HelloSign プライバシー ポリシー
掲載日：2022 年 7 月 15 日
発効日：2022 年 7 月 15 日
掲載日：2022 年 10 月 25 日
発効日：2022 年 10 月 25 日
Dropbox provides the Dropbox Sign service, which is an on-demand electronic signature service that gives Customers the ability to upload, display, deliver, receive, and acknowledge documents for electronic signature. Dropbox also provides the Dropbox Forms service, which provides Customers with a simple way to complete complex workflows through document automation and integrated electronic signature services. Dropbox also offers application programming interfaces (APIs) that allow Customers to build seamless embedded electronic signature or workflow automation services into their websites, applications and other properties. Finally, Dropbox also provides the Dropbox Fax service, which is an electronic facsimile service that gives Customers the ability to upload, display, deliver, and receive faxes without a traditional fax machine.
2. How we use your information
3. How we may share your information
5. How we protect your information
6. Your choices about your information
8. Where we may store, process, or transmit your information
10. How to contact us
1. INFORMATION WE COLLECT
Information you provide to us. When registering for or using the Dropbox Sign Services we collect personal information provided by you. For example, when you create a Dropbox Sign account, you may provide us with your name, account name, alias, employment-related information (to the extent you are using an employer’s business account), email address and a password, your phone number, your address and an electronic image of your signature (“Account information”).
You may provide us with personal information about other individuals when you use our Service, such as when you send or receive a signature request/workflow transaction, share information about such transactions, or ask others to electronically sign documents (“Your content”). You may also provide us with access to your contacts (“Contacts”) to make it easy for you to do things like share and collaborate with others, send messages, and invite others to use the Services. Contacts’ information may include personal information such as a real name, alias or email address. If you share your contracts with us, we will store those contacts on our servers for you to use.
Information that we collect automatically. We collect information related to how you use the Services, including actions you take in your account (like sharing, editing, viewing, creating, and signing documents) (“Usage information”). We use this information to provide, improve, and promote our Services, and to protect users of the Dropbox Sign Services. We also collect information from and about the devices you use to access the Dropbox Sign Services. This includes things like IP addresses, unique personal identifiers or online identifiers, the type of browser and device you use, the web page you visited before coming to our sites, and identifiers associated with your devices (“Device information”). Your devices (depending on their settings) may also transmit location information to the Dropbox Sign Services. For example, we use device information to detect abuse and identify and troubleshoot bugs.
HelloSign が第三者から収集する情報：HelloSign は、お客様によりよいサービスを提供するため、サービスをどのように維持し、改善できるかについて理解を深めることを主目的として、第三者が提供するその他のお客様に関する情報の共有および収集、またはそのいずれかを行うことがあります。また、購入、取得または考慮された製品またはサービスなど、お客様の購入または消費の履歴または傾向などの情報（以下「商業情報」）を収集します。具体例は次のとおりです。
- 分析：HelloSign は、Google Analytics や Heap など、Cookie その他の追跡技術を使用するサービスを用いて、製品およびサービスを改善するための利用データを収集します。
- Advertising: We use certain Google advertising features including Google Analytics Demographics and Interest Reporting and Remarketing. Third-party vendors, including Google, may show ads for the Dropbox Sign Services on sites across the Internet. You may opt out at any time here (adssettings.google.com/). We and third-party vendors, including Google, use first-party cookies and third-party cookies together to inform, optimize, and serve ads based on someone's past visits to our website.
- Mobile: We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the application.
Information we collect and process on behalf of you. The use of information collected through the Dropbox Sign Services shall be limited to the purpose for which you have engaged Dropbox. When you use the Dropbox Sign Services, we process and store certain information on your behalf as a data processor. For example, when a customer uploads documents for review or signature, we act as a data processor and process information on the customer’s behalf and in accordance with the customer’s instructions. In this situation, the customer is the data controller and is responsible for most aspects of the processing of the information.
If you are Customer that is based in the United States, its territories and possessions, Canada or Mexico, Dropbox, Inc. acts as your service provider. For all other Customers, Dropbox International Unlimited Company acts as a processor of your data.
Dropbox acknowledges that you have the right to access your personal information. Dropbox has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete data should direct their questions to Dropbox’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 and other technologies. We use technologies like cookies and pixel tags (more information available here: www.dropbox.com/terms/cookies) to provide, improve, protect, and promote the Dropbox Sign Services. For example, cookies help us with things like remembering your username for your next visit, understanding how you are interacting with the Dropbox Sign Services, and improving them based on that information. We may also use third-party service providers that set cookies and similar technologies to promote the Dropbox Sign Services.
HelloSign では、ブラウザから送信されたトラッキング拒否機能（Do Not Track）のシグナルを認識せず、これに応答しません。
2. HOW WE USE YOUR INFORMATION
HelloSign は、HelloSign 製品を通じて収集した情報を、以下のようにさまざまな理由で使用することがあります。
- HelloSign の製品およびサービスの提供、改善、保護および宣伝。
- お客様による HelloSign 製品の使用状況を把握し、機能をカスタマイズすること。
- HelloSign の製品およびサービスに関する問題の是正。
- HelloSign が提供する製品およびサービスの誤用の防止、ならびに、
- その他合法的な目的を実行すること。これについては HelloSign のユーザーおよびお客様にお知らせします。
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).
We give users the option to use some of the Dropbox Sign Services free of charge. These free Dropbox Sign Services are made possible by the fact that some users upgrade to one of our paid Dropbox Sign Services. If you register for the Dropbox Sign Services, we may, from time to time, send you information about upgrades. Users who receive these marketing materials can opt out at any time. If you don’t want to receive a particular type of marketing material from us, click the ‘unsubscribe’ link in the corresponding emails, or contact 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 respond to your request). Please note that such marketing opt-out does not impact any transactional or operational notices that we may need to send you.
We sometimes contact people who don’t have a Dropbox Sign account. For recipients in the EU, we or a third party will obtain consent before reaching out. If you receive an email and no longer wish to be contacted by Dropbox Sign, you can unsubscribe and remove yourself from our contact list via the message itself.
Bases for processing your information. We collect and use the personal data described above in order to provide you with the Dropbox Sign Services in a reliable and secure manner. We also collect and use personal data for our legitimate business needs. To the extent we process your personal data for other purposes, we ask for your consent in advance or require that our partners obtain such consent.
3. HOW WE MAY SHARE YOUR INFORMATION
- Vendors and other third-party service providers: We may share your information with third parties that we use for the business purposes of helping us to provide and support the Dropbox Sign Services. These parties provide services such as authentication, billing and collections, customer support, or data storage. We enter into legally binding agreements with these third-party service providers that protect your personal information and forbids such providers from using your information for their own purposes. These third parties (https://www.hellosign.com/subprocessors) will access your information to perform tasks on our behalf, and we’ll remain responsible for their handling of your information per our instructions.
- Dropbox has collected and disclosed the following categories of personal information, as described above, to vendors and third-party service providers in the preceding 12 months:
- アカウント情報：お客様の実名、別名、一意の個人識別情報またはオンライン識別情報など、お客様の個人を特定できる情報を含み、かつお客様の住所、インターネット プロトコル アドレス、メール アドレス、アカウント名または同様の識別情報を含むことがあります。
- Your content: what you and your users decide to input into the fields in the Dropbox Sign and Dropbox Forms forms that you create and/or fill out.
- 連絡先：実名、別名またはメール アドレスなど、お客様が HelloSign にアクセスを許可することを選択した識別情報を含みます。
- Usage information: includes information relating to your use of the Dropbox Sign Services. Because Dropbox provides online services, this may include internet or other electronic network activity information, such as information regarding your interaction with websites, applications, or advertisements.
- Device information: information about the particular devices you use to access the Dropbox Sign Services, which may include Usage information or device-specific information, such as an online identifier or Internet Protocol address, or geolocation data.
- Cookie およびその他の技術：Cookie およびピクセル タグなどの技術です。これらの技術は、オンライン識別子、インターネット プロトコル アドレス、その他類似の識別子および利用情報の収集につながる可能性があります。
- Other Dropbox Companies: the Dropbox Sign Services share infrastructure, systems, and technology with other services and companies owned or operated by Dropbox, Inc. (“Dropbox Companies”) to provide, improve, protect, and promote services provided by Dropbox Companies. We process your information across the Dropbox Companies for these purposes, as permitted by applicable law and in accordance with their terms and policies.
