Last updated: 2026-10-01 · Operator: SparkRelay Tech Services
Summary. This Privacy Policy explains what personal data we collect through the MultiSigner service, why we collect it, how we use and protect it, and the choices and rights you have regarding your data. By creating an account and using the Service, you acknowledge that you have read and understood this Policy.
1. Introduction and Scope
This Privacy Policy describes how SparkRelay Tech Services ("Company," "we," "us," or "our") collects, uses, stores, discloses, and protects personal data in connection with the MultiSigner electronic document signing service (the "Service"). It applies to all users of the Service, including account holders and visitors to our website. Capitalized terms not defined here have the meaning given in our Terms and Conditions.
2. Who We Are (Data Controller)
For the purposes of applicable data protection laws, the data controller of your personal data is:
SparkRelay Tech Services 2000 Hogback Rd, Suite 6, Ann Arbor, MI 48105-9735, USA
Email: info@multisigner.vip
3. Information We Collect
3.1 Account and Registration Information
When you create an account (including self-service registration), you provide:
email address (unique; used as your username);
a password (stored only as a one-way cryptographic hash — never in plain text);
your name;
your country, city, and street address;
your mobile phone number and country calling code;
your preferred interface language (Spanish, English, German, or French).
3.2 Payment Information
Payments for credits are not processed by us directly. Depending on the payment option configured for the Service and on the option you select at checkout, your payment is processed by one of the following providers, which acts either as our Merchant of Record or as a payment processor:
Fungies (Fungies Inc., or Fungies Europe PSA), acting as Merchant of Record. In that case Fungies is the legal seller of record for the transaction and is responsible for taking the payment, issuing your receipt and invoice, and calculating and collecting applicable taxes. Fungies' handling of your data is governed by Fungies' Buyer Terms of Service.
Stripe (Stripe, Inc.), acting solely as a payment processor. In that case the Company is the seller of record for the transaction. Stripe's handling of your payment data is governed by Stripe's Privacy Policy.
PayPal (PayPal Group), acting solely as a payment processor. In that case the Company is the seller of record for the transaction. PayPal's handling of your payment data is governed by PayPal's Privacy Policy.
The provider that processed your payment is identified on the confirmation, receipt, or invoice you receive. We do not collect or store full payment card numbers. We receive from the applicable provider only limited transaction data necessary to manage your account and credits, such as payment status, transaction references, and a customer or transaction identifier.
3.3 Documents and Certificates You Upload
PDF documents: the documents you upload for signing are processed transiently. Original and signed files are stored only temporarily and are automatically deleted after the applicable retention period. We do not provide permanent or archival storage; the retention period is limited and set by us at our discretion (see Section 9).
Digital certificate (.p12/.pfx) and password: your certificate and its password are used only to perform the requested signing. They are held encrypted (AES-256-GCM) for the duration of the active signing job and are permanently deleted when the job ends. They are never stored permanently, and the password is never retained.
Signing metadata: the reason ("motivo") you enter, the signing position on each page, the signer's Common Name (extracted from your certificate), job status, and timestamps.
3.4 Signature Flows: Data About Your Signers
If you use signature flows, you invite third parties ("signers") to sign documents through a tokenized link. In that scenario you are the data controller for your signers' personal data and we act as your processor under our Data Processing Agreement. In connection with each signer we process:
Identification data: the signer's name and email address, and the Common Name extracted from the signer's own digital certificate.
Acceptance video (image and voice): if the flow requires it, the Service records a short acceptance video in which the signer's face and voice appear, together with on-screen text and the date and time of recording. The video is stored as evidence associated with the flow and is downloadable by the account holder. Because it captures a person's face and voice, this recording may constitute, or may reveal, biometric or special-category personal data depending on the law applicable to you and your signer, and on how it is used.
Traceability data: for each step of the flow we record the signer's IP address, timestamps, and geolocation derived from that IP address (country, city, and approximate coordinates) obtained through third-party geolocation services.
