Privacy Policy

Version 1.0 · Effective from: This document takes effect on the day the app is published.

Language: English · Polski · Deutsch

The Polish version is the original of this document. Other language versions are translations provided for convenience.

1. Publisher and privacy contact

The publisher of the ARA Sign mobile application (the “Application”) is Krystian Janda Just In Time, ul. Lecha 5, 32-590 Libiąż, Poland, VAT ID (NIP): PL6281992900, Business register number (REGON): 120722683, TELEPHONE: +48737496462 (hereinafter the “Publisher”, “we”).

Contact point for all matters concerning privacy, personal data protection and the exercise of rights under data protection law: office@jintsoftware.pl

The Publisher has not designated a data protection officer. The obligation to designate one does not arise in the circumstances set out in Article 37(1) GDPR in relation to the Publisher’s activity connected with the Application.

2. Scope of the Policy

This Privacy Policy (the “Policy”) describes:

what information the Application processes locally on the user’s device,
what personal data the Publisher may receive and how it processes them,
what rights the user has and how to exercise them.

The Policy applies to the version of the Application indicated in the header and to processing carried out by the Publisher.

The fact that data are processed solely on the user’s device does not mean that those data fall outside the scope of data protection law. The allocation of roles in this regard is described in section 22.

The Policy does not cover processing carried out independently by the device’s operating system, by the Google Play store or by third-party applications chosen by the user. Such processing is governed by the rules established by the entities concerned.

The Application is intended for users worldwide. Where mandatory provisions of law applicable at the user’s location grant the user broader rights or impose more extensive obligations on the Publisher, those provisions apply to the extent that they are applicable.

3. Core principles

The Application has been designed in accordance with the principles of data minimisation and local processing.

As regards the functions covered by this Policy:

the Application does not require the creation of an account, registration or logging in;
the Publisher does not operate a server intended for storing the user’s documents, signatures, initials or stamp data;
the Publisher does not receive the PDF documents, signatures, initials or stamp data processed by the Application on the user’s device;
the Application does not contain its own analytics tools, tracking tools or advertising software development kits;
the Application uses the Android system mechanisms for taking photographs, selecting photographs, selecting files, saving files and sharing files;
the Application’s data have been excluded from the backup and data transfer mechanisms provided by the Android system, in accordance with section 12.

These principles describe how the Application operates and the Publisher’s commitments, and are of a permanent nature. Information on the technical characteristics of a specific version of the Application is set out in section 8.

4. How the Application works

The Application is used to prepare PDF documents locally by placing in them the graphic image of a signature or initials, as well as a stamp, a date, a place name or text entered by the user.

The user may, in particular:

create an image of a signature or initials on the basis of a photograph taken by the user;
remove the background from such an image;
save the image of the signature or initials for later use;
create a stamp on the basis of information entered by the user;
open a PDF document selected by the user;
place in the document a signature, initials, a stamp or a combination of them;
place in the document a date, a place name or text;
save the prepared document;
transfer the prepared document to another application using the system sharing function.

Operations performed by the Application itself take place locally on the user’s device.

5. Information processed locally on the device

The following information is processed and stored solely in the memory of the user’s device, in the area assigned to the Application by the operating system. The Publisher does not receive this information and has no access to it.

5.1. Signature and initials

In connection with the function of creating a signature or initials, the Application may process:

a photograph taken or selected by the user;
the image resulting from background removal;
the saved image of the signature;
the saved image of the initials.

Image processing takes place entirely on the user’s device.

The saved image of the signature or initials is created as a new image file containing solely the extracted ink trace in the colour selected by the user. The pixels of the source photograph are not retained in it. The Application reads from the photograph’s metadata solely the orientation tag, which is necessary to rotate the image correctly; the remaining metadata of the photograph, including any data on location, device and the time the photograph was taken, are neither used nor saved in the image created.

If the photograph was taken using the system camera function, the source file is saved in the Application’s temporary directory and deleted once processing is complete. Irrespective of this, the contents of the Application’s temporary directory are deleted each time the Application is launched.

If the user selected a photograph from the gallery, the file remains in the location where the system saved it. The Application does not delete files located outside its own temporary directory.

The Application stores one saved image of a signature and one saved image of initials. Creating a new image replaces the previous one.

5.2. Stamp data

The user may enter information intended to be placed in the stamp, in particular a company name, first name and surname, address, identification number or other data at the user’s discretion.

The content of the stamp is determined solely by the user. This information is stored locally and is not transferred to the Publisher.

5.3. Date and place name

The Application may remember locally the date and place name entered by the user in order to suggest them the next time.

To format the date, the Application reads the device’s regional settings. This reading takes place locally, does not require any permission and does not involve any transfer of information outside the device.

5.4. Text

Content entered by the user in the text tool is not remembered as a suggestion for subsequent documents. It may, however, form part of the locally saved state of unfinished work on a specific document, in accordance with point 5.5.

5.5. PDF document and the state of unfinished work

When a document is opened, the Application creates a working copy of it in its private directory. The copy makes it possible to work on the document independently of the original file, which remains unaltered.

Saving a prepared document consists in creating a new PDF file. The file selected by the user as the source file is not modified. The Application does not save in the file created any metadata identifying the user, the device or the Publisher.

The Application saves the state of unfinished work locally so that it is not lost if the Application is terminated by the system. This record covers the position and size of the elements placed, the text entered and the images of the signatures, initials and stamps placed, as well as the name and size of the document concerned.

The Application maintains one working session. Opening another document results in the deletion of the working copy and of the work state relating to the previous document.

5.6. Technical information concerning the interface

The Application stores locally the information necessary for the interface to function correctly, for example the information that a particular operating hint has already been displayed, and the appearance settings chosen by the user.

This information is not used for profiling or for analysing the user’s behaviour.

5.7. Information about the purchase of the full version and the free limit

In order to apply the rules of the free scope and of the full version, the Application stores locally:

information about the purchase of the full version, comprising the product designation, the time at which the purchase was confirmed on the device and — if the Google Play store provides it — the order identifier;
cryptographic hashes of documents saved or shared within the free limit.

A cryptographic hash is a string of characters calculated from the content of a document. It makes it possible to recognise that the same document has already been saved or shared, but it does not make it possible to reconstruct the document’s content, its name or the data it contains.

This information is not deleted by the function of resetting the security lock, as it records the status of the user’s entitlement. It is deleted together with the other data of the Application when the Application is uninstalled or its data is cleared in the system settings.

If the amount paid is refunded or the purchase is cancelled, the entitlement expires in accordance with clause 9.8 of the Terms, and the Application may update the stored purchase information accordingly.

5.8. Information about acceptance of the Terms

The Application stores locally information about the acceptance of the Terms: their version number, the time of acceptance and the version number of the Application in which acceptance took place. This information serves to demonstrate the conclusion of the agreement and to determine whether renewed acceptance is required after the Terms are amended. It is not deleted by the function of resetting the security lock; it is deleted together with the other data of the Application when the Application is uninstalled or its data is cleared.

6. The image of a handwritten signature and biometric data

Given the subject matter of the Application, the Publisher addresses this issue explicitly.

Under Article 4(14) GDPR, biometric data means personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that person. Under Article 9(1) GDPR, biometric data constitute a special category of data only where they are processed for the purpose of uniquely identifying a natural person.

As regards the Application:

the Application processes only a static image of a signature captured in a photograph of a sheet of paper. The Application does not record, and is not able to record, dynamic characteristics of the act of signing, such as pressure, speed, direction of movement or pauses in writing, because those characteristics are not present in a photograph;
the processing of the image by the Application consists in separating the ink trace from the background, straightening and cropping the image. The Application does not create a biometric template, does not extract characteristic features for the purpose of comparison and does not compare the image with any set of data;
the Application does not use the image of a signature or initials to identify or verify the identity of the user or of any other person.

