Privacy is very important to us. This privacy statement explains the personal data that Final Folio processes, how we process it, and for what purposes. References to Final Folio products in this statement include Final Folio services, websites, apps, software, servers, and devices. All references to Final Folio include our associated cloud services company Cloud Puffs Inc. This statement applies to the interactions Final Folio has with you and the Final Folio products listed below, as well as other Final Folio products that display this statement. It does not apply to Notary services provided by Final Folio, which are subject to specific requirements under state statutes and regulations.
Cookies - Most Final Folio sites use cookies, small text files placed on your device which web servers in the domain that placed the cookie can retrieve later. We use cookies to store your preferences and settings, to assist you in navigating the websites, to enable the use of any third-party financial institution’s payment facilities (currently Wells Fargo bank and Authorize.net – a Visa company), to improve the website’s usability, to analyze the use of the website, in the administration of the website, and to provide information and ads from us (we do not allow third-party cookies).
Final Folio adheres to the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. To learn more, visit the U.S. Department of Commerce’s Privacy Shield website.
If you have a privacy concern, complaint, or question for Final Folio please contact us, our Chief Operating Officer performs the role of Chief Privacy Officer and EU Data Protection Officer. For more information about contacting Final Folio, see the How to Contact Us section of this privacy statement.
Final Folio collects data from you, through our interactions with you and through our products. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with our products. The data we collect depends on the context of your interactions with Final Folio and the choices you make, including your privacy settings and the products and features you use. We may also obtain data about you from third parties.
You have choices when it comes to the technology you use and the data you share. When we ask you to provide personal data, you can decline. Some of our products, such as digital electronic signing services, require some personal data to provide you with the product or service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we may determine in our sole discretion that we will not be able to enter into the contract, including a contract to provide a service; or if this relates to an existing product you’re using, we may determine in our sole discretion that we have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.
All online payments to us are processed through third party portals operated by financial institutions (currently Wells Fargo bank and Authorize.net – a Visa company). They request information needed to facilitate payments. The service partners do not to share information they gather as part of the payment process with us beyond that necessary for us to record the payment and provide the product or service.
We record the email you use with our products or services and a phone number for two-factor authentication. We do not ask for or record your name, address, or other personal information. Because we do not store your personal information, we do not require that you create an account or login with a password. It is possible for identifying information to be transmitted by you to us during a transaction as part of communications protocols and malware detection, we do not use that information for other purposes.
When you choose the advanced security option, we may request photos of your driver’s license or other government issued ID and a “selfie” photograph to be able to verify the identity of those authorized to access your documents. After verifying that the ID is consistent with documents issued by your state or other government entity, we lock the ID in your Portfolio and store it in an encrypted MicroSoft Azure vault. We may also make a backup on optical media which is encrypted and physically protected. We do not record any of the ID information outside the vault, and, except for any encrypted optical disk backup, after verification we delete the ID and photo from all locations outside the locked archive. If you request a copy of a Folio you may be asked to provide a current copy of your driver’s license and photo so that we can verify it matches the archived ID.
When you choose to use our electronic signature services, we may request from you the same documents and photos we utilize to verify that users of our Advanced Security option are authorized to access archived Folios. We may also ask for additional personal information that we, in our discretion, deem necessary or advisable to satisfy the requirements of the United States Electronic Signatures in Global and National Commerce (ESIGN) Act, the Uniform Electronic Transactions Act (UETA), and other domestic and foreign statutes and regulations regarding the use of electronic signatures.
Final Folio uses the data we collect, through interactions such as surveys and email, to provide you with full featured, interactive experiences. In particular, we use data to:
Provide our products and services, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data within and outside Final Folio, when it is required to provide the products or service or carry out the transactions you request.
Improve and develop our products and services.
Personalize our products and services and make recommendations.
Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you with relevant offers and information.
We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research.
In carrying out these purposes, we combine data we collect from different contexts (for example, from your use of two Final Folio products or services) or obtain from third parties to give you a more seamless, consistent, and personalized experience, to make informed business decisions, and for other legitimate purposes. We do not sell or share any information that we might acquire with anyone outside our company and affiliated entities.
Our processing of personal data includes methods of processing that are automated, manual (human), or a combination of both. Our automated methods often are related to and supported by our manual methods. For example, our automated methods include artificial intelligence (AI), which we think of as a set of technologies that enable computers to perceive, learn, reason, and assist in decision-making to solve problems in ways that are similar to what people do. To build, train, and improve the accuracy of our automated methods of processing (including AI), we manually review some of the predictions and inferences produced by the automated methods against the underlying data from which the predictions and inferences were made. For example, we manually review short snippets of a small sampling of voicemail data (we take steps where appropriate to de-identify the sample, that is, to remove personal information from that might identify you) to improve speech services, such as recognition and translation.
We share your personal data with your consent or to complete any transaction or provide any product or service you have requested or authorized. We also share data with Final Folio controlled affiliates and subsidiaries; with vendors working on our behalf; with financial entities providing payment processing; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights and property of Final Folio and its customers.
