1DOX Privacy Policy

1. General

1.1 This privacy policy explains how 1DOX Digital OÜ (registry code 12595949, VAT no EE102244748, address Pärnu mnt 113, 11312 Tallinn, Estonia; hereinafter 1DOX or we) processes personal data in the 1DOX portal at 1dox.eu (hereinafter the Portal).

1.2 Personal data is processed in accordance with the General Data Protection Regulation (EU) 2016/679 (hereinafter the GDPR) and the Estonian Personal Data Protection Act.

1.3 This policy is not a contract and no consent to it is asked. The conditions of using the Portal are set out in the terms of service.

2. Controller and processor

2.1 For account holders' data (account, sign-in, billing, usage), 1DOX is the controller.

2.2 For documents uploaded to the Portal and the data of persons invited to sign them, the document owner (our customer) is the controller. 1DOX processes that data as a processor on the document owner's instructions and only to provide the Service.

2.3 In a company workspace, the document owner is the company in whose workspace the document is kept.

3. What data we process

3.1 Account holder: name, national identification code and its country, e-mail address, sign-in method (eID, Google, Apple, Microsoft, or e-mail and password with a two-step TOTP code), linked companies and roles in them, prepaid balance, payments and invoices, plan details, and usage data (for example the number of signatures and AI usage).

3.1.1 For security, on sign-in we record a device identifier, the browser name (user agent) and the IP address, so that a sign-in from a new device can be flagged.

3.2 Signer (also without an account): name, national identification code, country, signing certificate, time and method of signing, and e-mail address if they were invited by e-mail.

3.3 The content of documents, including personal data contained in them. We process document content only to provide the Service (storage, display, signing, features the User invokes).

3.4 Communication: the name, e-mail address and message sent through the feedback and contact forms.

4. Purposes and legal bases

4.1 Performance of a contract (GDPR Art. 6(1)(b)): keeping the account, sign-in, storing documents, signing, billing and customer support.

4.2 The document owner's instructions (GDPR Art. 28): processing the data of signers and documents on behalf of the document owner.

4.3 Legal obligation (GDPR Art. 6(1)(c)): keeping accounting records under the Estonian Accounting Act and anti-money-laundering requirements.

4.4 Legitimate interest (GDPR Art. 6(1)(f)): security of the Service, preventing fraud and abuse, error monitoring, and keeping a tamper-evident evidentiary log.

4.5 Consent (GDPR Art. 6(1)(a)): statistics and advertising cookies on the public marketing pages (section 10).

5. Signing without an account

5.1 Signing a document does not create an account. A signer's data is processed on behalf of the document owner (section 2.2).

5.2 A signer may later create an account if they wish. In that case the documents they signed earlier are added to it: for each document we keep a signature record (national identification code and document) for as long as the document exists.

6. Retention

6.1 Account data: while the account is active. On deleting the account, section 8.3 of the terms of service applies.

6.2 Billing and accounting records: 7 years from the end of the financial year (Estonian Accounting Act).

6.3 Data of a signer without an account: as long as the document owner keeps the document. When the document is permanently erased, the signer's name and national identification code are removed from the signing, signature and invitation records.

6.4 Documents: until the owner deletes them, subject to the owner's own statutory retention obligations.

6.5 Evidentiary log: kept permanently, also after a document is erased, as tamper-evident evidence of signing and access. The names, national identification codes, countries and e-mail addresses of signers and invitees may remain in the log. Ground: the establishment, exercise or defence of legal claims (GDPR Art. 17(3)(e)) and legitimate interest.

7. Recipients and sub-processors

7.1 Personal data is never sold. Data is passed only to the following sub-processors, to the extent necessary to provide the Service:

7.1.1 Amazon Web Services (Frankfurt, eu-central-1) — hosting, database, file storage and receiving incoming e-mail. Documents are stored in the European Union.

7.1.2 eID Easy — electronic signing and eID sign-in (together with the trust service providers whose means the signer uses).

7.1.3 Mandrill (Mailchimp) — sending e-mail.

7.1.4 Stripe and Montonio — payment processing. 1DOX never sees or stores card details.

7.1.5 Anthropic and Voyage AI — AI features and document search, only when the User invokes a feature (section 9).

7.1.6 Google — sign-in with a Google account, importing from Google Drive, statistics and advertising measurement with consent (section 10).

7.1.7 Microsoft — sign-in with a Microsoft account, importing from OneDrive, and sending a partner's e-mail through the partner's own Microsoft 365.

7.1.8 Apple — sign-in with an Apple account, where enabled.

7.1.9 Sentry (European Union data centre) — monitoring technical errors, without personal data.

7.2 Document conversion, virus scanning and signature validation run on 1DOX's own servers.

7.3 Data may be disclosed to authorities where the law requires it.

8. Transfers outside the European Economic Area

8.1 Some sub-processors (for example Anthropic, Voyage AI, Mandrill, Stripe, Google, Microsoft, Apple) are United States companies or their subsidiaries, so data may reach countries outside the European Economic Area.

8.2 For such transfers we rely on the EU–US Data Privacy Framework recognised by the European Commission (where the recipient is certified under it) or on the standard contractual clauses approved by the European Commission.

9. Artificial intelligence

9.1 AI features are used only when the User invokes them. Only the document content the feature needs is processed.

9.2 Customers' documents are not used to train AI models — neither by 1DOX nor by its sub-processors.

10. Cookies

10.1 The Portal uses necessary cookies: the sign-in session, security (including device recognition), the language choice and interface preferences. These require no consent.

10.2 On the public marketing pages we use Google Analytics and Google Ads only with consent. Before consent no Google cookie is set; Google may receive cookieless pings. The choice can be changed at any time through the “Cookie settings” link in the footer.

10.3 A signed-in user is not measured in the Portal, and document addresses are never sent to Google.

11. Your rights

11.1 You have the right to access your data, to have it rectified, erased or its processing restricted, to object to processing based on legitimate interest, and to receive your data in a machine-readable form (data portability). You may withdraw consent at any time.

11.2 If you are a signer or a person named in a document and the document belongs to our customer, address your request to the document owner. If you contact us, we forward the request to the document owner.

11.3 We answer a request within one month. Before answering we may verify the requester's identity.

11.4 You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (www.aki.ee).

12. Changes and contact

12.1 This policy may be amended. The current version is always available in the Portal; account holders are notified of material changes in advance.

12.2 Contact for personal data matters: 1DOX Digital OÜ, Pärnu mnt 113, 11312 Tallinn, e-mail info@1dox.site.

12.3 In case of conflict between the Estonian and English versions of this policy, the Estonian version prevails.