This agreement applies between the company (controller) and INI Sign (processor) and sets out how we process signers' personal data on the company's instructions.
01Roles
The company is the data controller: it decides whom it sends a document to, which document, and for what purpose.
INI Sign is the processor and acts only on the company's documented instructions.
If an instruction appears to us to conflict with the law, we will tell you without delay and suspend it.
02Subject of processing
Categories of data: the signer's identifying and contact details, technical data (IP address, device, browser) and the signing evidence.
Data subjects: the company's employees, counterparties and other people to whom the company sends a document.
Duration: the term of the contract, and for the evidence record, 10 years from signing.
03Security measures
Encryption in transit (TLS 1.3) and at rest (AES-256); access roles and least privilege; logging of every action.
Evidence is held in an immutable (WORM) archive where altering a record or deleting it early is technically impossible.
Our staff with access to data have signed confidentiality undertakings.
04Sub-processors
We engage sub-processors for sending SMS, delivering email, hosting and seal certification.
A written agreement with each of them imposes obligations no lower than those in this document.
We give at least 30 days notice before changing the list of sub-processors. On a reasoned objection the company may terminate the contract without penalty.
05Incidents
Within 48 hours of discovering a security incident we will write to you: what happened, which data it affected and what we did about it.
We help the company communicate with the regulator and with data subjects where the law requires such notice.
We keep an incident log and make it available on request.
06Return and deletion
For 30 days after the contract ends the company can download every document and evidence report.
After that period the document files are deleted from our systems.
The evidence record stays in the immutable archive for 10 years. That retention rests on legitimate interest and cannot be ended early for technical reasons.