Device data: technical information sent by the signer's browser, such as user agent, browser and operating system, device brand and model where available, screen characteristics, language, time zone, and hardware characteristics.
Verification and acceptance data: one-time password (OTP) issuance and verification records, and the signer's acceptance of having read each document.
Your responsibility as account holder. Because you decide which documents are sent, which individuals are invited, and why, you are responsible for having a lawful basis for this processing, for informing your signers that an acceptance video with their face and voice will be recorded, and for obtaining any consent required by applicable law. We process this data only on your instructions. See Sections 5, 6, and 7, and our Data Processing Agreement.
You are the one who requires this evidence. We only provide the method. The acceptance video, the reading-acceptance records, and the traceability data (IP address, IP-derived geolocation, and device data) are collected because you, as the account holder, require them as evidence of your signers' acceptance of the documents. The Company does not require, need, or use that evidence for its own purposes. In relation to it, the Company acts solely as the technical tool that provides the method of collecting and temporarily holding the evidence on your behalf. The evidence and the signed documents belong to you and are controlled by you, not by us.
Your duty to safeguard the evidence. You are solely responsible for retrieving, safely storing, and protecting that evidence once you download it — the acceptance videos, the traceability records, and the signed documents — and for keeping it secure and confidential and available for as long as you need it for your own legal, evidentiary, or compliance purposes. The Company is not the custodian or archivist of your evidence and does not accept responsibility for its safekeeping after you download it.
Deletion after a reasonable retention period. The documents and the evidence are automatically and permanently deleted after a reasonable, limited retention period (currently 30 days), which is set to give you sufficient time to download them. Retention is never indefinite or permanent. Once deleted they cannot be recovered, so it is your responsibility to have downloaded them in time. See Section 9.
Who can access a flow's documents and evidence during the retention period. While a flow's documents and evidence are retained, access to them is restricted and confined to the flow's creator. Specifically:
The flow's creator. The authenticated account holder who created the flow, and only that account holder, has full access to that flow's documents, signed documents, acceptance videos, and traceability records. Access is scoped to the creator's own account: no other customer, and no user of any other account, can see, list, or download them.
The invited signer. A signer can access only the specific documents they are required to read and sign, and only through their own single-use tokenized link, for the duration of their own step. That access ends automatically when they complete their signature: the link is invalidated and cannot be reused.
The Company's system administrators. For strictly limited operational purposes only, namely platform administration, technical support requested by you, security and abuse investigation, compliance with a legal obligation, or executing a deletion you have requested, the Company's designated administrators may access a flow. Such access requires administrator authentication and is subject to the security measures described in our Encryption and Access Control document.
No one else. We do not publish, share, sell, or otherwise disclose flow documents or evidence to any other party. There is no public listing, no public URL, and no directory of flows. When the retention period ends, the documents and the evidence are deleted and that access ends with them.
3.5 Usage and Technical Information
We automatically collect limited technical and usage data, including IP address, browser type and version, device information, pages or endpoints accessed, timestamps, and server logs. This data is used to operate, secure, and improve the Service.
3.6 Communications
We process the email messages we send you (OTP verification codes, password-reset links, signing completion notifications, and flow invitations and reminders) and any communications you send to us (such as support requests).
4. How We Use Your Information
We use your personal data for the following purposes:
To provide and operate the Service, including account creation and authentication, processing signing jobs, generating and delivering signed documents, and managing your credits and billing;
To verify your identity and secure the Service, including sending one-time passwords (OTP) to your email and password-reset links;
To process payments through the payment provider applicable to your purchase (see Section 3.2) and maintain accurate credit and ledger records;
To operate signature flows, including sending invitations and reminders to your signers, verifying their email by OTP, recording their acceptance video, and recording the traceability data described in Section 3.4, in each case on your instructions as controller;
To communicate with you regarding your account, signing jobs, downloads, and support;
To maintain security and prevent fraud, including logging and monitoring;
To comply with legal obligations, such as record-keeping, tax, or law enforcement requirements;
To improve and administer the Service, based on aggregated or de-identified usage data where possible.
