Privacy Policy

1. Scope

(1) When you (“user” or “you”) register to become a member of Kdan Mobile Software Ltd. (“Kdan” or “we”) and/or use Kdan’s products or relevant services or functions (including but not limited to DottedSign, Inspod, and ADNEX) (collectively, “Services”), you agree that your Personal Data (as defined below) will be collected, processed, and used in accordance with this privacy policy (“Privacy Policy”). (2) Personal Data means any data that may be used to directly or indirectly identify a person, such as the name, user name, password, email address that you provide to us (collectively, “Personal Data”).

2. Data Collected

(1) Contents provided by users: When you register to become a Kdan member, we will ask you to provide certain Personal Data for the registration, including but not limited to your email address, name, and password. When you use a third party account to register as a Kdan member, we will store the user information from the third party account, including but not limited to your names, email address, language preference, and profile photos in our member center. We will only use this account information in accordance with this Privacy Policy. You can use the following third-party services to sign up to be a Kdan member: Google, Facebook, LinkedIn, Twitter, Microsoft, WeChat and Tencent. When you use the Services, we will collect the content that you create, upload or receive from others, including but not limited to the files you upload to Kdan Cloud, notes, documents and signing tasks that you create through use of Kdan products. (2) Information collected through applications, browsers, and devices when using the Services: When you use the Services through applications, browsers, and devices, the information we collect will include but is not limited to the IP address, identity information related to devices, the categories of browsers and devices used, operating system, internet service provider, internet protocol address, and events on devices, including but not limited to crash records, system activities, and other records generated automatically by the servers. Our websites may also use cookies to enhance users’ experience. More information can be found in our Cookies Policy. You may manage the categories of information that we collect, to a certain degree, through methods including changing the settings of browsers and devices. (3) There is certain information that it is necessary you provide us to facilitate the contract for the Services. This includes, personal data that is used to register your account. If you fail to provide certain information when requested, we may not be able to perform our obligations under the contract.

3. Purpose and Use of Data

(1) Provision of Services We will use the data collected to provide Services, including but not limited to: recording detailed information related to the electronic documents and work process for electronic signatures when you use DottedSign to perform signing tasks, as well as contacting you through your contact information when you submit comments or questions to us. We process this information to provide the services in the contract between us. (2) Personalized services We process the data collected to learn how our users use our Services and resources, and to provide personalized services. We process this data for our legitimate interests of improving our Services, and your legitimate interest to receive a tailored service. (3) Send newsletter or marketing information to subscribers If you subscribe to our newsletter, we will send newsletters or marketing information to you via email. It is our legitimate interest to market similar goods and services that we think would be of interest to Users. Users may cancel the subscription to newsletter at any time, and you may find details regarding how to cancel the subscription in the bottom of our emails. (4) Manage special activities on our websites If you participate in activities such as raffles, competitions, surveys, and special offers on our websites, we may use the information provided by you to manage or conduct such activities. We process this information for our legitimate interest to run these activities, and the Users' legitimate interest to access and participate in the activities. (5) Improve our Services We may process information gathered from research and/or analysis. This is our legitimate interest to improve our service experience, and to enhance the safety and stability of our Services. It is also the Users' legitimate interest to receive a secure and improving Service.

4. User Rights

(1) Through the “Contact us” page on our websites (https://www.kdan.com/contact), you may make an inquiry of, review, request a copy of, supplement or correct, demand the cessation of the collection, processing or use of, restrict the use of, and request the deletion of your Personal Data. Where you have the right to data portability under Article 20 of the EU and UK GDPR, you may request that we send the information you have provided to us in a format that can be read by a computer, to another organization designated by you. (2) If you request Kdan to stop, or restrict, collecting, processing, using your Personal Data, or to delete your Personal Data, we may be unable to continue to provide the Services, or unable to provide a complete experience of the Services, pursuant to your request.

5. KDAN AI Services

(1)While using KDAN AI Services, you may provide the input to the KDAN AI Services and receive output from the KDAN AI Services corresponding to the input. Please note that you are fully responsible for the input and the usage of the output(the "Content"), including but not limited to ensuring that the Content does not violate any applicable laws, or ensuring that the Content and the usage of the KDAN AI Services will not infringe upon any third party rights. (2)To ensure the normal operation of KDAN AI functions and improve the quality of KDAN AI Services, Kdan would temporarily store the input data provided by users. We promise not to utilize users' personal data for AI data training or any other commercial purposes. KDAN AI uses the technology provided in part by OpenAI, LLC ("OpenAI") and Azure AI, and strictly adheres to OpenAI and Microsoft's policies. You must not violate any OpenAI and Microsoft policies while using KDAN AI, including but not limited to their content policy, sharing and publication policy, and community guidelines. (3)KDAN AI Services will strive to provide the best possible results; however, the output generated by AI technology may contain inaccuracies, harmful content, or biases. We cannot be held responsible for any content or errors resulting from the usage of KDAN AI Services. (4)Please note that due to the evolving nature of AI technology, the availability, content, pricing, and other aspects of the features provided by KDAN AI services may change in future versions.

