Impression Privacy Statement

1.1 The purpose of this document (“Privacy Statement”) is to inform users of the Impression Signatures (Pty) Ltd (“Impression Signatures”, “we”, “us” or “our”) websites, applications and services of how we collect, use, store, share and otherwise process personal information, as well as user’s rights in relation to such processing. 

1.2. The manner in which Impression Signatures manages personal information (personal data as defined in the data protection laws includes but is not limited to names, postal address, email address, telephone number, date of birth etc. is subject to the Electronic Communications and Transactions Act 25 of 2002; Protection of Personal Information Act 4 of 2013 and the European Union General Data Protection Regulations (“Data Protection Laws”)). 

1.3. When users (individuals who make use of any Impression Signatures websites and/or applications) interact with Impression Signatures, submit information to Impression Signatures, or sign up for any products and/or services offered by Impression Signatures, all personal information, which may be collected through our website or other channels, is treated as confidential and private. Impression Signatures manages the users personal information in the following ways: 

• 1.3.1. By collecting personal information;
• 1.3.2. Using such personal information;
• 1.3.3. Sharing (amongst ourselves) the users personal information; and
• 1.3.4. Disclosing such personal information to Impression Signatures authorized service providers as well as relevant third parties in the manner set forth in this Privacy Statement. 

1.4. Impression Signatures may from time to time update this document to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. By using our Services, you understand that we will collect and use your personal information as described in this Privacy Statement.

1.5. Impression Signature’s core product and Services help users create, complete, and show the validity of digital or electronic transactions. As part of our Services, users information is collected and recorded to prove the validity of such transactions. 

2. COLLECTION OF PERSONAL INFORMATION 

2.1. Impression Signatures collects user Personal Information in the following ways: 

2.1.1. Upon submission of an application form or other forms relating to any of Impression Signatures’ products and services such as: 

• 2.1.1.1. When interacting with Impression Signatures’ customer service officers (via calls, letters, face to face meetings and emails)
• 2.1.1.2. When making use of any Impression Signatures service i.e. Websites and/or applications; such as submit or receive a signature request/ electronic transaction.
• 2.1.1.3. Upon submission of a request for Impression Signatures to contact them, or request to be included in an email or other mailing lists.
• 2.1.1.4. When there is a response to Impression Signatures promotions, initiatives or to any request for additional information;
• 2.1.1.5. When contacted by or respond to Impression Signatures marketing representatives and customer service officers;
• 2.1.1.6. When Impression Signatures receives references from business partners and third parties;
• 2.1.1.7. When Impression Signatures seeks information from third parties in connection with the products and services applied for;
• 2.1.1.8. By participating in surveys, sponsored events, competitions, or when you sign up for newsletter;
• 2.1.1.9. By commenting on our blogs, whitepapers, or community forums; and
• 2.1.1.10. Upon submitting Personal Information to Impression Signatures for any other reason.

2.2. When a user browses Impression Signatures Websites, it is generally done anonymously. Impression Signatures does not automatically collect Personal Information unless such information is provided or login credentials are used.

2.3. Where a user provides Impression Signatures with personal information relating to a third party (including but not limited to employees, representatives, or counterparties to a transaction), the user warrants that:

• 2.3.1. they have a lawful basis to disclose such personal information to Impression Signatures, including obtaining any required consent or authorisation from the relevant third party where applicable;
• 2.3.2. the personal information has been collected and disclosed in compliance with applicable data protection laws, including the Protection of Personal Information Act 4 of 2013; and
• 2.3.3. the relevant third party has been informed of, or has had access to, this Privacy Statement.

2.4. Impression Signatures reserves the right to request proof of such lawful basis or consent at any time.

2.5. To the extent permitted by law, the user indemnifies and holds Impression Signatures harmless against any loss, claim, or damage arising from the user’s failure to comply with this clause. 

2.6. Users must ensure that all Personal information submitted to Impression Signatures is complete, accurate, true and correct. Failure to do so to do so may result in Impression Signatures inability to provide users with the products and services requested. 
 

3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION 

3.1. Role of Impression Signatures (Responsible Party / Operator)
3.1.1. Impression Signatures processes personal information in different capacities depending on the context in which such information is collected and used:

3.2. Responsible Party (Controller): 
Impression Signatures acts as a responsible party where it determines the purpose and means of processing personal information, including for purposes such as: 

• 3.2.1. managing its websites, applications and platforms;  
• 3.2.2. customer onboarding, account management and billing;  
• 3.2.3. compliance with legal and regulatory obligations; and  
• 3.2.4. internal business operations, analytics (on an aggregated and anonymised basis), and service improvement.

