Privacy Policy

JHS Solutions LLC ("Company," "we," "our," or "us") values the privacy and trust of every individual and organization that uses the Portal Platform and its related products and services.

This Privacy Policy explains how the Company collects, uses, stores, protects, shares, retains, and otherwise processes information in connection with the operation of the Platform.

This Privacy Policy applies to all current and future products, services, websites, applications, APIs, communications, artificial intelligence services, document workflows, verification services, enterprise offerings, and related technologies operated by the Company unless a separate privacy notice expressly states otherwise.

This Privacy Policy should be read together with the Master Terms of Service (LEGAL-001) and the other documents within the Portal Platform Legal Suite™. Where these documents address the same subject matter, they are intended to complement one another.

1.1 Purpose

JHS Solutions LLC is committed to respecting the privacy, confidentiality, integrity, and security of the information entrusted to the Company.

This Privacy Policy explains how the Company collects, receives, creates, uses, stores, secures, discloses, transfers, retains, and otherwise processes information in connection with the operation of the Platform.

The Company's objective is to process information responsibly while providing secure, efficient, and innovative technology services.

1.2 Scope

This Privacy Policy applies to all current and future services operated by the Company, including but not limited to:

Portal Platform™

Customer Portal

Signer Portal

Administrator Portal

Enterprise Portal

Client Portal

Mobile Applications

Desktop Applications

APIs

Developer Services

Artificial Intelligence Services

Future Platform Modules

eSignare®

Electronic Signatures

Document Preparation

Digital Agreements

Customer Workspace

Trust Center™

Certificate of Completion™

Dispatch Center™

Verification Services

Templates

Enterprise Services

Future Services

Where offered, this Privacy Policy shall also apply to:

eSignare Notary™

In-Person Electronic Notarization (IPEN)

Remote Online Notarization (RON)

Credential Analysis

Identity Proofing

Electronic Journals

Video Recording

Audio Recording

Artificial Intelligence Services

Chat Assistants

API Services

Future Products

1.3 Persons Covered

This Privacy Policy applies to information relating to:

visitors;

customers;

signers;

administrators;

enterprise organizations;

developers;

contractors;

vendors;

business partners;

governmental entities;

nonprofit organizations;

educational institutions;

customer support users;

API users;

mobile application users;

future Platform users.

1.4 Information Covered

This Privacy Policy governs the processing of information including, without limitation:

personal information;

business information;

organizational information;

documents;

communications;

authentication information;

billing information;

payment-related information;

verification information;

artificial intelligence interactions;

customer support information;

metadata;

audit information;

technical information;

device information;

browser information;

future categories of information processed by the Platform.

1.5 Privacy Principles

The Company strives to operate in accordance with the following privacy principles:

transparency;

accountability;

security;

confidentiality;

integrity;

lawful processing;

responsible innovation;

data minimization where appropriate;

operational necessity;

user trust;

continuous improvement.

These principles guide the Company's privacy practices but do not create obligations beyond those imposed by applicable law or this Privacy Policy.

1.6 Relationship to Other Legal Documents

This Privacy Policy should be read together with:

LEGAL-001 — Master Terms of Service;

Communications Policy;

Security Policy;

AI Services Policy;

Cookie Policy;

Electronic Signature Disclosure;

Trust Center™ Policy;

Record Retention Policy;

Enterprise Terms;

Developer & API Terms;

any additional legal documents incorporated by reference.

Where two documents address the same subject matter, they should be interpreted together whenever reasonably possible.

1.7 Geographic Scope

The Platform is operated from the United States.

Information may be processed in the United States or in other jurisdictions where the Company, its affiliates, cloud providers, service providers, or technology partners operate, subject to applicable legal requirements and appropriate safeguards.

The availability of specific services and the manner in which information is processed may vary depending on the user's jurisdiction and applicable law.

1.8 Changes to this Privacy Policy

Technology, legal requirements, business operations, and Platform functionality continue to evolve.

Accordingly, the Company may update this Privacy Policy from time to time to reflect:

changes in services;

changes in applicable law;

improvements in security;

new Platform features;

additional communication methods;

artificial intelligence enhancements;

enterprise functionality;

future technology offerings.