We do not use your personal data for purposes unrelated to the Service, and we do not sell it or use it to build profiles for third-party advertising.
5. Legal Bases for Processing (EU/UK/EEA Users)
If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we rely on the following legal bases under the GDPR / UK GDPR:
Performance of a contract: processing necessary to provide the Service you requested (e.g., your account, signing jobs, credits);
Consent: where you have given consent (e.g., your authorization described in Section 6, or where consent is otherwise required), including, where you act as a signer, your consent to the recording of the acceptance video and the traceability data described in Section 3.4;
Legitimate interests: maintaining and securing the Service, preventing fraud, and improving our offering, balanced against your rights;
Legal obligation: where processing is required to comply with applicable law.
6. Your Authorization: Storage and Use of Your Data
By creating an account and using the Service, you expressly authorize SparkRelay Tech Services to store and process the personal data you provide solely for the purposes of the processing that this Service and the Company offer — namely, operating, administering, and delivering the MultiSigner signing service and its related functions (account registration, OTP verification, document signing, credit and billing management, and customer support), as described in this Policy.
Your personal data:
will not be exposed publicly;
will not be sold, rented, or shared for third-party marketing;
will not be transferred or disclosed outside the Company for any reason without your prior authorization, except for: (a) the limited third-party service providers described in Section 7 that process data solely on our behalf and under confidentiality obligations to deliver the Service (payment processing or Merchant of Record services, email delivery, optional time-stamping, and IP geolocation for signature flows); (b) where disclosure is required by applicable law, regulation, or valid legal process; or (c) where necessary to protect the rights, property, or safety of the Company, our users, or the public.
You may withdraw this authorization at any time by contacting us; however, withdrawing your authorization may mean that we can no longer provide the Service to you.
7. How We Share and Disclose Information
We do not sell your personal data, and we do not expose it publicly. We disclose personal data only in the following limited circumstances:
Service providers: trusted third parties that perform services on our behalf and under contractual confidentiality and security obligations, strictly as necessary to deliver the Service. These currently include:
Fungies — where configured, acting as Merchant of Record for credit purchases, including payment, receipts and invoices, tax calculation and collection, and refund administration;
Stripe — where configured, payment processing for credit purchases;
PayPal — where configured, payment processing for credit purchases;
our email/SMTP provider — delivery of OTP codes, password-reset links, flow invitations and reminders, and notifications;
a Time Stamping Authority (TSA) — only where the RFC 3161 time-stamp feature is enabled and only for the cryptographic material required to obtain the time-stamp;
third-party IP geolocation services — only where signature flows are used, and only to derive country, city, and approximate coordinates from a signer's IP address for the traceability records described in Section 3.4.
The specific payment provider used for your purchase is identified on your confirmation, receipt, or invoice. Where Fungies acts as Merchant of Record, it acts as an independent controller of the transaction data it processes for its own tax, accounting, and compliance obligations.
Legal obligations: where required by law, regulation, court order, or valid government request.
Protection of rights: to enforce our Terms, investigate potential violations, or protect the rights, property, or safety of the Company, our users, or others.
Business transfers: in connection with a merger, acquisition, reorganization, or sale of assets, in which case your data may be transferred as part of the transaction (subject to this Policy continuing to apply or equivalent protection being provided).
With your consent or authorization: in any other circumstance, only with your prior authorization.
8. Cookies and Similar Technologies
The Service uses a single, strictly necessary session cookie (httpOnly, SameSite=Lax, and Secure in production) to maintain your authenticated session via a JSON Web Token (JWT). It does not contain personal data itself.
Certain user preferences (interface language and light/dark theme) are stored in your browser's localStorage so the Service can remember them between visits. These preferences are stored locally on your device and are not used for tracking or advertising.
We do not use third-party advertising cookies or tracking pixels, and we do not engage in cross-site behavioral advertising.
9. Data Retention
Data category
Retention
Account and profile data
For as long as your account is active, plus any period required by law; deleted upon account closure unless we must retain it for legal, security, or accounting reasons.
