We are a global company based in Middletown, Delaware, USA.
The following Privacy Notice outlines the procedures employed by Centilio, Inc. and its associated branches (referred to in various contexts as "Centilio", "we", "our", or "us") concerning the gathering, application, and release of your personal data. The data may be gathered through various means: use of our website (www.centilio.com), utilization of any of our products or services, interaction with the Centilio software-as-a-service product ("SaaS"), usage of the Centilio mobile application ("App"), account creation, interactions with us, opting to receive SMS messages, or interaction with any other websites, pages, or content we own or provide (collectively referred to as "Services"). If you do not agree with this Privacy Notice or fail to adhere to the outlined provisions, we recommend refraining from using our Services. By accepting this Privacy Notice and utilizing our Services, you consent to our data gathering, storage, usage, and dissemination practices as outlined in both this Privacy Notice and our Cookie Notice, which can be found at https://www.centilio.com/cookie-notice/. The use of our website and app is regulated by Centilio’s Terms of Service, accessible at https://www.centilio.com/terms-of-use/.
We might process your personal data in collaboration with third-party entities. For instance, this may occur when you log into our Services via a third-party site or interact with a link from a third party. In these cases, the third-party's terms and privacy notice govern the processing of your personal information. We advise you to review these terms and notices before interacting with third-party links. Centilio does not have any influence over the privacy practices of sites or apps that we do not own.
We are not responsible for the privacy practices of any websites or services linked to our Website, nor for their content. Please note that our Privacy Notice is not applicable to third-party websites or services. Your actions on any third-party website or service, even those with links on our Website, fall under their respective rules and policies. Additionally, we are not liable for third parties that you authorize to access your personal data. If you permit a third-party site or service to access your data, you do so at your own discretion.
We collect “Non-Personal Information” and “Personal Information,” and the information we collect from you depends on how you use the Services. “Non-Personal Information” includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit, and preferences that are generated based on the data you submit and a number of clicks. “Personal Information” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, and email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. The following provides examples of the type of information that we collect from you and how we use that information.
|Context||Types of data||Primary purpose for collection and use of data|
|Client information||We collect the name, username, and contact information, of our clients and their employees with whom we may interact.||We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing|
|Client user account information||We collect personal information from our clients when they create an account to access and use the Services. or request certain free Services from our Website. This information could include business contact information such as name, email address, IP address, geolocation, title, company information, industry, and password for our Services.||We have a legitimate interest in providing account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to fulfill our contract to provide you with Services.|
|14-day free trial and/or free e-sign account||We collect personal information from our clients when they request a 14-day free trial or free e-sign account from our Website. This Personal Information includes name, IP address, geolocation, and business contact information such as email address, title, and password for your Centilio account. Clients may also provide a credit card number or other billing details.||We have a legitimate interest in providing account-related functionalities to our users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, we use this information to facilitate ease of account creation if a user chooses to purchase the service during or immediately following a free trial period.|
|Contact information of vendors||Users of our Service may ask their vendors or service providers to submit company and security-related information on our platform (e.g., to complete a security questionnaire). When a user invites a vendor we collect the name and email address of the vendor.||We have a legitimate interest in contacting vendors on behalf of our clients in order to invite them to communicate with companies through our platform. Among other things, the communication allows our clients to efficiently solicit, and receive, security questionnaires, and allows vendors to efficiently solicit, and transmit security questionnaires. Additionally, we use this information to fulfill our contract to provide Services which may include soliciting, receiving, transmitting, and hosting responses to security questions.|
|Account information — vendors||We collect personal information from vendors when they create an account to access and use the Services or request certain free Services from our Website.||We have a legitimate interest in providing account-related functionalities to our vendor users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, in some cases, we use this information to fulfill our contract to provide vendor-users with Services.|
|Cookies and first-party tracking||We use pixels, beacons, cookies, and clear GIFs. "Cookies" are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. See our Cookie Notice for further information.||We have a legitimate interest in providing account-related functionalities to our vendor users, monitoring account log-ins, and detecting potential fraudulent logins or account misuse. Additionally, in some cases, we use this information to fulfill our contract to provide vendor-users with Services.|
