01
Who we are, and our role
This policy is issued by Carousify Private Limited, a company incorporated in India with its registered office at A-266, Triveni Nagar, Jaipur 302018, Rajasthan, India (“Carousify”, “we”, “us”). Carousify owns and operates Signibility (the “Service”).
It covers everyone whose personal data the Service handles, and our role differs between two groups:
- Account holders and visitors. For data about people who create an account, belong to a workspace, pay for a plan or visit our website, we decide why and how it is processed. We are the Data Fiduciary under the Digital Personal Data Protection Act, 2023 (DPDP Act) and the controller under the GDPR.
- Signers and document recipients. When a workspace sends a document, that workspace decides what the document contains and who receives it. For the document, its field values and the recipient details the sender entered, the sending workspace is the Data Fiduciary or controller, and we process that data on its instructions as a Data Processor or processor. Requests about such a document should go to the sender first. If you cannot reach them, write to us and we will help.
This policy should be read with our Terms of Service, GDPR page and Security page.
02
What we collect
Account holders
- Identity and contact: name, email address and, if you add them, phone number, job title and profile photo.
- Sign-in data: a hash of your password (never the password itself), or the public key of a passkey; failed sign-in counts and lock times; connected Google sign-in identifiers.
- Workspace data: workspace name, your role, plan, seats, branding (logo, website, custom domain) and, if a workspace connects its own mail server, those settings in encrypted form.
- Answers you give us: onboarding answers such as how you heard about us and what you intend to use the Service for, and, if you cancel, the reason you choose and any detail you type.
- Preferences: time zone, date format and notification and email settings.
- Billing references: the subscription and customer identifiers issued by our payment provider, plan and payment status. We never receive or store your card or bank details; see Lemon Squeezy below.
- Correspondence: emails you send us and our replies.
Signers and recipients
- Name and email address, as entered by the sender.
- A mobile number, only where the sender requires SMS verification.
- Everything typed into the document’s fields, the signature you draw, type or upload, the time you consented to sign electronically, and your reason if you decline.
- Where a share link restricts viewing to named people, the viewer’s email address.
Everyone
- Documents and files uploaded to the Service, and their file names.
- Technical and evidence data recorded against every action on a document: IP address, the forwarding headers our network adds to identify that address, browser user-agent and time. See the audit trail.
- Website usage data: aggregate, cookieless page-view measurement through Cloudflare Web Analytics, and, if you arrive through an affiliate link, an affiliate referral identifier. See cookies.
We do not collect sensitive categories of data on purpose, such as health, biometric or financial account data. If a document you upload or sign contains such data, it is processed only as part of that document, on the sender’s instructions. Passkey biometrics are checked by your own device and never reach us.
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Why we use it, and on what legal ground
| Purpose | Data used | Legal ground |
|---|---|---|
| Create and run your account, workspace and plan; send, sign and seal documents | Account, workspace, document and recipient data | Performance of our contract with you (GDPR Art. 6(1)(b)); your consent and use for the specified purpose you gave the data for (DPDP ss. 6–7) |
| Take payment and manage subscriptions | Billing references, plan, workspace name, email | Contract; legal obligations on tax and accounting records |
| Produce evidence of who signed what, when and from where | Audit trail and technical data | Legitimate interests of the sender and every signer in a provable record (GDPR Art. 6(1)(f)); use for the purpose the signer provided it for (DPDP s. 7(a)) |
| Keep the Service secure: rate limits, account lockout, bot checks, fraud and abuse prevention, error diagnostics | Sign-in data, IP address, technical data | Legitimate interests; legal obligations, including under the Information Technology Act, 2000 and CERT-In directions |
| Transactional email: sign-in codes, signing invitations, receipts, security and deletion notices, billing alerts | Name, email, document title | Contract; legitimate interests. These cannot be switched off while you hold an account |
| Product updates and tips and offers email | Name, email, plan and usage milestones | Consent, or for existing customers our legitimate interest in telling you about similar services. Withdraw any time with the unsubscribe link in every such email or in Account settings |
| Understand how the product is found and used, in aggregate | Onboarding answers, cookieless page-view counts | Legitimate interests |
| Comply with law, respond to lawful requests, and establish, exercise or defend legal claims | Any data relevant to the matter | Legal obligation; legitimate interests; GDPR Art. 17(3)(e); DPDP s. 7 |
Marketing email, stated plainly: “Product updates” is off until you switch it on. “Tips and offers” is on by default for account holders, and you can switch it off at any time with one click. Signers who never created an account receive no marketing email from us.