Password
Stored only as a hash; never in plain text.
Digital certificate (.p12/.pfx) and its password
Temporarily, only for the duration of the active signing job; permanently deleted when the job ends (or when the job TTL expires).
Uploaded and signed documents / ZIP packages
Temporarily. Signed packages remain available for download for a limited retention period set by us at our sole discretion (currently 30 days), after which they are automatically and permanently deleted. Retention is never indefinite or permanent, and we do not provide archival storage. You are responsible for downloading and securely storing your own copies within the period.
Signature flows: acceptance videos (image and voice of the signer)
Stored as evidence for the duration of the flow and for the applicable retention period, then automatically deleted. Videos uploaded to a temporary location but not confirmed are purged after 10 minutes.
Retained with the flow's records while the flow exists and for the applicable retention period, then deleted together with them.
OTP codes and password-reset tokens
One-time use and short-lived; expire after a few minutes (OTP) or 15 minutes (password-reset link) and are stored only as hashes.
Payment and credit ledger records
Retained as necessary for accounting, tax, and audit purposes.
Server logs and technical data
Retained for a limited period for security and operational purposes.
10. Security of Your Information
We implement appropriate technical and organizational measures to protect your personal data, including:
encryption in transit (TLS/HTTPS in production) and at rest where applicable;
one-way hashing of passwords (bcrypt) and of OTP codes and reset tokens (SHA-256);
AES-256-GCM encryption of digital certificates and their passwords while a signing job is active;
automatic, permanent deletion of certificates and passwords when a signing job ends;
restricted, permission-controlled storage of the database and files (directory permissions 0700), outside the public web root;
rate limiting on authentication and OTP endpoints and CSRF protections on mutating requests.
No method of transmission or storage is completely secure. While we strive to protect your data, we cannot guarantee absolute security.
11. International Data Transfers
Your personal data is processed and stored on our infrastructure, which uses automatic load balancing across servers located in the United States and Canada to provide greater efficiency and a service-level commitment of 99.5% availability (see our Service Level Agreement). If you are located outside the United States or Canada, your data will be transferred to and processed in those countries, whose data protection laws may differ from those of your jurisdiction. Where required by law (for example, for users in the EEA, UK, or Switzerland), we rely on appropriate safeguards such as Standard Contractual Clauses for such transfers.
12. Your Privacy Rights
12.1 California Residents (CCPA/CPRA)
If you are a California resident, you may have the right to: (a) know what personal information we collect, use, disclose, and sell (we do not sell personal information); (b) request deletion of your personal information; (c) correct inaccurate personal information; (d) opt out of the "sale" or "sharing" of personal information (we do not sell or share for cross-context behavioral advertising); and (e) be free from discrimination for exercising these rights. You may exercise these rights by contacting us using the details in Section 16. We will verify your request and respond as required by law.
12.2 EEA, UK, and Swiss Residents (GDPR / UK GDPR)
If you are located in the EEA, the UK, or Switzerland, you have the right to: access your personal data; request rectification; request erasure ("right to be forgotten"); request restriction of processing; request data portability; object to processing based on legitimate interests; withdraw consent at any time (without affecting the lawfulness of prior processing); and lodge a complaint with your local supervisory authority.
12.3 How to Exercise Your Rights
To exercise any of these rights, contact us at the details in Section 16. We may need to verify your identity before responding. We will respond within the timeframes required by applicable law.
13. Children's Privacy
The Service is not directed to, and we do not knowingly collect personal data from, children under the age of 13 (or 16 where required by applicable law). If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.
14. Do Not Sell / Do Not Track
We do not sell your personal information as that term is defined under applicable privacy laws. The Service does not respond to "Do Not Track" (DNT) browser signals because there is no consistent industry standard for doing so; however, we do not engage in cross-site tracking for advertising.
15. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. Material changes will be communicated by reasonable notice (such as posting the updated Policy or sending an email). Your continued use of the Service after the effective date constitutes acceptance of the revised Policy.
16. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at: