Data processing agreement
This agreement covers the personal data that a Team puts into Subsigno — its people’s names, work e-mail addresses, job details, saved signatures, photos, logos and banners. For that data the Team is the controller and Subsigno is the processor. It is part of the Terms and is accepted by using Team accounts.
Draft — under legal review, not legal advice. It may change before it takes effect.
Who is who
The Customer is the Team, through whoever is an Owner of it. The processor is Ruben José Dos Santos Marques (RJDSM), the sole trader who operates Subsigno as a brand of Solvetus; the legal notice carries the full identification. For the sign-in data of Owners and members, and for the security log, Subsigno decides the purposes itself and is a controller in its own right, as the Privacy page explains.
What is processed, and for how long
Subject matter: providing Team accounts, hosted images and permanent links, and saved Team signatures. Data subjects: the Customer’s Owners, members and the users of its shared mailboxes. Data: names, work e-mail addresses, job titles, departments, phone numbers, company details, social links, photos, logos, banners and signature content, plus sign-in data. No special categories of data are intended, and the Customer must not put any in. Duration: while the Team exists, and then only as long as the Privacy page says under “How long we keep things”.
Instructions and confidentiality
Subsigno processes the data only to provide the service and on the Customer’s documented instructions — the Owners’ actions on the account pages, and the Terms. It tells the Customer if an instruction looks as if it breaks data-protection law. Everyone who can reach the data is bound to confidentiality.
Security
Subsigno applies measures appropriate to the risk, among them: encryption in transit (HTTPS with HSTS) and of the backups; sign-in without passwords, with a passkey as a second step for Owners; the operator’s area behind Cloudflare Access; random identifiers; keyed one-way hashes for sign-in codes and counters; images re-encoded to remove embedded metadata; rate limits; no logging of requests for hosted images; an encrypted off-site backup that is restored in a test every quarter; and a written procedure for personal-data breaches.
Sub-processors
The Customer agrees to these sub-processors: Cloudflare (hosting, the D1 database, the R2 image storage in the EU jurisdiction, DNS and cache); Microsoft (delivery of sign-in and notice e-mails through Microsoft 365); OVH (encrypted backups, in France). Subsigno stays responsible for them and binds each to data-protection terms. It tells the Owners by e-mail 30 days before it adds or replaces one; an Owner who objects can download the Team’s data and delete the Team before the change takes effect.
Transfers outside the EEA
Cloudflare and Microsoft are US companies. Where data reaches them outside the European Economic Area, the transfer relies on the EU–US Data Privacy Framework or on the European Commission’s standard contractual clauses.
Helping the Customer
The Owners can download the Team’s data (Overview page) and delete the Team themselves (Danger zone page), and each person can download their own data (Profile page) and delete their account (Delete my account page). For anything else — a request from a data subject, an impact assessment, a question from an authority — write to privacy(at)subsigno.com and Subsigno helps within a reasonable time.
Personal-data breaches
If Subsigno becomes aware of a personal-data breach affecting the Team’s data, it tells the Team’s Owners without undue delay, with what it knows: the nature of the breach, the data and people concerned, the likely consequences and what it is doing about it.
Deletion and return
At any time the Owners can download the Team’s data and ask for the Team to be deleted. After the 30-day window the data is erased; the backups and the database’s rollback window expire on the schedule on the Privacy page. Only random ids and a date are kept for good, and they hold no personal data.
Audits
Subsigno gives the Customer the information needed to show that it complies with this agreement, and allows an audit by the Customer or its auditor, on 30 days’ notice, at most once a year, at the Customer’s cost and without access to other customers’ data.
Acceptance and changes
A Team accepts this agreement by using Team accounts, as the Terms say. Subsigno may change it by telling the Owners 30 days ahead.