Purpose

This document sets out the guidelines under which Doceo Software, S.L. collects, uses, stores and processes personal data of its customers and other individuals (collectively referred to as “Users”) who access or use our websites, mobile applications, contact forms and other related services (collectively referred to as the “Services”). By using our Services, you agree to the collection and use of your personal data as described in this Privacy Notice.

In some cases, we may process your personal data in collaboration with external third parties. In such situations, the terms and conditions of the agreement with that external organization will govern how your personal data is handled. If you believe an external organization has authorized us to process your personal data on their behalf, we suggest you contact them to clarify how your information is handled. Please note that this Privacy Notice does not apply to third-party websites or applications linked from our Services. Before clicking on any link, we urge you to review the terms and conditions and privacy policies of those third-party websites and applications.

It is important that you read this Privacy Notice carefully to understand how we collect, use, store and process your personal data, as well as to be informed about your rights regarding data protection.

Contact details for the purposes of this Policy: Doceo Software, S.L.

• NIF: B17995218
• Address: C/Francesc Artau, 14 Ático C 17005 Girona (Girona)
• Contact email: dpo@doceosoftware.com
• Email for exercising Data Protection rights: dpo@doceosoftware.com
• Phone: (+34) 972 98 22 87

If you have questions regarding this policy, you can contact DOCEO SOFTWARE through the contact methods mentioned above.

Personal Data Protection Officer

The Personal Data Protection Officer is responsible for protecting the fundamental right to personal data protection at Doceo Software and is responsible for ensuring compliance with data protection regulations. You can contact the Personal Data Protection Officer at the following address: dpo@doceosoftware.com

1. Privacy Policy

At Doceo Software, we aim to provide you with a safe and reliable browsing and service experience. In line with this objective, we have implemented this privacy policy in compliance with the security measures established by the European Regulation 679/2016 of April 27 (GDPR) and the Spanish Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD).

2. Collection of Personal Data

You, as a User, have the option to visit our websites, install our applications or provide us with personal data. However, if you do not provide certain personal data, it may not be possible to access some parts of our Services. For example, if you do not have an electronic signature, you will not be able to sign electronic documents in our service.

We collect your personal data in the following situations:

• Name and surname.
• Email address.
• Browsing information (cookies, IP, usage data, pages visited).
• Technical information about the device (operating system, browser).
• Register or log into your account (portal.doceosoftware.com).
• Create or modify your user profile (portal.doceosoftware.com).
• Contact our customer service.

3. Personal Data We Collect Automatically

We may automatically collect your personal data and your devices’ data when you use our Services, even when you visit our websites or applications without logging in. The types of data automatically collected include:

• Cookies and similar technologies for SEO analysis and user experience improvement.
• Website usage and navigation data for statistics and analysis.
• Combined information from external sources when legally authorized.

4. Use of Personal Data

The legal basis for processing your personal data depends on the type of data and the context in which it is collected. Normally, processing is based on your consent, the performance of a contract or legitimate interests.

We use your personal data to provide, operate, maintain and improve our Services. In addition, we use your personal data for the following purposes:

• Provide and bill for requested products and services.
• Process your transactions and send related notifications.
• Create and manage your account and relationship with us.
• Facilitate communication and collaboration.
• Improve the user experience.
• Provide technical support and resolve issues.
• Send you updates and newsletters.
• Respond to your comments, questions and support requests.
• Evaluate and improve the quality of our services.
• Comply with our legal obligations and prevent fraudulent, illegal or unauthorized activities.
• Comply with legal retention periods.
• Protect the rights, privacy, security or property of Users and Doceo Software.

5. Sharing of Personal Data

At Doceo Software, we understand the importance of protecting your personal data. We do not sell or rent your personal data to third parties for commercial purposes. However, we may share your personal data with third parties in the following situations:

Service providers: We may share personal data with service providers who perform services on our behalf, such as payment processing, web hosting services, data analysis, customer support and other similar functions. These service providers may have access to your personal data only to the extent necessary to perform their functions and are not permitted to share or use your data for any other purpose.

Legal compliance: We may disclose your personal data in response to valid legal requests, such as a court order, subpoena or valid government request.

Business transfers: In the event of a merger, acquisition, sale of assets or corporate restructuring, your personal data may be transferred as part of the business assets.

Publication of photos or videos on the website or social networks: For the publication of photographs or videos of our employees, customers or users on the website or social networks, as well as to collect data to carry out a contest or process any other personal data, we previously obtain the prior, explicit, indisputable and informed consent of the data subject.

6. Users’ Rights

Doceo Software provides Users with the necessary means to exercise their rights of Access, Rectification, Deletion, Objection, Portability and Erasure at any time they deem appropriate.

In general, Users’ rights may include:

• Access to their personal data and the possibility of obtaining a copy.
• Rectification of inaccurate or incomplete personal data.
• Deletion of personal data under certain circumstances.
• Restriction of personal data processing.
• Objection to personal data processing under certain circumstances.
• Portability of their personal data.
• Withdrawal of consent at any time when processing is based on consent.

Users also have the right to lodge a complaint with the competent data protection authority if they consider that their data protection rights have been infringed.

If you wish to exercise any of these rights or have any questions about your privacy rights, you can contact us through the contact details mentioned in this Privacy Notice, attaching a copy of your passport or ID (data subject) and clearly indicating in the subject the right you wish to exercise: access, rectification, deletion, objection, portability or erasure.

7. Other requirements and particularities

The services, access to content and product offerings on this website are exclusively restricted to persons over 18 years of age. Doceo Software will not be responsible for damages caused to the User or third parties that may be harmed by identity theft or any other negative consequences arising from non-compliance with this requirement by the User. For this reason, Doceo Software expressly informs that any person who provides their personal data declares and confirms that they have this minimum age, and contracting Doceo Software’s products and services and the corresponding provision of personal data is prohibited when it involves minors.

Likewise, the User will be solely responsible for the security measures they implement regarding the protection of their personal data. Doceo Software will not be responsible for situations arising as a result of not having implemented the corresponding security measures or due to the lack of diligence observed by the User, nor will it assume responsibility for causes or damages caused by third parties outside Doceo Software, including force majeure or unforeseen circumstances.

8. Security Measures in Data Collection

Doceo Software has a strong commitment to the security and protection of the personal data of its Users, following the standards established by the European Data Protection Regulation. To prevent the loss, misuse, alteration, unauthorized access, and theft of data provided by Users, Doceo Software has implemented appropriate technical and organizational security measures.

Doceo Software undertakes to inform Users of any situation that may endanger the confidentiality and availability of documents and data, taking appropriate measures to resolve the incident as quickly as possible. However, in situations where notification may increase the risk to the data or documentation processed, this obligation will not be enforceable. In cases where the law requires it, mandatory notification protocols will be followed to the competent authority or to the Users affected by the incident.

The security measures implemented by Doceo Software include:

• Secure access: All access to Doceo Software solutions is carried out through secure connections using HTTPS security certificates.
• Password encryption: Access passwords to Doceo Software solutions are stored in encrypted form while active.
• Distributed storage: To ensure the confidentiality, accessibility, and availability of the files in custody, they are stored in distributed and replicated systems within Doceo Software.

9. Social Media

The same general privacy rules apply.

The purpose of using social media is to provide visibility and dissemination of the products developed by Doceo Software.

In principle, the same data protection policy specified in this document applies regarding the collection, processing, and transfer of data.

Doceo Software does not identify with the opinions expressed by others or with the ideology of the profiles with which it has connections on any social network.

Doceo Software reserves the right to remove from its social networks any information posted by others that violates the law, incites such violation, or contains messages that infringe upon the dignity of individuals or institutions, as well as to block or report the profile of the author of such messages.

The social networks managed by DOCEO SOFTWARE, S.L are:

• Facebook: https://www.facebook.com/DoceoSoftware/
• Twitter: https://twitter.com/DoceoSoftware
• LinkedIn: https://www.linkedin.com/in/doceo-software/
• YouTube https://www.youtube.com/@DoceoSoftware
• TikTok https://www.tiktok.com/@doceosoftware

10. Electronic Signatures and Biometric Data

This section applies only if electronic signature services and biometric data capture are used in solutions such as Doceo BioSign, in any of its modalities: F2F (on-site), Mobile (two-factor), Delivery, and Forms (HTML forms and documents):

Specific collection:

• Date and time of the signature.
• Action performed (signed or rejected).
• Operating system and browser used.
• Geolocation data.
• Signature status.
• IP address.

Biometric signature data, including pressure, writing angle, speed, acceleration, letter formation, and stroke direction of the signature.

Use of the data:

• Ensure the authenticity and validity of the signature.
• Security of signed documents.
• Audit trail and legal compliance.

Specific security measures:

• Encrypted storage of documents and signature data.
• Access restricted to authorized personnel only.
• Notification of security incidents following legal protocols.

11. Changes to the Privacy Policy

This privacy policy may be updated from time to time to reflect changes in our services or data processing practices. An updated version will be published on our website, and if the changes are significant, we will notify you directly.

12. Acceptance of the Privacy Policy

By using our Services, you agree to the practices described in this Privacy Notice. If you do not agree with this policy, please do not use our Services or provide personal data.