Version Date:  27 October 2025 

Purpose  

The purpose of this document is to set out how Assentiri Pte. Ltd. and its affiliates (“Assentiri”, “us,” “our,” or “we”) collect, use, store, or otherwise process personal information about customers and other individuals (collectively "you") who access or use our websites, including without limitation assentiri.com and portal.assentiri.com, and/or any of our other websites, products, or services that link to this Privacy Notice, including without limitation the Assentiri app (the “Services”). By using our Services, you understand that we will collect and use your personal information as described in this Privacy Notice. 

In some cases, we may process your personal information pursuant to an agreement with a third-party organization. In those cases, the terms of that agreement may govern how we process your personal information. 

Assentiri’s core product and Services facilitate commercial transactions between buyers, sellers and other stakeholders. As part of our Services, users want us to collect and record information that helps the parties carry out the transactions, such as the names, identity details, residential addresses and e-mail addresses of the persons who are involved in the transactions. 

1. Collection of Personal Information 

Personal Information We Collect from You.  You provide us with personal information about yourself when you: 

• Register or log in to your account. 

• Start, sign, or review an electronic document. 

• Create or edit your user profile. 

• Contact Assentiri directly. 

• Participate in surveys, or when you sign up for newsletters. 

Your main choice for this type of personal information is simply not providing it, such as by not creating a user profile. 

Examples of the categories of personal information you may provide are: 

• Identifiers and Contact Information. This includes your name, email address, mailing address, phone number, or electronic signature. 

• Commercial Information. This includes billing and payment information (e.g., credit card number, expiration date, visual cryptogram), and products or services purchased. 

• Your Account Data. This includes your login information (email and password) and user profile information (contact details, including your name, email address, and photo (if uploaded)). 

• Other Contacts Data. When you grant us permission, information about your authorized contacts (e.g., name, email address) and an image of the contact (if uploaded) on your device that can be used to save as their profile image on your account. 

• Customer Service and Communications Information. This includes questions and other messages or feedback you address to us directly through online forms, by email or via our feedback surveys or customer support channels. If you use any of our chat features we may use to communicate with you, we may collect personal information you voluntarily provide during your interactions, such as your name, email address, contact details, or any other information you choose to share and retain a transcript of your chats for the purposes set forth in this Notice. 

Personal Information We Collect Automatically. We may automatically collect personal information from you and your devices when you use our Services, including when you visit our websites or apps without logging in. 

We collect personal information about how you use our Services and the devices (e.g., computers, mobile phones, tablets) you use to access our Services. This may include, but is not limited to, the following: 

• Device Data. This includes IP address, unique device identifiers, and device attributes, such as operating system and browser type. 

• Usage Data. This includes web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date(s) and time(s) you used our Services, the frequency of your use of our Services, error logs, and other related information. 

• Transactional Data. This includes IP addresses and authentication methods of parties to a transaction, subject line, history of actions that individuals take in connection with a transaction (e.g., review, sign, enable features), and information about those parties’ devices. 

• Marketing and Advertising Data. This includes your interests based on your use of our Services and other websites and online services, preferences in relation to receiving marketing materials from us, communication preferences, and your preferences for particular products and services. 

Some of the information we collect automatically is captured using cookies, which are text files containing small amounts of information that are downloaded on your device or related technologies, such as web beacons, local shared objects, and tracking pixels, to collect and/or store information. 

Personal Information We Collect from Other Sources. Subject to applicable law, we may collect personal information about you from others, such as: 

• Third-Party Sources. Examples of third-party sources include partners, affiliates, service providers, and others where they are legally allowed to share your personal information with us.  

• Third-Party Integrations. Third party integrations may access data or send information to and from your Assentiri account. It is your responsibility to review any third-party integrations you authorize. 

• Other Customers. Other customers may give us your personal information. For example, if a customer wants you to sign an electronic document in our Services, he or she will give us your email address and name. 

• Combining Personal Information from Different Sources. We may combine the personal information we receive from other sources with personal information we collect from you (or your device) and use it as described herein. 

