VICENT SOLUCOES TI LTDA · CNPJ 53.183.462/0001-58
This Privacy Policy describes how VICENT SOLUCOES TI LTDA ("DottSign", "we", "us", or "our"), a company registered in Brazil (CNPJ 53.183.462/0001-58), collects, uses, stores, and protects your personal data when you use the DottSign platform (website, web application, mobile application, WhatsApp signing channel, and connected AI app integrations where available). It applies to all users worldwide and is designed to comply with Brazil's Lei Geral de Proteção de Dados (LGPD — Law No. 13,709/2018) and, where applicable, the EU General Data Protection Regulation (GDPR — Regulation 2016/679).
1. Controller Identity and Contact
Data Controller: VICENT SOLUCOES TI LTDA CNPJ: 53.183.462/0001-58 Registered office: Brazil Data Protection Officer (Encarregado — LGPD Art. 41): dpo@dottsign.com General privacy enquiries: privacy@dottsign.com Legal notices: legal@dottsign.com We will respond to data-subject requests within 15 business days (LGPD Art. 18) or 30 calendar days (GDPR Art. 12(3)), whichever is stricter for your jurisdiction.
2. Personal Data We Collect
2.1 Account and Identity Data
- Full name (optional at registration; required for signing).
- E-mail address (required).
- Password (stored securely; the plaintext is never stored).
- Profile picture — uploaded voluntarily or obtained via Google OAuth.
- Google OAuth identifier and Google profile data, when you choose Google sign-in.
- Preferred language setting.
2.2 Authentication and Security Data
- Two-factor authentication (2FA) secret and backup codes, stored securely.
- Session tokens stored server-side with expiry.
- Password-reset tokens (short-lived).
- Mobile app: a flag indicating whether biometric app-lock is enabled. Biometric authentication is handled entirely on-device by the operating system. No biometric data reaches our servers.
2.3 Contract and Document Data
- PDF files you upload or import, stored encrypted on AWS S3.
- Contract title, description, tags, category, status, and expiry dates.
- Plain text extracted from PDFs, used to provide document-processing and AI features.
- A cryptographic hash of each uploaded document for integrity verification.
2.4 Signature and Audit Data
- Typed name used as electronic signature.
- IP address and browser information at the time of signing.
- Signing timestamp, verified by a timestamp authority.
- Cryptographic signature value and associated certificate.
- A cryptographic hash of the signed PDF.
- E-mail address of external (non-registered) signers.
- One-time code verification records for signing sessions.
2.5 AI Analysis Data
- Extracted document text may be sent to Groq, Inc. (USA) for AI inference, including categorisation, summarisation, clause analysis, and question-and-answer functionality, when you use DottSign's AI features.
- This processing is performed solely to provide the AI functionality requested by you. Neither DottSign nor Groq uses DottSign customer data to create, train, fine-tune, or improve generalized artificial intelligence or machine-learning models.
- AI job results, such as categories, summaries, and clause flags, are stored on our servers and linked to the relevant contract.
- Groq's applicable data-handling controls govern any temporary processing or logging associated with API inference requests. We do not authorize Groq to use DottSign customer data for generalized model training or improvement.
2.6 Billing and Subscription Data
- Stripe customer ID and subscription/price identifiers.
- Subscription status and current period end date.
- We do not store raw card numbers or full payment credentials — all payment processing is handled by Stripe, Inc.
2.7 Organisation Data
- Organisation name, URL slug, and optional logo.
- Member roles within organisations you belong to.
2.8 Technical and Usage Data
- Audit log entries (action type, resource, IP address, timestamp) for security and legal-evidence purposes.
- In-app notification content and read status.
- Usage counters (contracts created, AI questions used) for plan-limit enforcement.
- Salesforce OAuth tokens (stored encrypted) if you connect the Salesforce integration.
- With your consent, the web application and mobile app collect feature views, actions, and their outcomes (such as completed, failed, or blocked), through Google Analytics and Firebase Analytics, respectively. Events may include platform, plan, language, duration, item counts, and limited technical error codes. They use browser or app-instance and session identifiers and, when signed in, your internal account ID. These identifiers are pseudonymous, not anonymous. Product analytics events exclude document content, titles, names, email addresses, phone numbers, passwords, verification codes, and signing or OAuth tokens; private web page addresses are replaced with generic feature addresses.
2.9 Google Drive Data (Web Only — Optional)
- What we access: When you choose to import a PDF from Google Drive, we request a short-lived OAuth 2.0 access token scoped to drive.file and open Google's own Picker window, where you browse and select a file yourself. We never see or request a list of your Drive contents — Google's Picker handles browsing and search entirely on its own side. Upon your selection, we download the binary content of only the chosen PDF file.
- Purpose: Solely to allow you to import the PDF you selected as a contract document in DottSign. If you subsequently use DottSign AI features on that contract, the extracted text may be sent to Groq solely to provide the requested AI functionality.
- Storage: The OAuth access token is held only in browser memory for the duration of the import and is never transmitted to or stored on our servers. The selected PDF is stored encrypted on AWS S3 as a DottSign contract. We do not retain other Google Drive metadata.
- Third-party AI processing: When AI features are used on a document imported from Google Drive, extracted text from that document may be transmitted to Groq, Inc. solely to provide the requested DottSign AI functionality. Neither DottSign nor Groq uses Google Workspace or Google Drive user data, including raw, aggregated, anonymized, or derived data, to create, train, fine-tune, or improve generalized artificial intelligence or machine-learning models.
- Scope used: https://www.googleapis.com/auth/drive.file (per-file access limited to files you explicitly select through Google's Picker or that DottSign itself creates; no standing access to your Drive, no write, delete, or sharing permissions beyond that).
- No background access: Drive access occurs exclusively in response to an explicit user action (clicking “Import from Google Drive”). We do not access your Drive at any other time.
- Revoking access: You may revoke this access at any time from your Google Account permissions page (myaccount.google.com/permissions) without affecting your DottSign account.
2.10 WhatsApp Communication Data (PRO and ENTERPRISE plans)
- Signer phone number: Collected when a contract owner invites a signer via WhatsApp. Stored in our database linked to the signature spot and associated WhatsApp message record.
- WhatsApp signing session state: A temporary session is created when a signer initiates the WhatsApp-native signing flow. It stores the signer's name, email address, verified identity state, and signing progress. Sessions expire automatically after 30 minutes of inactivity.
- WhatsApp message records: Each outbound WhatsApp message (signature invitation, OTP, document delivery) generates a log entry containing the signer's phone number, delivery status, and the external message ID returned by the WhatsApp provider. This log is retained with the signature spot record.
- WhatsApp identity collection via Flows: When the signer completes the in-WhatsApp identity form (email address and full name), these values are received by our server through the Meta WhatsApp Cloud API and used solely to verify the signer's identity and pre-fill the signature record.
2.11 Identity Verification Data (Didit)
- When you verify your own identity or a contract owner requires a signer to do so, Didit's hosted verification flow may process images of a government-issued identity document, information read from that document (which may include name, date of birth, document number, issuing country, and expiry date), a selfie or face image, and liveness or face-matching signals. The checks and data requested depend on the verification configured for that session.
- DottSign receives and stores limited verification and linkage data: the account or signer's email or email hash, Didit session and workflow identifiers, the hosted session URL, document type, status, verification and expiry timestamps, and a limited non-document decision reason where supplied. We do not intentionally store the original identity-document or selfie images, document number, date of birth, face template, or full Didit decision payload in our identity-verification record.
- We use verification data to confirm identity, help prevent impersonation and fraud, link a completed check to an account or contract, and apply a verification requirement requested by a contract owner or workflow. Didit processes the submitted evidence through its hosted service under its own verification notice and the applicable service arrangement. See Didit's End User Terms and Verification Privacy Notice.
- Identity-verification results may be Approved, Declined, or In Review. In Review means the provider has not returned a final result. An unresolved required check may prevent a signer from completing the signature; the contract owner may be able to skip the requirement, with that action recorded in the contract audit trail.
2.12 Connected AI Apps (MCP)
- If you connect an external AI app such as Claude, Cursor, or another compatible MCP client, DottSign stores connection details such as the app's registered name and redirect addresses, the permissions you grant, connection and revocation times, last-use time, and hashed OAuth tokens. We do not store the plaintext access or refresh tokens after issuing them.
- When you use the connected app, it can request the DottSign data allowed by its granted permissions. Depending on the tools used, this may include contract titles and details, extracted contract text, signer names, emails and signing status, obligations, notifications, renewal history, and plan usage. Create, edit, and send-for-signature actions require their respective permissions and are performed in your DottSign account.
- The information returned to the connected app is then handled by that app and its provider under their own privacy terms. We do not control whether or how that provider retains or uses information it receives. Review its terms before connecting. You can revoke a connection in DottSign; revocation stops future access but does not delete copies the external app may already hold.
3. Legal Basis for Processing
| Processing purpose | LGPD basis (Art. 7/11) | GDPR basis (Art. 6) |
|---|---|---|
| Providing the platform and performing your contract | Contract execution (Art. 7, V) | Contract (Art. 6(1)(b)) |
| Authentication, security, and fraud prevention | Legitimate interest / legal obligation (Art. 7, II/IX) | Legitimate interests (Art. 6(1)(f)) |
| Generating cryptographic signature records | Legal obligation / contract (Art. 7, II/V) | Legal obligation / Contract (Art. 6(1)(b/c)) |
| Sending transactional e-mails (OTP, notifications) | Contract execution (Art. 7, V) | Contract (Art. 6(1)(b)) |
| AI-powered document analysis | Legitimate interest (Art. 7, IX) | Legitimate interests (Art. 6(1)(f)) |
| Google Drive file import (optional, user-initiated) | Consent (Art. 7, I) | Consent (Art. 6(1)(a)) |
| Processing payments via Stripe | Contract execution (Art. 7, V) | Contract (Art. 6(1)(b)) |
| Retaining audit logs for legal evidence | Legal obligation (Art. 7, II) | Legal obligation (Art. 6(1)(c)) |
| Website and web application usage analytics (optional, pseudonymous) | Consent (Art. 7, I) | Consent (Art. 6(1)(a)) |
| Mobile app usage analytics (optional, Firebase, linked to account ID) | Consent (Art. 7, I) | Consent (Art. 6(1)(a)) |
| Marketing communications (optional) | Consent (Art. 7, I) | Consent (Art. 6(1)(a)) |
| Sending WhatsApp messages (signature invitations, OTPs, document delivery) via WhatsApp channel | Contract execution (Art. 7, V) | Contract (Art. 6(1)(b)) |
| WhatsApp identity collection (email and name via WhatsApp Flows) | Contract execution (Art. 7, V) | Contract (Art. 6(1)(b)) |
| Identity verification and fraud prevention (may involve sensitive biometric data) | The applicable basis and any required condition for sensitive data depend on the request and verification flow; the requester must have authority and a lawful basis. See the notice presented for the check or contact our DPO. | The applicable basis depends on the context and the verification flow; see the notice presented for the check or contact our DPO. |
| Signup campaign attribution (limited UTM parameters) | The applicable basis depends on the context and applicable cookie requirements; see Sections 4 and 8. | The applicable basis depends on the context and applicable cookie requirements; see Sections 4 and 8. |
| Providing user-authorized MCP connections and access records | Providing the feature and protecting the service, as applicable to the processing; see Sections 4 and 5. | Providing the feature and protecting the service, as applicable to the processing; see Sections 4 and 5. |
4. How We Use Your Personal Data
- Creating and managing your account and organisation memberships.
- Processing electronic signatures and generating cryptographically sealed PDF documents.
- Sending signature-request e-mails, one-time codes, and signed-document copies to signers.
- Running AI analysis on your documents (summarisation, categorisation, clause extraction, and Q&A).
- Importing a PDF you select from Google Drive (web only, on your explicit request) and storing it as a contract document.
- When requested by you, sending extracted text from an imported document to Groq solely to provide DottSign's AI functionality.
- Sending WhatsApp signature invitations, identity-collection prompts, OTP verification codes, and signed PDF documents to signers when the WhatsApp signing channel is used (PRO and ENTERPRISE plans).
- Processing subscription payments and managing plan entitlements.
- Maintaining audit logs to provide legal evidence of signing events.
- Sending in-app notifications and, if opted in, e-mail notifications about contract events.
- Enforcing usage limits per subscription plan.
- Improving the platform through aggregated reports derived from optional usage analytics with pseudonymous identifiers.
- Understanding which web and mobile features are used and where actions succeed or fail, using consent-based events that may be linked to your internal account ID. Refusing or withdrawing optional analytics does not prevent you from using the platform.
- Running identity-verification checks requested for an account or contract, and retaining limited results and linkage metadata to operate the check and document its outcome.
- Attributing a signup to the first and most recent campaign indicated by UTM parameters, to understand which campaigns lead to registrations.
- Providing user-authorized connections to external AI apps through MCP and recording the permissions and security events needed to operate and manage those connections.
- Complying with applicable laws, court orders, and regulatory obligations.
5. Sharing and International Transfer of Data
5.1 Sub-processors and Third-Party Services
- AWS (Amazon Web Services): encrypted document storage and e-mail delivery. AWS infrastructure may be located in Brazil or the USA depending on configuration.
- Stripe, Inc. (USA): payment processing and subscription management.
- Google LLC (USA): optional OAuth-based authentication; on the web platform, optional Google Drive file import (read-only, user-initiated, access token never stored on our servers); Google Tag Manager / Google Analytics for consent-based website and web-product analytics; and Firebase Analytics for consent-based mobile usage events. Product events may be linked to your internal account ID. See Google’s Privacy Policy.
- Groq, Inc. (USA): third-party AI inference provider used to provide DottSign's contract analysis features. Extracted document text may be transmitted to Groq when AI functionality is requested by the user. DottSign does not authorize Groq to use customer data to create, train, fine-tune, or improve generalized AI or machine-learning models.
- Salesforce (optional integration): if you enable the Salesforce integration, your OAuth tokens and selected contract metadata are shared with Salesforce's servers.
- Meta Platforms, Inc. (USA) — WhatsApp Cloud API (PRO and ENTERPRISE plans): When the WhatsApp signing channel is used, signer phone numbers, contract titles, signer names, and email addresses are transmitted to Meta via the WhatsApp Cloud API to deliver signature invitation templates, interactive WhatsApp Flows (identity collection), OTP codes, and signed PDF documents. Meta processes this data as a data processor under our WhatsApp Business terms. Meta's data policy applies: business.whatsapp.com/privacy.
- Didit — identity-verification provider: When an identity check is requested, the verification session may send Didit identity-document images and extracted fields, a selfie or face image, and liveness or face-match signals, as applicable to the configured checks. Didit returns a decision and limited verification metadata to DottSign. Didit's own Verification Privacy Notice describes its processing of verification data. The provider's processing locations and retention settings depend on its configuration and the service arrangement. Contact privacy@dottsign.com for information about the arrangement applicable to a verification.
- External AI apps connected through MCP: When you connect an AI app and use its DottSign tools, the requested DottSign data is made available to that app and its provider. The app is selected and authorized by you, and its own privacy terms govern its subsequent handling. These app providers are not listed as DottSign subprocessors merely because you connect them.
5.2 International Data Transfers
- We are a Brazilian company (LGPD Art. 33). Transfers of personal data to third countries, including the USA for Stripe, Groq, Google, AWS, and Meta, are made using applicable legal safeguards and transfer mechanisms required by the LGPD and, where applicable, the GDPR. A Didit verification may also involve processing outside your country. The transfer mechanism and safeguards depend on the provider configuration and current service arrangement; contact privacy@dottsign.com for information about the transfer applicable to a verification.
- Where transfers rely on the receiving party's adequacy decision, certification, contractual safeguards, or another legally recognized mechanism, we maintain the applicable documentation in our records.
5.3 Disclosure to Authorities
- We may disclose personal data to courts, law enforcement, or regulatory authorities (including the ANPD) when required by applicable law or valid legal process.
- We will notify affected users of such disclosures where legally permitted.
5.4 Google API Limited Use Disclosure
- DottSign's use of information received from Google Workspace APIs complies with the Google API Services User Data Policy, including the Limited Use requirements.
- Google Account information obtained through Google Sign-In, such as name, email address, profile picture, and Google account identifiers, is used solely to create and authenticate your DottSign account and provide the requested sign-in functionality. We do not use this information for advertising, sell it, or transfer it to third parties for purposes unrelated to providing the DottSign service.
- Google Drive data obtained through the optional drive.file integration is used solely to allow you to select and import a PDF into DottSign. Access occurs only after your explicit request and only for the file you select through Google's own Picker.
- When you use DottSign AI features on a document imported from Google Drive, the extracted text from that document may be transferred to Groq, Inc. solely to provide the AI functionality requested by you. This transfer is necessary to provide a user-facing DottSign feature and is not performed for an unrelated purpose.
- Neither DottSign nor its third-party AI provider, Groq, uses Google Workspace or Google Drive user data, including raw, aggregated, anonymized, or derived data, to create, train, fine-tune, or improve generalized artificial intelligence or machine-learning models.
- Google Workspace or Google Drive user data is not used for advertising, creditworthiness determination, lending purposes, or sale to data brokers or other third parties.
- The web and mobile product analytics events described in Section 2.8 are collected independently of Google Sign-In and Google Drive. They describe use of DottSign features and do not include Google Sign-In profile data or Google Drive file content.
6. Data Retention
| Data category | Retention period | Justification |
|---|---|---|
| Account profile data | Anonymised in place when you delete your account; see the deleted-account identity record below | Service delivery; LGPD legitimate interest |
| Contract documents and signature records | Retained after account deletion; deleted on request except where an audit trail must be kept for at least 5 years | Legal evidence obligation |
| Deleted-account identity record (email, name, phone, sign-in identifiers) | Kept encrypted and separated for 5 years after account deletion, then permanently erased | Verifying a former user's identity if they later contact us about a contract they signed, and defending signed-contract audit trails (MP 2.200-2/2001, Lei 9.492/1997) |
| Audit logs | 5 years from event date | Legal and regulatory compliance |
| Billing records | 5 years from transaction | Brazilian tax and accounting requirements |
| AI job results | Deleted with associated contract | Derived data; no independent retention needed |
| Session and refresh tokens | Short-lived; revoked on logout or expiry | Authentication security |
| Password-reset tokens | Short-lived from generation | Security |
| One-time signing codes | Short-lived from generation | Security |
| WhatsApp signing sessions (temporary state) | 30 minutes (automatic expiry) | Security — no longer needed after session completes or times out |
| WhatsApp message records (phone, delivery status, external message ID) | Retained with the signature spot; deleted with contract data | Audit trail for signing event |
| Identity-verification and linkage records retained by DottSign | Limited result and session metadata is retained while needed to provide or reuse verification, support the related contract and audit trail, and meet legal obligations. No fixed automatic purge period is currently stated for these records. You may ask us about a specific record or request deletion; legal and contract-record obligations may limit deletion. | Verification service, fraud prevention, contract evidence, and legal obligations |
| MCP connection and authorization records | Connection details and hashed-token records are retained while a connection is active and may be retained after revocation as needed for security and audit purposes. Revocation invalidates future access. | Operate user-authorized access and protect the platform |
| Signup campaign attribution record | The browser cookie expires after 90 days. If the data is received at signup, first- and last-touch UTM values are stored with the account; no separate automatic expiry is currently configured for that database record. | Measure campaign-driven registrations |
7. Security Measures
We implement the following technical and organisational security controls (LGPD Art. 46; GDPR Art. 32):
- Encryption at rest for all documents stored in cloud storage; encryption keys are managed separately.
- Secure hashing for passwords and tokens.
- Encryption in transit for all API and web traffic.
- Cryptographic signatures and timestamp verification for legally verifiable signing records.
- Role-based access controls (administrator, manager, signer, viewer).
- Two-factor authentication (2FA) available for all accounts.
- Biometric app-lock on mobile (on-device only; no biometric data transmitted).
- Short-lived session tokens with server-side rotation.
- Comprehensive audit logging of all sensitive actions.
- Secure token storage on mobile devices using platform-provided secure storage.
- WhatsApp signing sessions: identity verified via email OTP before any signature is applied; sessions expire automatically after 30 minutes of inactivity and are deleted from our database on expiry. No signing credentials are stored on WhatsApp's or Meta's servers.
8. Cookies and Local Storage
- Product web application — strictly necessary cookies: We set one secure, server-side cookie containing the session token. This cookie is required to maintain your authenticated session and cannot be disabled without preventing login.
- Product web application — optional usage analytics: With your consent, Google Analytics may use analytics cookies and browser/session identifiers to measure feature usage and outcomes. Our Google Tag Manager container loads with consent signals initially denied; DottSign product events are sent only when analytics consent is granted. Private page URLs, document content, and contact details are not included in these product events. We disable advertising personalization signals in the product, and the authenticated product does not load the Meta Pixel. You can allow or decline analytics in the consent prompt and change your choice through “Analytics preferences” in the app.
- Marketing website (our public site) — cookie consent: On your first visit, a cookie banner lets you Accept all, Reject non-essential, or Manage preferences by category (Analytics, Marketing). Strictly necessary cookies are always active. Google Tag Manager loads with consent signals initially denied; optional DottSign analytics events and analytics cookies require analytics consent, and the Meta Pixel loads only after marketing consent; the separate signup attribution cookie described below is currently set when campaign parameters are present and is not controlled by those preference toggles. You can change your tag preferences at any time via the “Cookie Preferences” link in the site footer.
- Marketing website and web app — signup attribution cookie: When a page URL contains UTM campaign parameters, we store the first and most recent values for source, medium, campaign, term, content, and our campaign concept identifier in a first-party
ds_utmcookie on the DottSign domain for up to 90 days. We use these limited values to attribute a later signup to a campaign. We do not capture click IDs in this cookie or use it for ad retargeting. At signup, the values may be stored with your account for campaign measurement; that database record currently has no separate automatic expiry. This attribution cookie is currently set when UTM parameters are present and is not controlled by the Analytics or Marketing preference toggles. You may block or delete it in your browser settings. - Marketing website — analytics cookies (opt-in): Google Tag Manager manages our analytics tags with analytics consent initially denied. With your consent, Google Analytics uses analytics cookies to understand site traffic and interactions, including help and pricing page views, and improve the website.
- Marketing website — marketing cookies and conversions (opt-in): With your consent, we load the Meta (Facebook) Pixel to measure advertising performance. We also store the Pixel's browser and click identifiers and your consent choice with your account at signup. If you register, start a paid trial, or make your first paid purchase, we may send Meta a server-side conversion event with your email address hashed, those identifiers when available, and the purchase amount and currency. The authenticated product does not load the Meta Pixel. You can withdraw marketing consent through Cookie Preferences. If you are signed in, we also update your account's conversion preference; contact privacy@dottsign.com if you need to withdraw account-level consent while signed out.