When required by applicable law, the Company will provide notice of material changes through reasonable electronic means before the revised Privacy Policy becomes effective.

1.9 Contact for Privacy Questions

Questions regarding this Privacy Policy or the Company's privacy practices may be submitted to:

JHS Solutions LLC

Email: support@esignare.com

Support is available for matters including:

Privacy Requests

Personal Information

Data Access Requests

Data Correction Requests

Data Deletion Requests

Data Portability Requests

Privacy Questions

General Customer Support

Additional contact methods may be published through the Portal Platform™ from time to time. Where required by applicable law, the Company may designate a privacy contact or representative to assist with privacy-related inquiries.

1.10 Commitment to Continuous Improvement

The Company recognizes that privacy expectations, technology, and legal requirements evolve over time.

Accordingly, the Company is committed to periodically reviewing and improving its privacy practices, internal controls, security safeguards, vendor management, employee awareness, and information governance processes to support responsible stewardship of information.

2.1 General Principles

The information collected by the Company depends upon the services used, the manner in which the Platform is accessed, applicable legal requirements, user preferences, subscription level, and future Platform functionality.

Not every category of information described in this Privacy Policy is collected from every User.

The Company seeks to collect only information that is reasonably necessary to provide, secure, improve, administer, or lawfully operate the Platform.

2.2 Information You Provide

The Company may collect information that Users voluntarily provide when interacting with the Platform.

Such information may include:

full name;

business name;

organization name;

mailing address;

billing address;

email address;

mobile telephone number;

office telephone number;

job title;

department;

professional credentials where applicable;

account preferences;

communication preferences;

language preferences;

profile photographs where uploaded;

signatures;

initials;

documents;

templates;

uploaded files;

customer support requests;

survey responses;

feedback;

feature requests;

any other information voluntarily submitted through the Platform.

2.3 Account Information

When creating or managing an account, the Company may collect:

username;

encrypted password credentials;

password reset information;

Multi-Factor Authentication enrollment;

authenticator application information;

recovery methods;

account status;

subscription level;

account identifiers;

Workspace identifiers;

organization identifiers;

API credentials where applicable;

administrative settings.

Passwords are stored using secure cryptographic methods and are not retained in plain text.

2.4 Identity Verification Information

Where identity verification services are provided or required, the Company or its authorized service providers may process:

government-issued identification information;

identity verification results;

credential analysis results;

authentication results;

knowledge-based authentication results;

verification status;

verification timestamps;

future identity verification information.

Additional information may be collected where required by applicable law or the specific service requested.

2.5 Documents and Files

The Platform may process documents and related files uploaded by Users, including:

contracts;

agreements;

disclosures;

forms;

affidavits;

acknowledgments;

attachments;

exhibits;

templates;

images;

PDF files;

office documents;

electronic records;

future file formats supported by the Platform.

Users remain responsible for determining whether uploaded documents contain confidential, regulated, or sensitive information.

2.5A Encrypted Document Content and Keys

The Platform may receive document content in plaintext for standard workflows or as ciphertext for an expressly activated Customer-Controlled Encryption workflow.

For a Zero-Knowledge Enabled Service, supported content is intended to be encrypted on the authorized User's device before server storage. The Company processes the encrypted file, encrypted key envelopes, integrity values, and operational metadata but is not intended to possess the content-decryption key.

Zero-Knowledge protection applies only to a service or workspace expressly identified as enabled. General references to encryption, privacy, confidentiality, or secure storage do not mean that every Platform workflow is Zero-Knowledge.

An Enterprise Customer may elect to maintain its own organizational recovery key. The Company does not control that key and may be unable to recover plaintext content if all Customer and participant recovery methods are lost.

2.6 Electronic Signature Information

Where Users execute electronic signatures through the Platform, the Company may process:

signature images;

initials;

typed signatures;

signature timestamps;

authentication events;

signing sequence information;

intent-to-sign confirmations;

signature placement coordinates;

document identifiers;

future electronic signature metadata.