- Compliance with Law, Safety, Security, and Business Transactions: We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to: (a) comply with any applicable law, regulation, legal process, or appropriate government request; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of the Dropbox Sign Services or our users; (d) protect Dropbox’s rights, property, safety, or interest; or (e) perform a task carried out in the public interest.
- Other users: the Dropbox Sign Services display information like your name, profile picture, device, email address, and usage information to other users you collaborate or choose to share with. When you register your Dropbox Sign account with an email address on a domain owned by your employer or organization, we may help collaborators and administrators find you and your team by making some of your basic information - like your name, team name, profile picture, and email address - visible to other users on the same domain. This helps you sync up with teams you can join, and helps other users share files and documents with you.
- If you choose to opt-in to updates or marketing about the Dropbox Sign Services, we will email you with updates and offers, or inform you about other services and features.
4. RETENTION OF INFORMATION
お客様の個人情報を処理するための業務上の合法的な必要性が継続的になくなった場合、HelloSign は、お客様の個人情報を削除もしくは匿名化し、または、これが不可能である場合（お客様の個人情報がバックアップ アーカイブに保管されている場合など）、HelloSign はこれを安全に保管し、削除が可能になるまで、それ以上の処理を行えないように隔離します。
5. 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 email@example.com.
6. YOUR CHOICES ABOUT YOUR INFORMATION
Upon your written request (for which email is sufficient), Dropbox will provide you with information about whether we hold any of your personal information, the business or commercial purpose for collecting it, the types of sources we got it from and types of third parties we’ve shared it with. You may submit a data access request, request that your personal data be deleted, or object to the processing 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. We will not discriminate against you for exercising any of these rights.
7. CHILDREN’S PRIVACY
The Dropbox Sign Services are not intended for use by or directed to minors. We do not knowingly collect or ask for information from minors. We do not knowingly allow minors to use the Dropbox Sign Services. Any person who provides their information to Dropbox through the account login page for new customers, signup page, or any other part of the Dropbox Sign Services represents to Dropbox that they are of legal age (18 years of age or older or otherwise of legal age in your resident jurisdiction) and competent to agree to these Terms. We will delete any information we discover is collected from a minor without permission from their parent(s) or legal guardian(s). Please contact us using the contact details below if you believe you may have provided Dropbox with a minor’s information without permission from their parent(s) or legal guardian(s).
Around the world. To provide you with the Dropbox Sign Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. Data may also be stored locally on the devices you use to access the Dropbox Sign Services.
Data Transfers. When transferring data from the European Union, the European Economic Area, the United Kingdom, and Switzerland, Dropbox relies upon a variety of legal mechanisms, such as contracts with our customers and affiliates, Standard Contractual Clauses, and the European Commission's adequacy decisions about certain countries, as applicable.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield. Dropbox complies with the EU-U.S. and Swiss–U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union, the European Economic Area, the United Kingdom, and Switzerland to the United States, although Dropbox does not rely on the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield Frameworks as a legal basis for transfers of personal data. Dropbox has certified to the Department of Commerce that it adheres to the Privacy Shield Principles with respect to such data. You can also learn more about Privacy Shield at www.privacyshield.gov.
Dropbox is subject to oversight by the U.S. Federal Trade Commission. JAMS is the US-based independent organization responsible for reviewing and resolving complaints about our Privacy Shield compliance—free of charge to you. We ask that you first submit any such complaints directly to us via firstname.lastname@example.org. If you aren’t satisfied with our response, please contact JAMS at www.jamsadr.com/eu-us-privacy-shield. In the event your concern still isn’t addressed by JAMS, you may be entitled to a binding arbitration under Privacy Shield and its principles.
Our EEA Representative. Dropbox International has been appointed as Dropbox’s representative in the EEA for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. Dropbox International can be contacted in matters related to the processing of Personal Data. To make such an inquiry, please contact Dropbox International by emailing email@example.com. If they can’t answer your question, you have a right to raise questions or complaints with your local Data Protection Authority at any time.
9. CHANGES TO THIS POLICY
10. 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 firstname.lastname@example.org.