3.3. Operator (Processor): 
Impression Signatures acts as an operator where it processes personal information on behalf of its customers in the course of providing its electronic signature and digital transaction services. In such cases:

• 3.3.1. the customer is the responsible party and determines the purpose and lawful basis for processing;
• 3.3.2. Impression Signatures processes personal information strictly in accordance with the customer’s documented instructions and applicable law; and
• 3.3.3. Impression Signatures implements appropriate technical and organisational measures to safeguard such personal information.

3.4. Where Impression Signatures acts as an operator, data subjects should direct any queries, requests, or complaints relating to the processing of their personal information to the relevant customer (as responsible party), unless otherwise required by applicable law.

3.5. Impression Signatures collects, uses and discloses Personal Information of users for the following purposes:

• 3.5.1. To respond to queries and requests;
• 3.5.2. To manage the administrative, and business operations of Impression Signatures and comply with internal policies and procedures;
• 3.5.3. To supply certain service we process and store limited personal information on the users behalf as a data processor.
• 3.5.4. To facilitate business asset transactions (which may extend to any mergers, business asset transactions, acquisitions or asset sales) involving any of the Companies;
• 3.5.5. To match any Personal Information held, relating to, any of the purposes listed herein;
• 3.5.6. To resolve complaints and handle requests and/or enquiries;
• 3.5.7. To prevent, detect, investigate a crime, analyse and manage commercial risks;
• 3.5.8. To provide media announcements and responses;
• 3.5.9. To monitor or record phone calls and customer, phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity assurance and identity verification purposes;
• 3.5.10. For legal purposes (including but not limited to obtaining legal advice and dispute resolution);
• 3.5.11. To conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
• 3.5.12. To meet or comply with any applicable rules, laws, regulations, codes of practice  or guidelines issued by or guidelines issued by any legal or regulatory bodies which are binding on Impression Signatures (including but not limited to responding to regulatory complaints, reporting to regulatory bodies and conducting audit checks, due diligence and investigations);
• 3.5.13. To comply with Trust and Security measures stipulated

3.6. In relation to particular products and services or user interactions, Impression Signatures may also specifically notify users of other purposes for which personal information is collected, used, or disclosed. 

3.7. Users have a choice to withdraw consent for receiving marketing or promotional materials/communication. Users may contact Impression Signatures using the Head Office contact details found on the main website www.impression-signatures.com or mail info@impression.cloud 

3.8. Once Impression Signatures receives confirmation that a user wishes to withdraw consent for marketing or promotional materials/communication, it may take up to 30 (thirty) working days for the withdrawal to be reflected on the system. Therefore, users may continue to receive marketing or promotional materials/communication during that period of time. It may be noted that even 
upon withdrawal of consent for the receipt of marketing or promotional materials, Impression Signatures may still contact users for other purposes in relation to the products and services held by users or subscriptions to Impression Signatures.

4. PROCESSING OF PERSONAL INFORMATION 

4.1. By providing Personal Information to Impression Signatures, users acknowledge that the information has been collected from them directly and there is consent for Impression Signatures to process such information.

4.2. Where users submit Personal Information (such as identifiers and contact information, geographic location, commercial information) via the Impression Signatures Website (e.g. Through completing any online form) the following principles are observed in the processing of such information:

• 4.2.1. Impression Signatures will only collect Personal Information for a purpose consistent with the purpose for which it is required. The specific purpose for which information is collected will be apparent from the context in which it is requested.
• 4.2.2. Impression Signatures will only process Personal Information in a manner that is adequate, relevant and not excessive in the context of the purpose for which it is processed.
• 4.2.3. Personal Information will only be processed for a purpose compatible with that for which it was collected, unless the user has agreed to an alternative purpose or Impression Signatures is permitted in terms of national legislation of general application dealing primarily with the protection of personal information.
• 4.2.4. Impression Signatures will keep a record of all Personal Information collected and the specific purpose for which it was collected for a period of 1 (one) year from the date on which it was last used.
• 4.2.5. Impression Signatures will not disclose user Personal Information relating to any third party, unless prior consent from the user is obtained, or where Impression Signatures is required to do so by law.
• 4.2.6. If Personal Information is released with consent of the user, Impression Signatures will retain a record of the information released, the third party to which it was released, the reason for the release and the date of release, for a period of 1 (one) year from the date on which it was last used.
• 4.2.7. Impression Signatures will destroy or delete any Personal Information that is no longer needed by Impression Signatures for the purpose it was initially collected, or subsequently processed.

5. DATA SUBJECT RIGHTS

5.1. Subject to applicable law, users have the following rights in relation to their personal information:

• 5.1.1. Access: to request access to the personal information held about them.
• 5.1.2. Correction: to request correction of inaccurate or incomplete information.
• 5.1.3. Deletion: to request deletion of personal information, where appropriate.
• 5.1.4. Objection: to object to the processing of personal information on reasonable grounds.
• 5.1.5. Withdrawal of Consent: to withdraw consent where processing is based on consent.
• 5.1.6. Complaint: to lodge a complaint with the relevant regulator.

6. DISCLOSURE OF PERSONAL INFORMATION 

6.1. Impression Signatures will take reasonable steps to protect Personal Information of users against unauthorised disclosures. Subject to the provisions of any applicable law, Personal Information may be disclosed for the purposes listed above (where applicable), to the following: 

• 6.1.1. Impression Signatures’ related corporations and employees to provide content, products and services to address user questions and requests in relation to customer accounts, subscription and billing arrangements with Impression Signatures as well as products and services;
• 6.1.2. Companies providing services relating to insurance, quality assurance and consultancy to Impression Signatures;
• 6.1.3. Agents, contractors or third party service providers who provide operational services to Impression Signatures, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to Impression Signatures;
• 6.1.4. Vendors or third party service providers in connection with marketing promotions and services offered by Impression Signatures;
• 6.1.5. Other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
• 6.1.6. Collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
• 6.1.7. Credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;
• 6.1.8. External banks, credit card companies and their respective service providers;
• 6.1.9. Impression Signatures‘ professional advisers such as auditors and lawyers;
• 6.1.10. Relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
• 6.1.11. Any other party to whom users authorise Impression Signatures to disclose Personal Information to.

7. CROSS-BORDER TRANSFERS OF PERSONAL INFORMATION (IF APPLICABLE)

7.1. Impression Signatures may transfer, store or process personal information outside of the Republic of South Africa in connection with the provision of its Services, including where it makes use of third-party service providers, cloud hosting infrastructure, or group entities located in other jurisdictions.

7.2. Where personal information is transferred across borders, Impression Signatures will ensure that such transfers are carried out in accordance with applicable data protection laws, including the Protection of Personal Information Act 4 of 2013 and, where applicable, the General Data Protection Regulation. This includes implementing appropriate safeguards, such as:

• 7.2.1. transferring personal information to jurisdictions that are recognised as providing an adequate level of data protection;
• 7.2.2. entering into binding agreements incorporating standard contractual clauses or equivalent safeguards with the receiving party; or
• 7.2.3. relying on other lawful transfer mechanisms permitted under applicable law.
    

8. By using the Services, users acknowledge that their personal information may be transferred to and processed in jurisdictions outside of South Africa.
 

9. Where Impression Signatures acts as an operator on behalf of a customer, such cross-border transfers will be conducted in accordance with the customer’s documented instructions and applicable law.

 
10. USE OF COOKIES 

10.1. Impression Signatures uses cookies (a small piece of information that is placed on a user’s computer when visiting certain websites) for the following purposes:

• 10.1.1. To enable certain features and functions on websites, e.g. Remembering user-id, favourite channel selections, browsing and other service preferences;
• 10.1.2. To build up a profile of how users experience the website;
• 10.1.3. To improve the efficiency of Impression Signatures’ website;
• 10.1.4. To administer services to users and advertisers;
• 10.1.5. To establish usage statistics.

10.2. Most internet browsers provide users with the option of turning off the processing of cookies (please see the “help” section of the browser), but this may result in the loss of functionality, restrict use of the website and/or delay or affect the way in which it operates.
 
10.3. Advertisements on the Impression Signatures website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Impression Signatures does not control these third parties and their cookie policies. Should users have any questions about Impression Signatures’ Data Privacy Policy, they may contact Impression Signatures. 

10.4. Impression Signatures is not responsible for the Personal Information policies (including Personal Information protection and cookies), content or security of any third party websites linked to the Website.

11. QUERIES 

11.1. If a user :

• 11.1.1. Would like to withdraw consent to any use of their Personal Information as set out in this privacy statement, they may contact the business unit executive that manages their account or info@impression.cloud;
• 11.1.2. Would like to obtain access and make corrections to their Personal Information records, they may contact the business unit executive that manages their account or info@impression.cloud;
• 11.1.3. If your Personal Information has been provided to Impression Signatures by a third party (e.g. A referrer), users should contact that organisation or individual to make such queries, complaints, and access correction requests to Impression Signatures on their behalf.
• 11.1.4. If a user withdraws their consent to any or all use of Personal Information, depending on the nature of such a request, Impression Signatures may not be in a position to continue to provide its products and services to users. In addition, Impression Signatures may not administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Impression Signatures , and may result in the user being in breach of contractual obligations or undertakings. Impression Signatures’ legal rights and remedies in such event are expressly reserved.
  

12. GOVERNING LAW 

This privacy statement and use of the Website shall be governed in all respects by the laws of South Africa.

 
13. INFORMATION OFFICER DETAILS 

Impression Signatures has appointed an Information Officer responsible for ensuring compliance with applicable data protection laws. 

14. INFORMATION OFFICER CONTACT DETAILS:

Name: Verusha Appalsamy 
Email: verushaa@impression.cloud / support@impression.cloud
   
Users may contact the Information Officer for any queries relating to this Privacy Notice or the processing of personal information.