The Company records such information to facilitate electronic workflows and generate Platform audit records.

2.7 Communications

The Platform may process communications exchanged through or with the Platform, including:

email communications;

SMS messages;

MMS messages;

WhatsApp messages;

push notifications;

secure portal messages;

customer support communications;

chatbot interactions;

AI assistant conversations;

Dispatch Center™ communications;

enterprise messaging;

API communications;

webhook communications;

future electronic communications.

Communication records may include associated metadata such as transmission time, delivery status, sender, recipient, routing information, and related operational information.

2.8 Billing and Payment Information

When purchasing services, the Company or its authorized payment providers may process:

billing name;

billing address;

payment method type;

transaction identifiers;

subscription information;

invoices;

receipts;

payment history;

billing events;

tax-related information;

future billing information.

Payment card information is generally processed by authorized payment providers and not retained by the Company except as necessary for lawful operational purposes.

2.9 Device Information

When Users access the Platform, the Company may automatically collect technical information including:

device type;

operating system;

browser type;

browser version;

device identifiers;

screen resolution;

language settings;

time zone;

application version;

network information;

mobile platform information;

future device characteristics.

2.10 Technical Information

The Company may automatically collect technical information including:

IP address;

Internet service provider;

session identifiers;

authentication events;

connection timestamps;

referring URLs;

page interactions;

API activity;

download activity;

upload activity;

system performance information;

diagnostic information;

error logs;

future technical information.

This information assists the Company in maintaining Platform performance, security, and reliability.

2.11 Cookies and Similar Technologies

The Platform may use:

cookies;

session cookies;

persistent cookies;

local storage;

browser storage;

authentication tokens;

pixel tags;

software development kits (SDKs);

web beacons;

similar technologies.

These technologies may support:

authentication;

security;

fraud prevention;

user preferences;

analytics;

Platform functionality;

performance improvements.

Additional details are provided in the Company's Cookie Policy.

2.12 Analytics Information

The Company may collect analytics information including:

page visits;

navigation paths;

feature usage;

document workflow statistics;

error frequency;

performance metrics;

interaction timing;

aggregated usage patterns;

future analytical information.

Where feasible and appropriate, analytics may be aggregated or de-identified.

2.13 Artificial Intelligence Interactions

When AI Services are used, the Platform may process:

prompts;

questions;

responses;

uploaded content used to provide AI functionality;

AI-generated summaries;

AI-generated translations;

AI-generated recommendations;

interaction history;

AI performance information;

future AI interaction information.

The use of such information is governed by this Privacy Policy and the AI Services Policy.

2.14 Audit Information

To support Platform integrity, the Company may generate audit information including:

login events;

authentication events;

signature events;

document events;

communication events;

administrative actions;

timestamps;

IP address information;

device information;

workflow events;

verification information;

future audit metadata.

Audit information helps support security, accountability, and verification services.

2.15 Future Services

As the Platform evolves, additional categories of information may be collected in connection with new services, including:

eSignare Notary™;

In-Person Electronic Notarization (IPEN);

Remote Online Notarization (RON);

credential analysis;

identity proofing;

electronic journals;

audio recordings;

video recordings;

witness information;

enterprise integrations;

future Platform technologies.

Where new categories of information require additional disclosures or consent under applicable law, the Company will provide such notices before processing the information.

3.1 General Purpose

The Company processes information to operate, maintain, secure, improve, and expand the Platform while providing reliable services to Users.

Information is processed only for legitimate business, operational, contractual, security, legal, customer support, research, or other lawful purposes consistent with this Privacy Policy, applicable law, and the services requested by the User.

3.2 Providing Platform Services

The Company uses information to provide requested services, including:

creating and maintaining Accounts;

authenticating Users;

providing Customer Workspaces;

providing Signer access;

managing Administrator functions;

processing electronic signatures;

generating Certificates of Completion™;

generating Verification IDs;

operating the Trust Center™;

managing document workflows;

processing invitations;

maintaining user preferences;

providing enterprise services;

operating APIs;

supporting future Platform services.

3.3 Identity Verification and Authentication

Information may be processed to:

verify user identity;

authenticate users;

administer Multi-Factor Authentication (MFA);

confirm account ownership;

prevent unauthorized access;

recover accounts;

validate administrative privileges;

manage security credentials;

support future authentication technologies.

3.4 Electronic Communications

Information may be used to send:

document invitations;

signature requests;

authentication codes;

password reset instructions;

billing notices;

invoices;

receipts;

security alerts;

fraud alerts;

account notifications;

policy updates;

support communications;

maintenance notices;

Dispatch Center™ communications;

legally required notices;

future operational communications.

Where required by law, marketing communications will be sent only after obtaining any necessary consent.

3.5 Customer Support

The Company uses information to:

respond to inquiries;

troubleshoot technical issues;

resolve document workflow questions;

investigate reported problems;

improve customer experience;

respond to complaints;

provide training materials;

improve documentation;

assist enterprise customers;

improve future support services.

Support interactions may be reviewed for quality assurance, training, security, or service improvement purposes.

Support personnel are not permitted to browse customer documents for unrelated purposes. Plaintext access to content protected by a Zero-Knowledge Enabled Service requires a deliberate, limited and auditable authorization from an authorized Customer. If the Customer does not provide such access, the Company may troubleshoot only through metadata, encrypted artifacts, diagnostic information, or customer-provided descriptions.

3.6 Billing and Subscription Management

Information may be processed to:

administer subscriptions;

process payments;

generate invoices;

generate receipts;

administer free trials;

process upgrades;

process downgrades;

manage renewals;

detect payment fraud;

administer taxes;

process refunds where applicable;

maintain billing history.

Payment card transactions are generally processed by authorized third-party payment providers.

3.7 Security and Fraud Prevention

Information is processed to protect the Platform, Users, and third parties.

Security-related purposes include:

detecting unauthorized access;

identifying suspicious activity;

preventing fraud;

protecting accounts;

investigating security incidents;

preventing abuse;

detecting malware;

protecting APIs;

monitoring authentication;

monitoring system integrity;

responding to cybersecurity threats;

improving Platform security.

Security remains one of the Company's highest operational priorities.

3.8 Artificial Intelligence Services

Where AI Services are provided, information may be processed to:

answer User questions;

summarize documents;

perform OCR;

translate content;

classify information;

improve search;

automate workflows;

recommend Platform features;

improve customer support;

detect fraud;

improve accessibility;

improve AI performance;

support future AI functionality.

The Company does not intend for AI-generated output to replace professional legal, tax, financial, immigration, accounting, medical, engineering, or other professional advice.

Users remain responsible for reviewing AI-generated content before relying upon it.

The Company will not use plaintext document content protected by a Zero-Knowledge Enabled Service to train a general-purpose artificial intelligence model. Standard document content will not be used for generalized AI training without an express disclosure and legally sufficient Customer authorization.

3.9 Product Improvement

Information may be used to:

improve Platform functionality;

enhance user experience;

identify software defects;

improve workflow efficiency;

develop new products;

evaluate feature usage;

improve artificial intelligence systems;

improve accessibility;

improve documentation;

improve system performance;

conduct internal research;

develop future Platform technologies.

Where appropriate, the Company may use aggregated, anonymized, or de-identified information for these purposes.

3.10 Analytics

The Company may analyze information to understand:

Platform usage;

feature adoption;

workflow performance;

document completion rates;

communication performance;

service reliability;

customer satisfaction;

operational efficiency;

future product development.

Analytics may be aggregated or de-identified whenever reasonably practicable.

3.11 Legal Compliance

Information may be processed where reasonably necessary to:

comply with applicable law;

respond to lawful governmental requests;

comply with subpoenas;

comply with court orders;

enforce contractual rights;

protect the Company;

protect Users;

protect third parties;

preserve evidence;

defend legal claims;

establish legal claims;

comply with regulatory obligations.

Nothing in this Privacy Policy limits disclosures required by applicable law.

3.12 Business Operations

The Company may use information to support normal business operations including:

internal administration;

accounting;

auditing;

financial reporting;

vendor management;

enterprise administration;

software development;

project management;

employee training;

quality assurance;

risk management;

business continuity planning.