|Demographic information||We use IP information to 1). Ensure the legality of our documents (under eSignature law); 2). Understand how user behavior varies in different locations in order to improve our software; 3.) Depending on location, provide better support and success service.||We have a legitimate interest in ensuring that our product/service is legal and providing tailored services based on the location (Country) – such as appropriate 1) support, 2) contract content, and 3) templates. IP information will not be used for behavioral purposes absent explicit consent.|
|Email interconnectivity||If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases. If you choose to connect your Gmail account to Centilio, we collect personal data such as name, IP address and Gmail account address to enable the functionality of displaying the Gmail account address to your chosen recipients. Centilio's use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.||We have a legitimate interest in understanding how you interact with our communications to you. Such data capture will only be deployed following receipt of explicit consent. Explicit user consent is captured when a user chooses to connect their Gmail account; Centilio has a legitimate interest in improving the functionality of our platform.|
|Employment||When you apply for a job posting or become an employee or contractor, we collect information necessary to process your application or to retain you as an employee or contractor. This may include, among other things, your Social Security Number, diversity or demographic information, including race or ethnicity, gender or gender identity, and veteran or disability status. Providing this information is required for employment.||We use information about current employees to perform our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We also have a legitimate interest in using your information to have efficient staffing and workforce operations and provide the Website, the Services, and App to our clients.|
|Feedback/Support||We collect Personal Information from you contained in any inquiry you submit to us regarding our Website or Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support requests, or to report an issue. When you communicate with us over the phone or over a video-call platform, your calls may be recorded and sent to you as a support measure. These calls may also be analyzed for training, quality control, and for sales and marketing purposes by Centilio. During such calls we will notify you of the recording via either voice prompt or script. We may collect sensory information such as audio and visual image.||We have a legitimate interest in receiving, and acting upon, your feedback, issues, or inquiries.|
|Mailing list||When you sign up for one of our mailing lists, we collect your email address along with your first and last name.||We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.|
|Marketing data||When you subscribe to one of our mailing list(s), we collect your email address along with your first and last name.||We share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.|
|Mobile device data||We collect information from your mobile device when visiting our Website. Such information may include operating system type and/or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier and/or other device identifier, mobile phone carrier identification, and device software platform and firmware information.||We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.|
|Order placement||Subsequent to Service enrollment (where we collect name, email and phone number, job role, company name and size), to place an order, we collect billing address, and credit or debit card details.||We use your information to perform our contract to provide you with products or services.|
|Social Media Connectors||Our Website uses social media connectors. They are social media buttons, such as LinkedIn, Facebook, Twitter, Instagram and YouTube, you see on our Website that allow you to connect and learn more about us and interact with us, our users and marketing partners.||We may engage in behavior-based advertising, capturing website and mobile application analytics and engaging third parties to assist with providing services that may be of interest to you.|
|Transactional Data/Event Data||Names and email addresses of parties to a transaction, subject line, history of actions individuals take related to a transaction (i.e. sign and forward features) and personal information about those individuals or their devices, such as name, IP address, email address and other authentication methods.||We use this information to fulfill our contractual duties to our Customers. We also have a legitimate interest in creating and maintaining an audit trail proving the authenticity and legality of signatures and documents created by Centilio.|
|Usage Data||Such as referring and exit pages and URLs, domain names, landing pages and content viewed and the order of those pages, the amount of time spent on particular pages, the frequency of your use of our Services and other related information.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Website interactions||We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.||We have a legitimate interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.|
|Web logs||We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the Internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.||We have a legitimate interest in monitoring our networks and the visitors to our Website and App as well as the access and use of the Services to enhance the Services. Web logs also help us understand which of our services is the most popular.|
In addition to the purposes and uses described above, we use information in the following ways:
Although the sections above describe our primary purpose in collecting your information, in many situations, we have more than one purpose. For example, if you sign up for Services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your Services. As a result, our collection and processing of your information are based on different contexts upon your consent, our need to perform a contract, our obligations under the law, and/or our legitimate interest in conducting our business.
