Data Processing Addendum

Version 1.0, approved 2026-09-21. This addendum sets out the operational commitments the code and procedures honour, and the positions eScryber takes on roles, transfers, audit and liability (decision D25). It applies to United States organisations; section 8 says what that means for anyone else.

1. Scope and roles

This addendum forms part of the Terms of Service between the organisation ("you") and eScryber. Where you use eScryber to send documents to and collect entries and signatures from people, you determine the purpose and content of that processing and eScryber processes personal data on your instructions: for that data you are the controller and eScryber is your processor. For the account, member and billing data eScryber needs to run and bill the service — names, email addresses, roles, sign-in records, subscription state — eScryber determines the purpose and is the controller, as the privacy policy describes.

2. What is processed

The categories of data subjects, personal data and purposes are set out in the engineering data map (an internal inventory, available on request), which is incorporated by reference. In summary: your members (name, email, role, activity); your recipients (name, email, document entries, signature, consent, network details at signing); and the documents themselves.

3. Instructions

eScryber processes personal data only:

• to provide the service as described in the terms and the documentation — delivering, rendering, signing, stamping, storing and returning documents, and producing audit trails and certificates;
• as you direct through the product — who you send to, what you attach, which integrations you connect, when you export or delete;
• as required by law, in which case eScryber tells you first unless the law prevents it.

eScryber does not use your personal data for its own purposes, does not sell it, and does not use document content to train models.

4. Confidentiality

Persons authorised to process personal data are bound by confidentiality. Operator access to customer data requires a stated reason and is written to a hash-chained audit log that is verified daily (security).

5. Security

eScryber maintains the measures described in the security policy, which is incorporated by reference. They include transport encryption, hashed credentials, encrypted integration tokens, tenant isolation tested route by route, hash-chained audit trails, request and storage bounds, and logging that removes credentials and content before writing.

6. Subprocessors

You authorise the subprocessors listed on the subprocessors page as of this addendum's approval date. eScryber adds a subprocessor only by updating that page, with notice to organisation owners 30 days before the subprocessor receives data, and you may object within that period; if the objection cannot be resolved you may terminate and export. Integrations you connect yourself (Microsoft, DocuSign, your webhook endpoints) act on your direct instruction and are not eScryber's subprocessors.

7. Assistance

eScryber assists you in responding to requests from data subjects by providing, on request, the export described in the deletion and export policy and by carrying out deletions as described there. eScryber assists with security incident notification as described in the incident response policy: notice to affected organisations without undue delay and within 72 hours of confirming a breach affecting their data, with what is known, what is being done, and a named contact.

8. International transfers

eScryber is hosted and backed up in the United States and sells to United States organisations (decision D13). Stripe, Mailgun and Microsoft may process data in other countries under their own published terms, as the subprocessors page records. eScryber does not at this time offer standard contractual clauses or any other transfer mechanism for data that non-US data-protection law applies to; an organisation that needs one should not send such data through the service until it is offered.

9. Return and deletion

At the end of the service you may export your data through the product. After the export window in the deletion and export policy, eScryber deletes your personal data, except what that policy names as kept and why (nonprofit fingerprint, operator audit entries, legal holds, Stripe's own records, email suppression).

10. Audit and information

On reasonable request, no more than once a year unless an incident has occurred, eScryber provides the information reasonably necessary to demonstrate the commitments here: this document set, the current evidence of tests and controls, and the outcome summary of any external security review. No on-site audit is offered; the information above is provided in writing.

11. Liability and precedence

The warranty and liability terms in section 12 of the Terms of Service apply to this addendum, and the total liability limit there is shared between the terms and this addendum, not additional to it. If this addendum and the terms conflict about the processing of personal data, this addendum governs; on anything else, the terms govern.

Contact

privacy@escryber.com