We do not use personal data or document content to train artificial intelligence models, we do not make decisions about you by solely automated means that have legal or similarly significant effects, and we do not sell or rent personal data.
04
Your documents
Every file stored by the Service, including documents, signatures, profile photos and workspace logos, is encrypted with AES-256-GCM under a key unique to that file before it is written to storage. Each file key is itself encrypted by a master key held separately from the storage.
- We do not read your documents. Our internal admin tools show document titles, statuses and counts, and cannot display a document’s contents.
- Technical access exists, and we limit it. Because the Service must render and seal your documents, the application can decrypt them. A person with privileged access to our production systems could therefore technically do the same. We do so only where required by law, or where you ask us to investigate a specific problem and authorise it.
- The database is not encrypted at the application layer. Names, email addresses, IP addresses and field values are stored as ordinary database records, protected by access controls rather than by field-level encryption. Passwords, session tokens, sign-in codes and API keys are stored only as hashes. Third-party credentials, connected-account tokens and mail-server settings are encrypted.
05
The audit trail
A signature is only as useful as the evidence behind it. Every meaningful action on a document, including sent, opened, consented, verified, signed, declined and voided, is written to a hash-chained audit trail.
- Each entry records the actor’s name and email as they were at that moment, their IP address, forwarding headers, browser user-agent and time.
- The completed document’s certificate shows these details, including IP addresses, and is delivered to every party. Other signers can therefore see where you signed from. This is disclosed to you before you sign.
- Entries cannot be edited. The database rejects any change to them, including by us. An individual entry cannot be corrected or redacted; it can only be removed by deleting the entire document it belongs to.
07
Services we use
We share personal data only with the service providers below, each bound by contract to use it solely to provide its service to us, and with no one else except as required by law.
| Provider | Purpose and data received | When |
|---|---|---|
| Cloudflare | Network, DDoS protection and TLS for our website and app; sees IP addresses and request data in transit. Cookieless page-view analytics. | Every visit |
| Cloud hosting and object storage providers | Run our servers and database; store files, which reach storage already encrypted by us. | Always |
| Email delivery provider | Recipient address, name and the message, which may name the sender and document title. | Every email we send |
| Lemon Squeezy | Our Merchant of Record. Processes payments, calculates and remits tax, issues invoices and handles refunds. Receives your name, email, billing address and payment details directly at checkout under its own privacy policy; receives your workspace reference from us. | When you buy, change or cancel a paid plan, or arrive through an affiliate link |
| reCAPTCHA: IP address and browser signals. Google sign-in: identity returned from your Google account if you choose it. | Protected forms; only if you choose Google sign-in | |
| Dropbox | Access you grant to list and import the files you pick. | Only if you connect it |
| Twilio | A signer’s mobile number, to deliver a verification code. | Only if the sender requires SMS verification |
| Timestamp authority | A cryptographic hash of the sealed document, never the document. | When a document is sealed, where timestamping is enabled |
| Sentry | Error reports to diagnose faults, configured not to attach cookies, user details or local variables, though a report can include the page address and technical context of the fault. | When an error occurs, where enabled |
Customer-controlled destinations. A workspace may send its email through its own mail server, or serve signing pages on its own domain. Where it does, messages and page requests pass through infrastructure that the workspace controls and is responsible for.
We may also disclose personal data where required by law, court order or a lawful request from a government authority; to protect the rights, safety or property of our users or the public; or to a successor in a merger, acquisition or sale of assets, which would remain bound by this policy.
08
Transfers outside your country
Carousify is based in India. Our service providers operate servers in other countries, including the United States and member states of the European Union, so your data may be processed outside the country where you live.
- For transfers out of India, we transfer only to countries not restricted by the Central Government under section 16 of the DPDP Act.
- For personal data from the EU, EEA, UK or Switzerland, we rely on adequacy decisions, the EU–US Data Privacy Framework where a provider is certified, or standard contractual clauses published by the European Commission or UK authorities.