Consequently, neither the image of a signature nor the image of initials is processed by the Application for the purpose of uniquely identifying a natural person. The Application does not use these images to establish, confirm or compare identity. Within the scope described in this Policy, the processing of these images does not constitute the processing of biometric data for the purpose of uniquely identifying a natural person within the meaning of Article 9(1) GDPR.

The above does not mean that the image of a signature or initials is devoid of the character of personal data. Where, in the circumstances, such an image can be attributed to an identified or identifiable natural person, it constitutes personal data and is subject to the rules described in this Policy. These images are stored solely locally, on the terms described in section 5.

7. Access to photographs, the camera and files

The Application does not contain its own camera or its own file browser. It uses solely the mechanisms provided by the Android system:

taking a photograph — the Application passes a request to the system camera and receives solely the photograph taken in the course of that operation;
selecting a photograph — the Application uses the system Photo Picker and receives solely the photograph selected by the user;
selecting a document — the Application uses the system file picker and receives solely the file selected by the user;
saving a file — the Application uses the system save dialog, and the save location is chosen by the user.

In none of these cases does the Application gain access to the entire photo gallery or to the entire contents of the device’s memory. On each occasion the user selects a specific file.

8. The Application’s network access — information concerning this version

The version of the App covered by this Policy declares in its manifest the permissions android.permission.INTERNET and android.permission.ACCESS_NETWORK_STATE, as well as the permission com.android.vending.BILLING. These permissions are introduced by the Google Play billing library, which handles the purchase of the full version of the App (Section 9 of the Terms). The user may verify the list of permissions independently, in the list available in Google Play.

Working with documents takes place solely locally on the device and does not require an internet connection. This applies to opening documents, placing signatures, initials, the stamp, text and the date in them, saving the prepared document and passing it to another application. An internet connection is used solely for handling the purchase of the full version of the App: when making the purchase, when restoring it and during the automatic check of the purchase status, which the App performs each time it starts if a connection is available. As part of this check, the App does not transmit any documents or data entered by the user.

The App does not transmit PDF documents, signatures, initials or stamp data to the Publisher’s infrastructure or to any other entity. The Publisher has no technical means of establishing which documents the user opens, prepares or saves, or to whom the user passes them.

The information contained in this section should not be read as a statement about the operation of the Android system, the Google Play store, device services or other installed applications. It concerns the App alone.

If a future version of the App changes the scope of network access or the scope of data processing in a manner material to the user’s privacy, information to that effect will be included in an updated version of this Policy, made available together with that version of the App.

Irrespective of the scope of system permissions, the principle set out in Section 3 applies: the App does not pass PDF documents, signatures, initials or stamp data to the Publisher.

9. Third-party libraries and components

The Application uses software libraries originating from third parties, responsible among other things for handling PDF documents, image processing, selecting files and photographs, and saving and sharing files.

A full list of the components together with the text of the relevant licences is available in the Application, in the “Licences” section.

For the sake of full transparency, the Publisher identifies three elements which are included in the installation package together with those libraries, even though they are not needed in order to perform the Application’s functions:

the WebView component, introduced by the library used to display PDF documents. The Application does not use this component to display content originating from the network or to transmit user data;
a query concerning applications capable of handling operations on selected text, added by the development framework in which the Application was built. Within this narrow scope the Application may obtain information as to which installed applications support that type of operation. The Application does not read the full list of installed applications in this way and does not pass such information to the Publisher or to any other entity.
the Google Play billing library, together with Google Play Services components, which handles the purchase of the full version of the App. This library introduces into the installation package components serving communication with the Google Play store, including Google’s transport layer. These components are active solely within the scope of handling the purchase and its restoration. The processing of data by the store operator in connection with the transaction takes place on terms determined by that entity — see Section 25.

10. No analytics, advertising or profiling

The Application does not contain its own analytics tools, advertising software development kits, tools tracking user behaviour or advertising profiling mechanisms.

The Publisher does not sell users’ personal data and does not make documents, signatures, initials or stamp data available to advertising partners or to data brokers.

The Publisher does not take, in relation to users, decisions based solely on automated processing which would produce legal effects concerning them or similarly significantly affect them.

11. Transfer of a document by the user to another application or service

The Application enables the user to transfer a prepared document to another application using the system sharing function, and also to save the document in a location chosen by the user.

The user may, in particular, choose an email application, a messaging application, a cloud service or another application handling the given type of file.

Once the user makes such a choice, the document leaves the Application’s domain. Further processing of the document takes place according to the rules of the entity operating the chosen application or service. If the user selects a save location belonging to an external service, the document may be transmitted to that service.

Such a transfer takes place solely on the user’s initiative. The Publisher does not control the further processing of the document and bears no responsibility for it.

12. Backups and transfer of the Application’s data

The Application has been configured so as to exclude its data from the backup and data transfer mechanisms provided by the Android system. The configuration covers disabling the backup of the Application’s data and rules excluding the Application’s data from cloud backups and from device-to-device transfers.

In practice this means that locally saved signatures, initials, stamp data, settings, working copies of documents and the state of unfinished work are not transferred automatically to a new device using the standard mechanisms of the Android system.

This is a deliberate choice by the Publisher, limiting the risk of the image of a signature ending up outside the user’s device. Its cost is the need to create the signature, initials and stamp again after changing device.

The operation of the system mechanisms may depend on the version of the Android system and on the solutions applied by the device manufacturer.

13. Storage and deletion of local data

The information referred to in section 5 is stored on the device until it is replaced or deleted. The Publisher does not set a separate storage period for it, because the Publisher has no access to it and cannot dispose of it.

The Application deletes data on its own in the following cases:

the contents of the Application’s temporary directory are deleted each time the Application is launched;
opening a new document results in the deletion of the working copy and of the work state relating to the previous document;
output files created by the Application in its private directory are deleted the next time the Application is launched. This does not apply to a document which the user has saved independently in a location of the user’s choice.

The user may at any time, without contacting the Publisher:

replace the saved signature or initials with a new image;
change or clear the stamp data;
use the function of resetting the security lock, if the Application provides one; this function deletes the saved signature, initials, stamp data, the remaining settings and the saved state of unfinished work;
delete the Application’s data using the settings of the Android system;
uninstall the Application.

Deleting the Application’s data or uninstalling the Application results in the permanent deletion of local data. The Publisher does not hold a copy of them and is not able to restore them.

14. Personal data received by the Publisher

The Publisher receives personal data primarily where the user contacts the Publisher of their own accord, in particular by email.

Depending on the content of the contact, the Publisher may receive:

an email address;
a first name, surname, business name or other data provided by the user;
the content of the message;
information contained in attachments;
other information provided voluntarily by the user.

The Publisher recommends that the user should not send in correspondence confidential information, special categories of data or documents containing third-party data, unless this is necessary in order to deal with the matter.

15. Purposes of and legal bases for processing

The Publisher processes data received in connection with contact for the following purposes and on the following legal bases:

replying to a message and conducting correspondence — Article 6(1)(f) GDPR, the legitimate interest of the Publisher consisting in communicating with persons who contact it;
dealing with a report, complaint or other request and providing technical support — Article 6(1)(b) GDPR, where processing is necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract, or Article 6(1)(f) GDPR in other cases;
compliance with obligations arising from the law, including obligations relating to the protection of personal data and accounting and tax obligations — Article 6(1)(c) GDPR;
establishing, pursuing or defending against claims — Article 6(1)(f) GDPR, the legitimate interest of the Publisher consisting in protecting its rights;
ensuring the security of the Application and preventing abuse — Article 6(1)(f) GDPR, the legitimate interest of the Publisher consisting in protecting the Application and its users.

Where, in a particular case, the basis for processing would be consent, that consent will be obtained separately and the user will be informed of the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

16. Voluntary nature of providing data

Using the Application does not require the user to provide the Publisher with any personal data.

Providing data in correspondence with the Publisher is voluntary. Providing a return address and information enabling the content of the report to be understood is, however, necessary in order to reply — without them it may prove impossible to deal with the matter.

17. Period of storage of data by the Publisher

The Publisher stores correspondence and other data received directly from the user for the period necessary to achieve the purpose for which they were provided.

Once the matter has been concluded, the data are stored for the period necessary to demonstrate how it was dealt with and to establish, pursue or defend against claims — no longer than until the expiry of the limitation period for claims arising under the applicable law.

Data for which the law provides for a mandatory storage period, in particular data covered by accounting and tax obligations, are stored for the period arising from those provisions.

Once the relevant period has expired, the data are deleted or stripped of features allowing the person concerned to be identified.

18. Recipients of data

Data received by the Publisher may be made available to the following categories of recipients, solely to the extent necessary to achieve the purposes set out in section 15:

providers of infrastructure and IT services, including the email service provider;
entities providing legal, accounting or advisory services, where this is necessary in order to establish, pursue or defend against claims, or to comply with obligations arising from the law;
public authorities and other authorised entities, where the obligation to disclose arises from the law or from a request of an authorised body issued on the basis of the law.

Information stored solely locally on the user’s device, including documents, signatures, initials and stamp data, is not made available to any of those entities, because the Publisher does not have it at its disposal.

19. Service providers

For the handling of email the Publisher uses hosting services provided by cyberFolks, insofar as that entity remains the provider of the office@jintsoftware.pl mailbox.

To the extent that the provider processes personal data on behalf of the Publisher, the processing takes place on the basis of an appropriate contractual arrangement, in accordance with Article 28 GDPR.

Should a provider material to the processing of data change, information to that effect will be included in an updated version of this Policy.

20. Transfers of data outside the European Economic Area

As regards data received directly from the user, the Publisher does not plan to transfer them to third countries or international organisations.

Should such a transfer prove necessary, it will take place solely by applying a mechanism provided for in Chapter V GDPR, and the user will be informed of the mechanism applied and of how to obtain a copy of the relevant safeguards.

21. Security

The Publisher applies technical and organisational measures appropriate to the nature, scope and risk of the processing of data under its control.

As regards information processed locally, the principal measure limiting risk is the architecture of the Application itself: the absence of a user account, the absence of a Publisher’s server and the absence of any mechanism for transmitting documents, signatures, initials and stamp data to the Publisher’s infrastructure.

If the Application provides a local security code function, that code is stored solely on the user’s device, is not transferred to the Publisher and is not stored in any set of data maintained by the Publisher.

The security of data stored locally also depends on the security of the device itself. The Publisher recommends using a screen lock, installing system security updates and not making an unlocked device available to unauthorised persons. The Publisher has no influence over the security of the device, the operating system or third-party applications.

22. The roles of the Publisher and of the user in relation to processing

The Publisher is the controller of personal data which it receives directly from the user, in particular data contained in correspondence addressed to the Publisher. Sections 14–21 and 23 of this Policy apply to those data.

As regards documents, signatures, initials, stamp data and other content processed by the user solely locally using the Application, the Publisher does not receive those data, does not store them in its systems and has no access to them. The Publisher does not use those data for its own purposes, in particular for analytics, advertising, profiling or the creation of any sets of data.

Who is the controller of personal data contained in a document prepared using the Application, and in what capacity those data are processed, depends on how they are used and on the circumstances of the particular case. The mere saving of a document on the user’s device does not determine controller status or the role of other entities involved in the processing.

