Updated March 22, 2019
Cohesion Signing Service, Inc., its affiliates, and agents (collectively, "Cohesion Signing Service", "we", "us", or "our") have prepared this Privacy Policy to describe to you our practices regarding the Personal Data (defined below) we collect from Users (defined below) of our website, located at www.cohesionss.com, or any other websites of Cohesion Signing Service (collectively, the "Website"), in any way, including using services or resources available or enabled via, or that interact with, the Website (collectively, the "Services"), unless otherwise indicated. Collectively, the Website and Services are "Our Properties." In conjunction with this Privacy Policy, you should also review our Terms of Service Agreement, available at www.cohesionss.com/tos, for a more complete understanding of the rules governing Our Properties.
- Questions or Concerns. If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or email: Address: Cohesion Signing Service, Inc 1621 Central Ave, Cheyenne, WY 82001 Email: orders@cohesionss.com
- Services. Cohesion Signing Service provides an online platform and notary database to bring together:
- Individuals and entities who are taking out a loan ("Borrowers") and working with title and escrow companies ("Companies") to close their loans;
- Companies seeking notary services to help their Borrower’s sign documents for loan closings;
- Polished notary signing agents ("Notaries") seeking to advertise and provide notary signing services; and
- Other parties related to a particular closing (e.g. real-estate agents and banks) seeking to monitor the signing of documents by the Borrowers ("Participants").
- Collectively, the Borrowers, Companies, Notaries, and Participants are our "Users."
- User Content. By submitting Personal Data through our Website or Services, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.
- A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Cohesion Signing Service and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at orders@cohesionss.com.
- A Note to Users Outside of the United States. If you are a non-U.S. user of Our Properties, by visiting the Website and providing Cohesion Signing Service with data, you acknowledge and agree that your Personal Data may be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. By providing your data, you consent to such transfer.
- Types of Data We Collect. "Personal Data" means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. "Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.
- Information You Provide to Us.
- We may collect Personal Data from you, such as your first and last name, e-mail and mailing addresses, company name, and password, when you create an account to log in to our Website ("Account").
- When you use our Services, we may collect Personal data from you,
- Such as your governmental identification, date of birth, and other information to obtain or verify your identity;
- If you are a Borrower, we may collect information related to your loan transaction, including without limitation Personal Data in your loan application, your signature;
- If you are a Notary, we may collect your notary certification, qualifications related to being a notary, office location, professional history, and other information related to providing notary services.
- If you use our Services on your mobile device, we may collect your phone number and the unique device id number.
- When you complete a transaction on our Website, we will collect all information necessary to complete the transaction, including your name, credit card information, bank information, automated clearing house information, billing information, billing address, and home address. We do not store this information directly on our servers, but this information will be collected by or shared with third parties who will help process and fulfill your purchases.
- We retain information on your behalf, such as files, messages, transaction history, timestamp information, and information that you store using your Account.
- If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you participate in one of our surveys, we may collect additional profile information.
- We may also collect Personal Data at other points on Our Properties that state that Personal Data is being collected
- Information Collected via Technology.
- Information Collected by Our Servers. Information Collected by Our Servers. To make Our Properties more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol ("IP") address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Log Files. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to analyze trends, administer the Website, track Users’ movements around the Website, gather demographic information about our user base as a whole, and better tailor our Services to our Users’ needs. For example, some of the information may be collected so that when you visit Our Properties again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. Except as noted in this Privacy Policy, we do not link this automatically-collected data to Personal Data.
- Cookies. Like many online services, we use cookies to collect information. "Cookies" are small pieces of information that a website sends to your computer’s hard drive while you are viewing the website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. This type of information is collected to make the Website more useful to you and to tailor the experience with us to meet your special interests and needs. For information on how to disable Cookies, please see Section 10 (Your Choices About Information).
- Pixel Tags. In addition, we use "Pixel Tags" (also referred to as clear .gifs, web beacons, or web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies that are used to track online movements of web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our Users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our Users’ Personal Data.
- How We Respond to Do Not Track Signals. We do not currently respond to "do not track" signals or other mechanisms that might enable Users to opt out of tracking on our Website.
