms is defined in the CPRA ) the personalinformation We
collect without providing You a right to opt out. We do not sell or share personal information of
minors of at least the age of thirteen (13) but less than sixteen(16) years without receiving such
minor ’ s consent or the consent of the minor ’ s guardian if the minor is less than thirteen (13)
years. We have not sold or shared (asthe term is defined in the CPRA ) any personal information in the
twelve (12) monthsprior to the Effective Date. We shall not disclose further the personal
informationcollected for verification of a consumer’s request or retain it longer than it is
necessaryfor the purpose of verification.
9.4. Your Rights.
9.4. Rights of the residents of the State of California:
You have certain rights, subject to certain limitations under applicable law, with respect to your
personal information, including:
A) The right to request disclosure of details, and categories of personal
information collected;
B) The right to request disclosure of personal information collected
twelve (12)months prior to the Effective Date, this right shall apply only to personal information
collected after January 1, 2022
C) The right to request di sclosure of information sold or
shared and the right todisclosure of the service provider or contractor, or a third-party (as defined
inthe CPRA) to whom such information is sold or shared ;
D) The right to request the
correction of inaccurate personal information collected.
E) The right to request deletion of
Your personal information held by Us or by Our service provider, contractor, or any other third party
We have disclosed personal information to. We shall hold a confidential record of all deletion
requests forthe purpose of preventing the selling of such personal information for which You have
submitted a deletion request.
F) The right to "opt out" of any sale or sharing of
personal information (as definedin the CPRA ), if such sale or sharing occurs.
G) The right to
request the transfer of specific pieces of personal information toany other entity.
H) The
right not to be discriminated against for exercising your rights under CPRA.
Rights for the residents of the Commonwealth of
Virginia: You have certain rights, subject to certain limitations under applicable law, with
respect to your personal data,including
A) The right to confirm whether We are processing the personal information
collected and the right to access such personal information.
B) The right to correct
inaccuracies in the personal data collected taking into account the nature of the personal information
and the purposes of the processing of the personal information
C) The right to request the
deletion of personal information provided by or obtained from You.
D) The right to request the
deletion of personal information collected from sources other than You. We shall comply with such a
request by either (i) retaining are cord of the deletion request and the minimum information necessary
for the purpose of ensuring Your personal information remains deleted from the business ’ s records
and not using such retained information for any other purpose pursuant to this Section or (ii) opting
You out of the processing of such personal information for any purpose except those exempted by the
Virginia Data Protection Act.
E) The right to request the transfer of the personal information
collected to another controller in a technically feasible and readily usable format.
The right to opt-out of the processing of the personal information for
purposes of (i)targeted advertising, (ii) the sale of personal information, or (iii) profiling in
furtheranceof decisions that produce legal or similarly significant effects concerning You. California
and Virginia consumers may make a request pursuant to their rights underthe CPRA and VDPA respectively
by contacting Us at support+ezysign@whizpool.com or via mailto
Our postal address set forth above. We will verify Your request using the information associated with
Your account, including e-mail address and/or Government identification. We will let You know if We
need additional information to verify Youridentity. Consumers may also designate an authorised agent
to exercise these rights ontheir behalf.
Where We are a service provider: We may also
act as a service provider (as theterm is defined in the CPRA). When We act as a service provider,
including by providing our services to another company that You interact with, We follow the
instructions of the company that engaged Us as a service provider and You should directly contact that
company if You have any questions or would like more details on how Your personal information is
processed by that company.
10.1. Cookies are text files that are placed on Your computer to collect
standard internet log information and visitor behavior information by Us. When You visit the
Website(s), We may collect Personal Data automatically from You through cookies or similar technology.
We also set cookies to collect information that is used either in aggregate form to help Us understand
how our Website(s) are being used or how effective Our marketing campaigns are, to help customize the
Website(s) for You or to make advertising messages more relevant to You.
10.2. Essential
Cookies: We set essential cookies that enable core functionality such as security, network management,
and accessibility. You may not opt-out of these cookies. However, You may disable these by changing
Your browser settings, but this may affect how the Website(s)
functions.
10.3. Analytics, Customisation and Advertising Cookies: We set these cookies
to help Us improve Our Website(s) by collecting and reporting information on how You use it. The
cookies collect information in a way that does not directly identify anyone.
11.1. We recognize the importance of children's safety and privacy.
We do not request, or knowingly collect, any Personal Data from children under the age of 18. If a
parent or guardian becomes aware that his or her child has provided Us with Personal Data, they should
write to us at the email address provided in clause 12.
12.1. eZy Sign is intended for use by enterprises. Where eZy Sign is made
available to an End-User through a Subscriber, that enterprise is the Controller of the End-User’s
Personal Data. For example, when a Subscriber uploads Documents for review or signature, We act as a
data processor and process the Documents on the Subscriber's behalf and in accordance with their
instructions. In such a case, the End-User’s data privacy questions and requests should be submitted
to the Subscriber in its capacity as the End-User’s Controller. If the End-User is an individual who
interacts with a Subscriber using Our Services, the End-User will be directed to contact Our
Subscriber for assistance with any requests or questions relating to their Personal Data. We are not
responsible for Subscribers’ privacy or security practices which may be different from this notice.
Subscribers to Our Services are solely responsible for establishing policies for and ensuring
compliance with all applicable laws and regulations, as well as any and all privacy policies,
agreements, or other obligations, relating to the collection of Personal Data in connection with the
use of eZy Sign by End-Users.
12.2. Our Website(s) contain links to other websites. Our
Policy applies only to our Website(s), so if You click on a link to another website, You should read
their privacy policy. We encourage You to review the privacy statements of any such other websites to
understand their Personal Data practices.
12.3. This Policy does not apply to aggregated
information which summarizes statistical information about groups of members, and which does not
include name, contact information, or any other information that would allow any particular individual
to be identified.
You may contact us if You have any enquiries or feedback on Our personal
data protection policies and procedures, or if You wish to make any request, in the following
manner:
Attention: Support Team
Email Address: support+ezysign@whizpool.com
We keep this Policy under regular review and may update this webpage at any
time. This Policy may be amended at any time and You shall be notified only if there are material
changes to this Policy.