Where the user uses the Application to process the personal data of other persons, the user is responsible for ensuring that such processing complies with the provisions applicable to the activity carried out by the user.

23. Rights of data subjects

To the extent that the GDPR applies to the processing concerned, the user has the right to:

access the data and obtain a copy of them (Article 15 GDPR);
rectification of the data (Article 16 GDPR);
erasure of the data (Article 17 GDPR);
restriction of processing (Article 18 GDPR);
data portability (Article 20 GDPR);
object to processing based on legitimate interest (Article 21 GDPR);
withdraw consent at any time, where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal (Article 7(3) GDPR);
lodge a complaint with a supervisory authority (Article 77 GDPR).

The scope of each right depends on the legal basis for and the circumstances of the particular processing.

Requests concerning data under the Publisher’s control should be sent to office@jintsoftware.pl. The Publisher may take reasonable steps to confirm the identity of the person making the request.

Requests concerning information stored solely on the device are carried out by the user independently, on the terms described in section 13. The Publisher is not able to remotely provide, rectify or erase information to which it has no access.

24. Supervisory authority

A data subject may lodge a complaint with the supervisory authority competent for their habitual residence, place of work or the place of the alleged infringement.

In Poland the supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych). Information on how to lodge a complaint and the authority’s current contact details are available on its official website: https://uodo.gov.pl

25. Google Play

The Application is distributed through the Google Play store.

Google may, independently of the Publisher, process information relating to the user’s Google account, the device, the installation of the Application and the use of the store, including for diagnostic and security purposes. That processing takes place on the terms established by Google and remains outside the Publisher’s control.

The information on data handling which the Publisher provides in the “Data safety” section in Google Play corresponds to the content of this Policy.

26. Children and minors

The Application is not directed at children.

The Publisher does not intend knowingly to collect through the Application personal data of children in a manner requiring the consent of a parent or legal guardian. Where the law in force in a given jurisdiction requires the consent of a parent or legal guardian, or provides for other specific requirements concerning the processing of minors’ data, those requirements apply.

If the Publisher becomes aware that it has received a child’s data in circumstances in which their further processing is not permitted without the required consent or another legal basis, it will take the steps required by the applicable law.

27. Users in other jurisdictions

Users located outside the European Economic Area may have additional or different rights arising from local law, including from privacy laws in force in certain states of the United States.

The Publisher does not sell users’ personal data and does not use them for cross-context behavioural advertising.

A user to whom local law grants additional rights may contact the Publisher at office@jintsoftware.pl. The request will be dealt with in accordance with the law applicable to the particular case.

28. The nature of a signature placed using the Application

The Application is a tool making it possible to place in a PDF document the image of a signature or initials, as well as a stamp and other information.

The mere use of the Application does not result in the document being provided with a qualified electronic signature, an advanced electronic signature or any other signature having a specific legal status.

The legal effect of a document depends, among other things, on the applicable provisions, the type of document, the requirements laid down for the given legal act and on arrangements between the parties.

The assessment of whether the manner of signing a document using the Application is sufficient for a particular document or a particular legal act rests with the user.

29. Changes to the Application and to the Policy

The Application is being developed and its subsequent versions may introduce new functions.

If a change in the way the Application operates affects the scope or manner of data processing, this Policy will be amended accordingly and made available together with the version of the Application to which it relates.

The current version of the Policy is available in the Application and at: https://jintsoftware.pl/arasign/polityka-prywatnosci

In the event of a change materially affecting the user’s rights, the Publisher will provide notice of it in the manner required by the applicable law.

30. Final provisions

This Policy describes how the Application operates in the version indicated in the header and the rules on data processing by the Publisher in force from the effective date of the Policy.

Rights vested in the user under mandatory provisions of law remain unaffected.

This Policy has been drawn up in the Polish language. The Polish version is the original version. Versions in other languages are translations made available in order to ensure that the information is comprehensible.

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