- Interest-Based Advertising. In addition to using Cookies and related technologies as described above, we may also permit third parties to help us tailor advertising that we think might be of interest to Users and to collect and use other data about user activities on our Website (e.g. to allow them to tailor ads on third party services). Those companies may deliver ads that might also place Cookies and otherwise track user behavior. If you prefer that we not share information with companies that use tracking technologies to deliver targeted display advertising based on such information, you might be able to opt-out by visiting http://www.aboutads.info/ or http://networkadvertising.org/choices/, or if you are located in the EU, http://www.youronlinechoices.eu/.
- Analytics Services and Interest-Based Advertising. In addition to the tracking technologies we place, other companies may set their own cookies or similar tools when you visit our Website. This includes third party analytics services, including but not limited to Google Analytics ("Analytics Services"), that we engage to help analyze how Users use the Website, as well as third parties that deliver content or offers. We may receive reports based on these parties’ use of these tools on an individual or aggregate basis. We use the information we get from Analytics Services only to improve Our Properties. The information generated by the Cookies or other technologies about your use of Our Properties (the "Analytics Information") is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ Terms of Use and Privacy Policy. By using Our Properties, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services, please contact us at orders@cohesionss.com.
- Information Collected from Others About You. If you are a Borrower, we may collect the following information from Companies with whom you are working: (i) Personal Data about you, such as your name and e-mail address, so we may follow up with you about our Services; and (ii) files and information related to your loan transaction, such as your loan application, to provide you, and the applicable Company and Notary our Services and to improve our Services. We rely on the Company to obtain from you all consents required to: (i) allow the Company to share such Personal Data with us, and (ii) allow us to use and disclose your Personal Data in accordance with this Privacy Policy. You or the third party may contact us at orders@cohesionss.com to request the removal of this information from our database.
- Information Collected from You About Others. If you decide to invite a third party to create an Account, we will collect your and the third party’s names and e-mail addresses in order to send an e-mail and follow up with the third party. We rely upon you to obtain whatever consents from the third party that may be required by law to allow us to access and upload the third party’s names and e-mail addresses as required above. You or the third party may contact us at orders@cohesionss.com to request the removal of this information from our database.
- Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our products by way of a co-branded or private-labeled website or companies that sponsor contests for which we have contributed our products for prizes. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Website in order to improve the Services we provide.
- Use of Your Personal Data
- General Use. In general, Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- facilitate the creation of and secure your Account on our network;
- identify you as a user in our system;
- identify the type of user you are in our system;
- verify and check your identify;
- confirm ownership of your email address, and payment provider account;
- preventing and protecting against fraud, including, without limitation, with respect to handling of payments;
- to provide you with a streamlined account experience;
- to process and fulfill your transactions or contact you concerning the status of a transaction;
- provide improved administration of Our Properties;
- improve the quality of experience when you interact with our Website;
- send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- send you administrative e-mail notifications, such as security or support and maintenance advisories;
- respond to your inquiries related to employment opportunities or other requests;
- provide you with targeted offers and advertising, including on the Website, via direct mail, e-mail, or push notifications, and to contact you about upcoming sales, promotions, offers and product information. You may receive these offers in advertising that is directed to you via third party websites and media properties, including in social media;
- send newsletters, surveys, offers, and other promotional materials related to our products and for other marketing purposes of Cohesion Signing Service; and
- enforce our Terms of Service Agreement.
- User Testimonials and Feedback. We often receive testimonials and comments from Users who have had positive experiences with our products. We occasionally publish such content. When we publish this content, we may identify our Users by their first and last name and may indicate their city and other Personal Data. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Website from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback.
- Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Website navigation, and to make recommendations to our Users about how to better use Our Properties. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
- Disclosure of Your Personal Data. We disclose your Personal Data as described below and as described elsewhere in this Privacy Policy.
- Authorized Third Parties. We share your Personal data with trusted third parties in the following ways:
- Third Parties Designated by You. When you use our Services, some of the Personal Data you provide will be shared with third parties you designate to receive such information.
- Third Parties Designated by a Company. If you are a Borrower, some of the Personal Data provided by you to a Company may be shared with other Users that such Company designates to receive such information. For example, when a Company uploads a Borrower’s loan documents that require notarization, such loan documents will be shared with the applicable Notary to provide notary signing services for you and the Company.
- Our Service Providers. We may share your Personal Data with third party service providers to: provide you with the Services that we offer through our Website; to facilitate creation of Accounts; to facilitate transactions; to provide technical support; to provide other services to Cohesion Signing Service; and/or for the maintenance, improvement, and enhancement of our services.
- Our Payment Processor. We use a third-party payment processor, bill.com, to process payments made to us. We do not retain any financial information used in connection with the processing payments through our third-party payment processor. Rather all your financial information, such as your name, billing address, and credit card information, is provided directly to our third-party payment processors, and bill.com’s use of such information, as well as any of your Personal Data, is governed by their respective privacy policies. By paying or receiving funds through the Services, you agree to be bound by bill.com’s US Terms of Service available https://app.bill.com/TermsOfService and Privacy Policy available at https://www.bill.com/privacy/.
- Our Marketing Partners. We may share Anonymous Data with our third-party marketing partners to analyze trends, track user movements, and gather broad demographic and behavioral information for aggregate use. We may share Personal Data, such as your email address, with certain third-party marketing partners to, among other things, compare your Personal Data with each third-party marketing partner’s user information for the purpose of helping us better market our Services to our Users and other users on third-party websites.
- Affiliates. We may share some or all of your Personal Data with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to honor this Privacy Policy. However, certain third party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase related transactions. We recommend that you read these providers’ privacy policies so you can understand the manner in which they will handle your personal information.
- Media Agencies; Social Media Sites. We may also share your email address with a third party, such as a media agency, to send email and other communications, including interest-based advertising to you on our behalf. We may also share aggregated or de-identified information about you, including based on your email address, with our advertising and marketing partners, and third party media properties, including social media websites, to allow them to send targeted advertising messages on our behalf. If you wish to stop receiving promotional communications from these third parties, please contact us at orders@cohesionss.com.
- Notice to California Residents. YOUR CALIFORNIA PRIVACY RIGHTS AS PROVIDED BY CALIFORNIA CIVIL CODE §1798.83: A California resident who has provided Personal Information to a business with whom he/she has established a business relationship for personal, family, or household purposes (a "California Customer") may request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed. California Customers may request further information about our compliance with this law by contacting us at the email address listed in Section 1 (Questions or Concerns). Please note that we are required to respond to one request per California Customer each year, and we are not required to respond to requests made by means other than through the email address listed in Section 1 (Questions or Concerns).
- Corporate Restructuring. We may share some or all of your Personal Data in connection with or during negotiation of any merger, financing, acquisition or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the Personal Data collected by us and will assume the rights and obligations regarding your Personal Data as described in this Privacy Policy.
- Other Disclosures. Regardless of any choices you make regarding your Personal Data (as described below), Cohesion Signing Service may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to subpoenas or warrants served on Cohesion Signing Service; (c) to protect or defend the rights or property of Cohesion Signing Service or Users of Our Properties; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
- Third Party Websites. Our Website may contain links to third party websites. When you click on a link to any other website or location, you will leave our Website and go to another website, and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your Personal Data after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.
- Your Choices About Information. You have several choices regarding the use of information on our Website:
- Email Communications. We will periodically send you free newsletters and e-mails that directly promote the use of Our Properties. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Please note that despite your indicated e-mail preferences, we may still contact you in relation to your order(s) or any issues relating to any business you conduct with us, including notices of any updates to our Terms of Use or Privacy Policy.
- Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
- Changing or Deleting Your Personal Data. All Users may review, update, correct or unpublish the Personal Data in their user account by editing their profile via the Services. If you completely delete all of your Personal Data, then your user account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.
- Changes to This Privacy Policy. This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here www.cohesionss.com and we will change the "Last Updated" date above. You should regularly consult this Privacy Policy for any changes. Any changes will be effective immediately for new Users of Our Properties, and thirty (30) calendar days following our posting of the new Privacy Policy on our Websites and Apps. Your continued use of Our Properties following notice of such changes shall indicate your acknowledgement of such changes and agreement to by bound by the terms and conditions of such changes. If you do not wish to permit changes in our use of your Personal Information, you must notify us at the contact information listed in Section 1 (Questions or Concerns) prior to the effective date of the changes, and upon such notice we will deactivate your Account.
Contacting Us
If you have any questions about this Privacy Policy, please contact us by email at orders@cohesionss.com