In general, we use non-personal information to help us improve the Services and customize the user experience. We also aggregate non-personal information in order to track trends and analyze use patterns on the Services. This Privacy Notice does not limit in any way our use or disclosure of non-personal information, and we reserve the right to use and disclose such non-personal information to our partners, advertisers, and other third parties at our discretion.
In addition to the specific situations discussed elsewhere in this policy, we may share personal information in the following situations:
Except as otherwise stated in this Privacy Notice, we do not sell, trade, rent, or otherwise share for marketing purposes your personal information with third parties without your consent.
The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. We keep your personal information for no longer than necessary for the purposes for which it was collected and/or processed. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it. See the Section “Your choices” about storage of your personal information.
We implement security measures designed to protect your personal information from unauthorized access. We apply these tools based on the sensitivity of the personal information we collect, use, and store, and the current state of technology. We protect your personal information through technical and organizational security measures to minimize risks associated with data loss, misuse, unauthorized access, and unauthorized disclosure and alteration. We periodically review our information collection, storage, and processing practices, including technical and organizational measures, to guard against unauthorized access to systems. Any account you have on our Website, SaaS, or App is protected by your account password, and we urge you to take steps to keep your personal information safe by not disclosing your password and by logging out of your account after each use.
Because the internet is not a completely secure environment, Centilio cannot warrant the security of any information you transmit to Centilio or guarantee that information on the Website may not be accessed, disclosed, altered, and/or destroyed by a breach of any of our physical, technical, and/or managerial safeguards. In addition, while we take reasonable measures to ensure that service providers keep your information confidential and secure, such service providers' practices are ultimately beyond our control.
We are not responsible for the functionality, privacy, and/or security measures of any other organization. By using our Website, you acknowledge that you understand and agree to assume these risks. You may ask for a list of technical and organizational measures taken to protect your personal data by emailing us at firstname.lastname@example.org.
You may take the below actions to change or limit the collection or use of your Personal Information:
Our company operates globally and has a global infrastructure. We utilize cloud computing, which means your personal data may be transferred to a country with data protection laws not as strong as where you reside. We will transfer your Personal Data to countries deemed having adequate levels of data protection as determined by the European Commission.
If we share your personal information with entities located in the United States or other non-EEA jurisdictions which, according to the European Commission and the Court of Justice of the European Union through its Schrems II decision, do not offer an adequate level of protection to personal information, the GDPR authorizes other solutions to address lawful cross-border transfers. Centilio may rely on data processing agreements (DPAs) with attached standard contractual clauses (SCCs) approved by the European Commission or other appropriate solutions to address cross-border transfers as required or permitted by Articles 46 and 49 of the GDPR. Where required by such laws, you may request a copy of the suitable mechanisms we have in place by contacting us.
Centilio does not knowingly collect personal data from children under the age of thirteen (13). If we learn that we have collected Personal Information from a child under age thirteen (13), we will delete such information as quickly as possible. If you believe that a child under the age of thirteen (13) may have provided us Personal Information, please contact us at email@example.com. By using the Services, you represent that you are at least eighteen (18) years old and understand that you must be at least eighteen (18) years old in order to create an account and/or purchase goods and/or services through the Website.
If you are visually impaired, you may access this notice through your browser’s audio reader.
In general, changes will be made to this Privacy Notice to address new or modified laws and/or new or modified business procedures. However, we may update this Privacy Notice at any time, with or without advance notice, so please review it periodically. We may provide you additional forms of notice of modifications and/or updates as appropriate under the circumstances. Your continued use of the Website after any modification to this Privacy Notice will constitute your acceptance of such modifications and/or updates. You can determine when this Privacy Notice was last revised by referring to the date it was last “Updated” above.
For questions or complaints regarding our use of your personal information or Privacy Notice or to forward deletion requests, please contact us at: firstname.lastname@example.org.
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