Personal Information We Collect & Process on Behalf of Customers. When our business customers use certain Services, we generally process and store limited personal information on their behalf as a data processor. For example, when a customer uploads contracts or other documents for review or signature, we act as a data processor and process the documents on the customer's behalf and in accordance with their instructions. In those instances, the customer is the data controller and is responsible for most aspects of the processing of the personal information. 

2. Use of Personal Information and Lawful Bases for Processing 

In general, and subject to applicable law, we will use your personal information to provide, maintain, and improve our Services, develop new Services, and market our products and Services.  

Lawful Basis for Processing Your Personal Information. If applicable data protection law requires a lawful basis for processing, and where Assentiri acts as a data controller, our lawful basis for collecting and using the personal information described in this Notice will depend on the type of personal information concerned and the specific context in which we collect or use it. 

We normally collect or use personal information only where we need the personal information to perform a contract with you or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or may need the personal information to protect your vital interests or those of another person. In certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data.  

If we process sensitive personal information about you, as well as ensuring that one of the lawful bases referenced above applies, we will make sure that one or more of the grounds for processing sensitive personal information applies. 

Note that in situations where Assentiri acts as a processor, it is our customer who determines the appropriate legal basis associated with processing activities, and queries about the applicable lawful basis should be directed to them. 

Other Uses. We may aggregate the personal information we collect, or insights generated or derived from the use of our Services, or remove pieces of personal information (“de-identify”) to limit or prevent identification of any particular user or device to help with goals like marketing, research and product development (including training our artificial intelligence models that power certain of our Services). Where such information has been aggregated and anonymized so that it is no longer considered personal information under applicable data protection law, this Notice does not apply. 

3. Disclosures of Personal Information 

Subject to applicable law, including to the extent applicable law requires us to obtain consent, we may disclose personal information as follows: 

• Service Providers. We disclose your personal information to service providers we use to support our Services.  

• Public or Government Authorities. We may disclose your personal information to comply with our legal obligations, regulations, or contracts, or to respond to a court order, administrative, or judicial process, such as a subpoena, government audit, or search warrant where we are legally compelled to do so.  

• Consent. We may disclose your personal information in other ways if you have asked us to do so or have given consent. For example, with your consent, we post user testimonials that may identify you. 

Your personal information may also be disclosed as described below: 

• Other Assentiri users. When you are part of a transaction, other users may be granted access to your personal information such as e-mail address or passport copy. For example, if you are an Attorney in Fact for an entity, we may make your details available to other transaction stakeholders. 

• Profile Information. When you create an Assentiri profile, other Assentiri users can view your profile information.  

• Your Employer or Organization. When you create an account or user role with an email address assigned to you as an employee, contractor, or member of an organization (e.g., yourname@youremployer.com), that organization (if it is an Assentiri customer with certain features) can find your account and take certain actions that may affect your account. 

4. Retention of Personal Information 

We keep your personal information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain personal information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws as set out in our data retention policy and information handling standards. Generally, this means we retain your personal information to comply with any retention compliance obligations or statutory requirements or for purposes of performing a contract with you. Where there are technical limitations that prevent deletion or anonymization, we safeguard personal information and limit active use of it through implementing appropriate organizational technical and security measures. 

5. Your Privacy Rights and Choices 

Rights Regarding Your Personal Information. You may have certain rights related to your personal information, subject to local data protection laws, as described in more detail below.  

• You have a right to correct inaccurate personal information about you, and you should notify us immediately if you believe the personal information we hold about you is inaccurate, incomplete, or out-of-date. 

• In certain situations, you can ask that we erase or stop using your personal information, object to or restrict the use of your personal information, or export your personal information to another controller.  

• Where we rely on your consent to process your personal information, you have the right to decline consent and/or, if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. At any time, you can request that we stop using your personal information for direct marketing purposes. 

Certain personal information may be exempt from such requests under applicable law. We need certain types of personal information so that we can provide the product and Services to you. If you ask us to delete it, you may no longer be able to access or use our product and Services. 

6. How to Contact Us 

For questions or complaints regarding our use of your personal information or this Notice, please contact us at assentiri.com/contact or by sending a letter to Assentiri Pte. Ltd., Attention: Privacy Team, 56A Boat Quay, Singapore 049845.