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Priva6 is operated by SASU PDFShift, a French company, and is designed for the GDPR from the ground up: the data needed to sign and prove a signature, nothing more, hosted in the European Union.
Who is responsible for what
| Data | Controller | Processor |
|---|---|---|
| Your clients, signers, their signatures and the documents you send | You, the organization using Priva6 | SASU PDFShift (Priva6) |
| Your account, your team members and your workspace settings | SASU PDFShift (see our Privacy Policy) | Not applicable |
As your processor, we only process your clients' and signers' personal data on your documented instructions, which are given by your use of the Service and by these terms.
What is recorded when someone signs
Signing records the IP address, country, browser and signature. Under GDPR, signers must be told about this, usually with a privacy notice link next to the "I agree" checkbox. That "I agree" also shouldn't be read as GDPR consent.
In detail, for each signer, Priva6 records:
- the email address the signing link was sent to, and the name;
- the details you chose to request: company, position, department, company address, website, VAT and registration numbers, phone, and the primary signer's initials;
- the signature: typed, drawn or uploaded as an image (whose metadata, such as location, is removed), and the signing date;
- the exact consent text the signer agreed to;
- evidence: IP address, country (derived from the IP address, no precise location), browser and operating system names (from a fixed list, not a full fingerprint), and when the document was sent, viewed and signed. A view is only recorded after a real interaction with the page, so automated email scanners are not counted.
All of this appears in the audit trail sent, with the signed PDF, to every party once everyone has signed.
Informing signers
Every signing and review page links to a privacy notice, next to the "I agree" checkbox, that explains what is collected, why, who receives it, how long it is kept and how to exercise their rights. We recommend that you also mention electronic signature in your own privacy policy, as the controller of this data.
The "I agree" checkbox is not GDPR consent
Signers tick a checkbox to agree to sign electronically and to receive the signed document electronically. This is part of forming the agreement; it is not consent to the processing of personal data within the meaning of Article 6(1)(a) GDPR, and must not be presented or relied upon as such. Consent could be withdrawn at any time, which would be incompatible with keeping evidence of a signature.
The processing of signers' data generally relies on:
- Article 6(1)(b) GDPR: the performance of the contract being signed, or steps taken at the signer's request before entering into it;
- Article 6(1)(f) GDPR: the legitimate interest of the parties in being able to prove the signature, who signed and when.
As the controller, you are responsible for determining and documenting the legal basis that applies to your documents.
Our commitments as your processor
These commitments form our data processing terms under Article 28 GDPR and are part of our Terms of Service. We will:
- process personal data only on your documented instructions, including for international transfers, unless required by law, in which case we will tell you first, unless the law forbids it;
- ensure that the people authorized to process the data are bound by confidentiality;
- implement appropriate technical and organizational security measures (Article 32), described below;
- only engage subprocessors under a written contract imposing the same data protection obligations, keep the list of subprocessors up to date, and inform you of any intended change so that you can object;
- assist you in responding to requests from data subjects exercising their rights;
- assist you in ensuring compliance with your security, breach notification, impact assessment and prior consultation obligations;
- notify you of any personal data breach affecting your data without undue delay after becoming aware of it, with the information you need to meet your own obligations;
- at the end of the Service, delete your personal data (after giving you the opportunity to download your signed documents), unless the law requires us to keep it;
- make available the information necessary to demonstrate compliance with these obligations, and allow for and contribute to audits, under reasonable notice and confidentiality conditions.
If you need a countersigned Data Processing Agreement, write to privacy@priva6.com.
Description of the processing
| Item | Description |
|---|---|
| Subject matter | Providing the Priva6 Service: drafting, sending and electronic signature of documents, with their audit trail |
| Duration | The term of your use of the Service, then the retention periods below |
| Nature and purpose | Hosting, sending emails, collecting signatures, generating signed PDFs and audit trails, generating AI explanations of document sections, keeping evidence |
| Data subjects | Your clients, signers and any person named in your documents |
| Categories of data | Identity and contact details, professional details, signatures and initials, consent text, IP address, country, browser and operating system names, timestamps, document content |
| Special categories | None by design. Don't include special categories of data in your documents unless necessary, and only on a valid legal basis |
Retention
- Signed documents and their audit trails are kept as long as your organization keeps its Priva6 account, and cannot be altered or deleted in the meantime: they are legal records. Each party keeps its own copy.
- Unsigned documents and pending requests are kept until you delete them.
- Once a link has been used or has expired, it reveals nothing but its status.
- Our email provider keeps the content of emails for 45 days.
Security measures
- Database and files hosted in the European Union (Ireland); encrypted connections (TLS).
- Isolation of each organization's data by row-level security, with admin, editor and reader roles.
- Signing, review and preview links are 256-bit random tokens; only their SHA-256 fingerprint is stored, as for API keys.
- Signing pages served from a separate domain, under a strict Content Security Policy; document content is sanitized; no third-party scripts, no remote images.
- Integrity: SHA-256 fingerprints of the signed content and of every annex, checked before the signed PDF is generated; append-only, hash-chained audit log.
- Minimization: no tracking, analytics or advertising; browser names only; country only; image metadata removed; sign-up data purged automatically.
- Rate limits on sign-ups, emails and the API.
More details on our Security page.
International transfers
Our main infrastructure is in the European Union. When a subprocessor is located outside the European Economic Area, transfers rely on an adequacy decision or on the European Commission's Standard Contractual Clauses, with additional measures where needed. Locations are listed on our Subprocessors page.
Exercising rights
Signers and clients should contact the organization that sent them the document, as the controller. If they contact us, we forward their request to you without delay and help you answer it. Where the data is needed as evidence of a signature, some rights (such as erasure) may be limited for as long as the signed document is kept.
Contact
Privacy questions: privacy@priva6.com, SASU PDFShift, 128 rue La Boétie, 75008 Paris, France.
Our lead supervisory authority is the French data protection authority, the CNIL.