09
How long we keep things
| Data | How long |
|---|---|
| Account, profile and preferences | While the account exists; deleted 30 days after you ask us to delete the account |
| Completed and declined documents, with their audit trails | Kept as records for as long as the workspace exists, and after account deletion where needed to establish or defend legal claims (see what erasure deletes) |
| Drafts, in-progress and voided documents | Until deleted, and with the account |
| Documents moved to trash | 30 days, then permanently deleted with their files |
| Signing links | Expire after 120 days, or 48 hours after the document completes |
| Share links | Until revoked, or until the expiry the owner sets (up to one year) |
| Sign-in codes | 10 minutes; password reset links 1 hour; email sign-in links 24 hours; cleared shortly after expiry |
| Sessions | 7 days, or 30 with “Remember me”; expired records deleted 45 days later |
| Workspace invitations | 7 days |
| In-app notifications | 90 days after being read, or 365 days if unread |
| Billing and tax records | As long as required by Indian tax and company law, generally 8 years; payment records held by Lemon Squeezy under its own policy |
| Email campaign send records | Until the account is deleted |
When an account is deleted we remove it from live systems. Copies in backups and logs held by our infrastructure providers are overwritten in their normal cycles and are not restored except to recover from an incident.
10
How we protect it
We use reasonable security practices and procedures appropriate to the nature of the data, including:
- AES-256-GCM encryption of every stored file under a per-file key, and TLS for all data in transit, with HSTS on our app.
- Passwords hashed with Argon2id; passkeys (WebAuthn) supported; accounts locked after repeated failed sign-ins; sign-in rate limits and, on protected forms, reCAPTCHA.
- Sessions, sign-in codes and API keys stored only as hashes; third-party credentials encrypted.
- Completed PDFs sealed with a digital signature, and an audit trail hash-chained and protected against edits at the database.
- Role-based access inside workspaces, cross-site request protection and strict browser security headers.
- Automated checks of our software dependencies for known vulnerabilities.
No method of transmission or storage is completely secure, and we cannot guarantee absolute security. The Security page describes these measures, and what we have not yet done, in more detail.
Personal data breaches. If a breach affects your personal data, we will notify you and the relevant authorities, including the Data Protection Board of India, CERT-In and, where the GDPR applies, the competent supervisory authority, within the time and in the manner the law requires. Where we are processing for a workspace, we will inform that workspace without undue delay so it can meet its own duties.
11
Your rights
Subject to applicable law, you have the right to:
- Access the personal data we hold about you and information about how it is processed;
- Correct, complete or update it;
- Erase it, subject to the limits below;
- Withdraw consent at any time, as easily as you gave it, without affecting processing before withdrawal;
- Object to or restrict processing based on legitimate interests, and object to direct marketing at any time;
- Data portability: receive your data in a structured, machine-readable format;
- Nominate another person to exercise your rights in the event of your death or incapacity (DPDP Act s. 14); and
- Grievance redressal, and to complain to a regulator (see below).
Much of this is self-serve: Account settings lets you edit your profile, export your data as a JSON file and schedule deletion of your account. For anything else, email [email protected]. We may need to verify your identity before acting, and we will respond within the time the law allows, and in any case within 30 days.
Limits we apply. An audit trail entry cannot be edited or partly redacted. We may retain a completed or declined document, and its audit trail, despite an erasure request where it is needed to comply with law or to establish, exercise or defend legal claims, because it is also the other parties’ evidence. If you signed a document as a guest, the sending workspace controls that document, and we will pass your request to it.
California residents: we do not sell or share personal information for cross-context behavioural advertising, and you will not be discriminated against for exercising your privacy rights.
12
Children
The Service is not intended for anyone under 18. We do not knowingly collect personal data from children. By accepting the Terms of Service, account holders confirm that they are at least 18. If you believe a child has given us personal data, contact us and we will delete it.
13
Grievance Officer and complaints
Complaints and requests about your personal data, or about this policy, can be sent to our Grievance Officer:
- Grievance Officer, Signibility (Carousify Private Limited)
- Email: [email protected]
- Post: A-266, Triveni Nagar, Jaipur 302018, Rajasthan, India
We acknowledge complaints within 48 hours and aim to resolve them within 30 days. If you are not satisfied with our response, you may complain to the Data Protection Board of India. If you are in the EU, EEA or UK, you may also complain to your local data protection supervisory authority. We would welcome the chance to address your concern first.
14
Changes to this policy
We may update this policy as the Service or the law changes. The date at the top shows the latest version. If a change materially affects how we use personal data, we will tell account holders by email or in the app before it takes effect, and where the law requires consent we will ask for it again.