- Consent choices and withdrawal: The website and web app share the
dottsign_consentpreference cookie across DottSign subdomains for up to 180 days. Analytics and marketing are separate choices. Refusing analytics stops future DottSign product events; for an authenticated account, withdrawal also clears the temporary server-side analytics context so pending events using that context are not sent. It does not automatically erase data already sent; contact privacy@dottsign.com to request deletion. Temporary server analytics context expires after 24 hours. Provider-held analytics data is subject to the applicable Google Analytics / Firebase retention settings; contact us for information about the settings applicable to your data. - Mobile application — optional usage analytics: Collection is disabled until you opt in and can be changed in Profile → Usage analytics. This choice is stored locally and is separate from web cookie preferences. Advertising consent remains disabled.
- Mobile application — secure storage: Access tokens and session tokens are stored in the device's secure storage provided by the operating system.
- Mobile application — local storage: Offline contract metadata cache and locale preference are stored in local device storage.
9. Your Rights
Under LGPD (Art. 18) and GDPR (Arts. 15–22), you have the following rights. To exercise any of them, e-mail privacy@dottsign.com with your account e-mail address. We will respond within the applicable legal deadline.
Rights applicable under LGPD (all users) and GDPR (EU/EEA users)
- Right of Access (Art. 18, I / GDPR Art. 15): obtain confirmation whether we process your data and receive a copy.
- Right to Rectification (Art. 18, III / GDPR Art. 16): correct inaccurate or incomplete data.
- Right to Deletion/Erasure (Art. 18, VI / GDPR Art. 17): request deletion of your data, subject to legal retention obligations.
- Right to Data Portability (Art. 18, V / GDPR Art. 20): receive your personal data in a structured, commonly used, machine-readable format.
- Right to Information about Sharing (Art. 18, VII): know which entities we have shared your data with.
- Right to Object / Opt-out (Art. 18, II / GDPR Art. 21): object to processing based on legitimate interest; opt out of marketing communications at any time.
- Right to Withdraw Consent (Art. 8, §5 / GDPR Art. 7(3)): withdraw consent for consent-based processing without affecting the lawfulness of prior processing.
- Right to Review Automated Decisions (Art. 20 / GDPR Art. 22): request human review of decisions taken solely by automated means that significantly affect you.
- Right to Petition the ANPD (Art. 18, VIII): lodge a complaint with Brazil's Autoridade Nacional de Proteção de Dados (www.gov.br/anpd).
- GDPR only — Right to Restriction of Processing (Art. 18 GDPR): request that we restrict processing in certain circumstances.
- GDPR only — Lodge a complaint with a supervisory authority: EU/EEA residents may lodge a complaint with their local data protection authority.
10. Children's Privacy
DottSign is not directed at children under 18 years of age. We do not knowingly collect personal data from minors. If we learn we have collected data from a minor without verified parental consent, we will delete it promptly. Contact privacy@dottsign.com if you believe a minor's data has been collected.
11. Data Breach Notification
In the event of a personal data breach, we will assess the incident and make any notifications to the ANPD, other competent authorities, and affected data subjects that are required by applicable law, within the applicable legal deadlines. Notifications will include the information required by applicable law, including, where applicable, the nature of the breach, categories of data affected, likely consequences, and remediation measures taken.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you by e-mail and/or prominent in-app notice at least 15 days before material changes take effect. The updated policy will display a new effective date. Continued use of the platform after the effective date constitutes acknowledgment of the updated policy. For material changes affecting consent-based processing, we will request fresh consent where required.
13. Contact and Complaints
Data Protection Officer (Encarregado): dpo@dottsign.com Privacy enquiries: privacy@dottsign.com Legal notices: legal@dottsign.com ANPD (Autoridade Nacional de Proteção de Dados): www.gov.br/anpd EU/EEA supervisory authorities: edpb.europa.eu/about-edpb/board/members