3.13 Corporate Transactions

If the Company participates in:

a merger;

acquisition;

corporate reorganization;

financing transaction;

sale of assets;

business transfer;

succession planning;

information may be transferred as part of that transaction, subject to applicable law and appropriate confidentiality obligations.

Users will be notified where required by applicable law.

3.14 Future Services

As the Platform evolves, information may be processed to support future services including:

eSignare Notary™;

In-Person Electronic Notarization (IPEN);

Remote Online Notarization (RON);

enterprise administration;

API integrations;

developer services;

mobile applications;

artificial intelligence technologies;

future communication systems;

future verification services;

future Platform products.

Where new uses require additional disclosures or consent under applicable law, the Company will provide such notice before implementing those uses.

3.15 Our Commitment

The Company does not sell personal information in exchange for monetary compensation unless expressly disclosed and permitted by applicable law.

The Company is committed to using information in a manner that is:

lawful;

transparent;

secure;

responsible;

proportionate;

consistent with user expectations;

consistent with contractual commitments;

consistent with this Privacy Policy.

4.1 Lawful Processing

The Company processes information only where it has a lawful basis to do so under applicable law.

Depending upon the circumstances, information may be processed because:

the User has requested or authorized the service;

processing is necessary to perform contractual obligations;

processing is required to comply with legal obligations;

processing is necessary to protect the security, integrity, or functionality of the Platform;

processing supports the Company's legitimate business interests, provided those interests are not overridden by applicable legal requirements or the rights of the individual;

the User has provided consent where consent is required.

The legal basis for processing may vary depending on the type of information, the service provided, and the applicable jurisdiction.

4.2 Consent

Where consent is required by applicable law, the Company will request consent before processing information for that specific purpose.

Consent may be obtained through:

electronic acknowledgments;

acceptance checkboxes;

electronic signatures;

account settings;

communication preferences;

separate disclosures;

other affirmative actions recognized by applicable law.

Users may withdraw consent where permitted by law. Withdrawal of consent does not affect the lawfulness of processing performed before such withdrawal and may limit the availability of certain Platform features.

4.3 Sharing Information

The Company does not disclose personal information except as described in this Privacy Policy, required by law, or authorized by the User.

Information may be shared with:

service providers;

cloud hosting providers;

payment processors;

identity verification providers;

email delivery providers;

SMS providers;

WhatsApp Business providers;

customer support providers;

artificial intelligence providers;

analytics providers;

enterprise integrations authorized by the User;

professional advisors;

auditors;

insurers;

regulatory authorities;

courts;

law enforcement agencies where legally required or appropriate;

successor organizations in connection with lawful corporate transactions.

The Company does not authorize third parties to use User information for purposes unrelated to the services they perform on the Company's behalf unless otherwise disclosed or authorized.

For a Zero-Knowledge Enabled Service, a recipient of encrypted content receives plaintext access only when an authorized Customer or participant has provided the recipient with an appropriate encrypted key envelope or other authorized decryption grant.

4.4 Service Providers

The Company may engage carefully selected third-party providers to support Platform operations.

These providers may assist with:

infrastructure;

cloud hosting;

communications;

cybersecurity;

payment processing;

identity verification;

fraud prevention;

artificial intelligence;

document processing;

analytics;

software development;

customer support;

backup services;

disaster recovery;

future Platform functionality.

Where appropriate, the Company requires such providers to maintain contractual obligations regarding confidentiality, privacy, and security consistent with applicable law.

Providers supporting regulated-data configurations may also be required to execute Business Associate Agreements, data protection terms, financial-institution service-provider provisions, or other written safeguards appropriate to their role.

4.4A Health and Financial Information

The ordinary availability of the Platform does not authorize use with Protected Health Information ("PHI"), electronic PHI, or Nonpublic Personal Information ("NPI"). Such information may be processed only through an eligible configuration expressly approved for the applicable regulated use and after completion of any required written agreement.