You can make choices about the collection and use of your data by Final Folio. You can control your personal data that Final Folio has obtained, and exercise your data protection rights, by contacting Final Folio or using various tools we may provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which products you use. For example, you can:
Choose to utilize our Advanced Security services that require us to retain an encrypted copy of your documents, or you can choose to have us delete your documents from our servers after digitally signing the associated portfolio.
Choose whether you wish to receive promotional emails and text messages.
Not all personal data processed by Final Folio can be accessed or controlled via the tools above. If you want to access or control personal data processed by Final Folio that is not available via the tools above or directly through the Final Folio products you use, you can always contact Final Folio at the email address in the How to Contact Us section.
We also provide aggregate metrics about user requests to exercise their data protection rights via the Final Folio Privacy Report.
Our third-party payment service providers use cookies and similar technologies for storing and honoring your preferences and settings, where appropriate for enabling you to sign into a payment portal, combating fraud, analyzing how our products and services perform, and fulfilling other legitimate purposes. Final Folio apps may use cookies and additional device identifiers for similar purposes. We do not use cookies to collect and retain personal information other than as it relates to use of our products or services.
We may also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.
You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.
If you use a Final Folio product with an account provided by an organization you are affiliated with, such as your work or school account, that organization can:
Control and administer your Final Folio product and product account, including controlling privacy-related settings of the product, service, or account.
Access and process your data, including the interaction data, diagnostic data, and the contents of your communications and files associated with your Final Folio product, service, or account.
If you lose access to your work or school account (in event of change of employment, for example), you may lose access to products and services and the content associated with those products and services, including those you acquired on your own behalf.
Many Final Folio products are intended for use by organizations, such as schools and businesses. If your organization provides you with access to Final Folio products, your use of the Final Folio products is subject to your organization's policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When you use social features in or associated with Final Folio products or services, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the Final Folio product or service. Final Folio is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.
When you use a Final Folio product provided by your organization, Final Folio’s processing of your personal data in connection with that product is governed by a contract between Final Folio and your organization. Final Folio processes your personal data to provide the product to your organization and you, and for Final Folio’s legitimate business operations related to providing the product. As mentioned above, if you have questions about Final Folio’s processing of your personal data in connection with providing products to your organization, please contact your organization. If you have questions about Final Folio’s legitimate business operations in connection with providing products to your organization, please contact Final Folio as described in the How to Contact Us section.
not collect or use personal data beyond that needed for authorized educational or school purposes;
not sell or rent personal data;
not use or share personal data for advertising or similar commercial purposes, such as behavioral targeting of advertisements;
not build a personal profile, other than for supporting authorized educational or school purposes or as authorized by the parent, guardian, minor, or student of appropriate age; and
require that our vendors with whom personal data is shared, if any, are obligated to implement these same commitments for personal data of children 13 years old or younger.
Final Folio does not require you to create an account, sign into a product or service, or enter a password, to use Final Folio products and services. Apps that Final Folio provides for smartphones and other devices may utilize password or other biometric security to verify that the user is authorized to access our products and services. As a result of doing so, Final Folio may obtain information regarding the identity of the device and the owner. This information is used only for the purpose of verifying the user’s right to use the products and services.
Final Folio partners, including payment portals, may require you to provide personal information and/or register an account to facilitate performance of legitimate business operations related to providing ancillary services for Final Folio’s products. Personal data associated with third-party accounts may include credentials, name and contact data, payment data, device and usage data, your contacts, information about your activities, information used to verify your identity, and your general interests. If you do not agree to provide that information, e.g. you do not provide information to a financial institution that is necessary to process a payment, you may not be able to use a product or service.
Providing an email address, and phone number for two factor authentication, and allows us to inspect and verify government ID’s before encrypting them inside your Final Folio, enables personalization and consistent experiences across products and devices, permits you to use our archival cloud data storage, allows you to make payments using payment information stored with third party financial institutions, allows us to verify your right to access archived Folio, and enables other features.
When you create your Final Folio transaction Record tied to your personal email address and a phone number, we refer to that transaction as a personal Final Folio Record.
When you or your organization (such as an employer or your school) creates your Final Folio transaction tied to your email address and phone number provided by that organization, we refer to that account as a work or school Record.
When you or your organization create your Final Folio transaction for the purpose of notarizations, we refer to that account as a Final Folio Notary Record.
Notary services require the collection of personal information. Government statutes and regulations apply to notarizations and must be complied with for a document to be legally binding. When we perform notary services we collect and retain personal information necessary or convenient for providing the services. For online notarizations we use a third party, DocVerify. You should carefully read the DocVerify privacy policy on their website before utilizing our Notary Services.
We may refer you to Notaries who are commissioned to provide services in your state of residence or other states where documents are to be notarized. While we may receive a referral fee, third party Notaries are independent third parties and not employees or contractors of Final Folio. We do not have any control over the privacy, security, or other policies and business practices of any independent third-party, including notaries.