6. Safety Measures

(1) We will adopt appropriate protection, storage, and process mechanisms and safety measures to prevent your Personal Data from being stolen, altered, damaged, lost, or leaked. (2) Our websites follow the PCI vulnerability standards to provide a safe environment to our users through our best efforts. (3) To find out more about the safety measures we adopt, kindly refer to our Security Policy (https://www.kdan.com/security).

7. Retention Period

(1) You may alter or delete most of your Personal Data stored in the Kdan account, including but not limited to: the files you upload to Kdan Cloud, the notes and documents you established through Kdan products. (2)Kdan account information: Kdan account information includes your email address, name, and password. This information will be retained until you delete your Kdan account or until your Kdan account expires due to any reason. If you use the same Kdan account to connect to multiple Kdan products, then we will retain your Kdan account information during the term that you continue to use your Kdan account to access or subscribe to any of Kdan products. If your Kdan account belongs to any team subscription plan, Kdan will continue to retain your Kdan account information until your Kdan account is removed from such team subscription plan (please note that the team administrator’s permission is required for you to be removed from a team subscription plan). If you wish to delete or stop using your Kdan account, you may contact our customer service through https://www.kdan.com/contact. Please note, once your Kdan account is deleted, all files stored on Kdan Cloud will be permanently removed. Also, as Kdan products and services are connected to your Kdan account, once you delete your Kdan account, you will no longer be able to use any Kdan products or services through such deleted account. It will also be impossible to restore information stored in the deleted account. (3) Information related to DottedSign signing tasks: If you use DottedSign to conduct signing tasks, the deletion of such signing tasks (including Personal Data therein) must obtain consent from all related persons (if any). Otherwise, we may choose to retain the information related to such signing tasks for protection of the interests of related persons. Kdan is not responsible for the storage of the information related to DottedSign signing tasks. Users must download and retain information related to DottedSign signing tasks upon the completion of such signing tasks. After all persons related to a DottedSign signing task have ceased to use DottedSign, we may choose to delete all information related to such signing tasks. (4) Information stored in Kdan Cloud: If you subscribe to Kdan Services and obtain cloud storage space in accordance with your subscription plan, once your subscription expires, we may choose to delete any files you store in Kdan Cloud after sixty (60) days starting from expiration date. To learn more about our subscription expiration policy, kindly refer to our Terms of Service under the title “Subscription Expiration”. (5) To comply with laws and course of business (including but not limited to regulations and accounting procedures), or to provide services related to Kdan products, we will retain your Personal Data to the extent necessary.

8. Information Sharing and Disclosure

We will not share users’ Personal Data with any third party unless any of the following circumstances is applicable: (1) If we have obtained your prior consent, we may share information with third parties within the scope of your consent. (2) To comply with laws and lawful requests of government agencies, we may share Personal Data with third parties. (3) We may use third-party service providers to help us operate our business and websites, or to manage activities on our behalf, such as sending newsletters or surveys. We may share your information with these third parties for the purposes as stipulated under Article 3. We will instruct these third parties to comply with this Privacy Policy and adopt appropriate confidentiality and safety measures. (4) We may share generic and aggregated statistical information with our business partners, trusted affiliates,and/or advertisers for the purposes as stipulated under Article 3. (5) We may share information that is aggregated or de-identified such that it cannot be reasonably used to identify an individual. (6) We may disclose, sell, trade, and/or rent generic and aggregated statistical information to any third party, as such statistical information is aggregated or de-identified, and is not personal information, which may include but is not limited to application name, install/uninstall date and time, locale (Country), and other statistical information that is aggregated or de-identified so that it cannot be reasonably used to identify an individual. (7) To carry out our applicable Terms of Service (https://www.kdan.com/terms_of_service), including to investigate users’ potential abuse of our services, and to deal with safety and technical issues, we may share Personal Data with third parties. (8) If we are involved in a merger, acquisition, or sale of assets, we will continue to adopt measures to protect the confidentiality of Personal Data, and will notify affected users before transferring any Personal Data to a new entity.

9. Third-party Websites or Services

(1) Our websites, applications, and Services may contain links, services, and advertisements run by third parties. These third-party links, services, and advertisements are not run by Kdan, and this Privacy Policy does not apply to said links, services, and advertisements. Kdan takes no legal responsibility regarding how these third parties collect, process, and use users’ Personal Data. It is the user’s own responsibility to review the terms of service or privacy policy of these third parties before contacting, clicking, or using said links, services, and advertisements. (2) Our websites, applications, and Services may use services such as YouTube API services (including but not limited to that users may upload videos to YouTube through such services). Users must carefully review the relevant terms below before using such services: YouTube API Services Terms of Service: https://developers.google.com/youtube/terms/api-services-terms-of-service YouTube API Services - Developer Policies: https://developers.google.com/youtube/terms/developer-policies Google’s Privacy Policy: https://policies.google.com/privacy?hl=en&gl=ZZ Google API Services User Data Policy: Our use and transfer of information received from Google APIs to any other app adheres to Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes). This may include but not limited to file names, file content, folder structure, and metadata. We use information received from Google APIs solely to provide or improve user-facing features. This includes facilitating file management, storage, and any additional features or functionalities enabled through our integration with the Google Drive API. We transfer such information only as allowed under the Limited Use Requirements and does not transfer or sell this information to third parties or to serve advertising. Microsoft API Services User Data Policy: Our use and transfer of information received from Microsoft APIs to any other app adheres to Microsoft API Services User Data Policy (https://learn.microsoft.com/en-us/legal/microsoft-apis/terms-of-use). This may include but not limited to file names, file content, folder structure, and metadata. We use information received from Microsoft APIs solely to provide or improve user-facing features. This includes facilitating file management, storage, and any additional features or functionalities enabled through our integration with the Microsoft API. We transfer such information only as allowed under the Limited Use Requirements and does not transfer or sell this information to third parties or to serve advertising. (3) We utilise automated processes to provide emails and notifications to Users depending on events that occur when using our Services, as well as determining the User's access level and operating a Chatbot. We employ a third-party to facilitate User payments. This incorporates automated decision making to block high-risk payments.

10. Team Administrator’s Liabilities

(1) Team Administrators of Kdan’s team subscription plan(including the payer for the fees of such team subscription plan, and the administrator appointed for each team) hereby warrant that its/his/her management and use of the Personal Data contained in the Kdan accounts that belong to such team subscription plan is in compliance with local regulations (including but not limited to the Personal Data Protection Act in Taiwan, the GDPR in EU). (2) Team Administrators hereby agree to indemnify Kdan, from and against any damages (including but not limited to attorney fees, legal expenses, the settlement costs Kdan pays to third parties, and any amount the court awards to third parties) arising out of or in any way connected with any claim made by third parties (including the individual Kdan account users that belong to a team subscription plan) due to its/his/her unlawful acts.

11. Data Transfers

Your Personal Data may be processed on servers located outside of the country where you live. Regardless of where your Personal Data is processed, we apply the same protections described in this Privacy Policy. We also comply with legal requirements relating to cross-border transfers of Personal Data. If your Personal Data is transferred to a third country or organisation, we will ensure there is either an adequacy decision in place, or in the absence of an adequacy decision we will implement appropriate standard contractual clauses to ensure the security of your data.

12. Changes to Privacy Policy

(1) Due to rapid technological developments, Kdan may update this Privacy Policy from time to time, to reflect the legal, technical, and commercial changes in accordance with relevant regulations. You agree that it is your responsibility to review the latest Privacy Policy regularly, and your continued use of Kdan products or Services will be deemed that you agree to the updated Privacy Policy. Should you disagree with any updated Privacy Policy, please discontinue your use of Kdan products or Services. (2) Whenever we update this Privacy Policy, we will publish the updated Privacy Policy on Kdan’s websites, and will notify you soon through the applications or emails.

13. Right to lodge a complaint

You have the right to lodge a complaint with the appropriate supervisory authority in your country. If you do have any concerns about how we have handled your data we would kindly ask that you contact us in the first instance, before you speak to the supervisory authority, so that we have an opportunity to put things right.

14. Contacting Us

If you have any questions about this Privacy Policy, data transfers, or Kdan products, please contact us at: Kdan Mobile Software Ltd..

Kdan Mobile Software Ltd fully understands our obligations concerning your personal data under the EU and UK GDPR.

This Privacy Policy applies to all Personal Data we collect.

This Privacy Policy was last updated on the 6th day of May 2024.