Healthcare use may require a Business Associate Agreement between the Company and the covered entity or business associate Customer. Customer-Controlled Encryption or No-View status does not eliminate Business Associate obligations where the Company creates, receives, maintains, or transmits PHI on behalf of a regulated Customer.

Financial institutions and cooperatives remain responsible for their own regulatory determinations, vendor due diligence, access decisions, notices, retention obligations, and oversight. The Company will provide applicable service-provider commitments only through the governing Enterprise agreement or addendum.

Applicable requirements may include HIPAA, the Gramm-Leach-Bliley Act and FTC Safeguards Rule, regulator or supervisory requirements, Section 5 of the Federal Trade Commission Act, and Puerto Rico privacy protections. Puerto Rico institutions remain responsible for determining whether OCIF, COSSEC, NCUA, or another authority governs the particular institution and transaction.

4.5 International Transfers

Information may be processed, stored, transmitted, or accessed in jurisdictions other than the jurisdiction in which it was originally collected.

Where international transfers occur, the Company will implement commercially reasonable safeguards appropriate to the circumstances and consistent with applicable legal requirements.

The availability of particular Platform services may vary depending upon regional legal restrictions.

4.6 Cookies and Similar Technologies

The Platform uses cookies and similar technologies to support:

authentication;

security;

fraud prevention;

remembering preferences;

improving usability;

analytics;

maintaining sessions;

system performance;

future Platform functionality.

Users may manage certain cookie preferences through browser settings or other controls where available.

Disabling cookies may reduce or prevent the functionality of certain Platform features.

Additional information is provided in the Company's Cookie Policy.

4.7 Analytics Technologies

The Company may use analytics technologies to better understand Platform performance and user experience.

Analytics information may be used to:

evaluate feature usage;

improve navigation;

identify software defects;

improve accessibility;

understand system performance;

measure communication effectiveness;

improve customer experience;

develop future products.

Where reasonably practicable, analytics may be aggregated, anonymized, or de-identified.

4.8 Children's Privacy

The Platform is intended for individuals who are legally capable of entering into binding agreements or otherwise authorized to use the services.

The Company does not knowingly collect personal information directly from children under the age required by applicable law without appropriate authorization.

If the Company becomes aware that information has been collected from a child in violation of applicable law, the Company will take commercially reasonable steps to delete or otherwise address such information in accordance with applicable legal requirements.

Parents or legal guardians who believe that a child has submitted information may contact the Company using the methods identified in this Privacy Policy.

4.9 User Rights

Subject to applicable law, Users may have rights regarding their personal information, including the right to request:

access to certain personal information;

correction of inaccurate information;

deletion of information where legally permissible;

restriction of certain processing;

withdrawal of consent where applicable;

a copy of certain information in a portable format where required by law;

information regarding certain disclosures;

review of communication preferences.

The availability and scope of these rights may vary depending upon applicable law, jurisdiction, and the specific services used.

The Company may request reasonable verification of identity before fulfilling requests in order to protect Users and prevent unauthorized disclosures.

4.10 Data Retention

The Company retains information only for as long as reasonably necessary to:

provide requested services;

comply with legal obligations;

resolve disputes;

enforce agreements;

maintain security;

support fraud prevention;

preserve audit records;

satisfy record retention requirements;

support legitimate business operations.

Retention periods may differ depending upon:

account type;

subscription level;

document category;

applicable law;

litigation holds;

regulatory requirements;

operational necessity.

Upon expiration of applicable retention periods, information may be securely deleted, anonymized, aggregated, or archived in accordance with Company policies and applicable law.

Deletion of encrypted document content does not require the Company to possess a decryption key. Cryptographic erasure may also be used where appropriate by destroying Company-controlled key material; Customer-controlled keys and copies outside the Company's systems remain the Customer's responsibility.

4.11 Security Measures

The Company maintains commercially reasonable administrative, technical, organizational, contractual, and physical safeguards designed to protect information from unauthorized access, disclosure, alteration, destruction, or misuse.

Security measures may include:

encryption;

authentication controls;

Multi-Factor Authentication (MFA);

role-based access controls;

audit logging;

network security;

vulnerability management;

incident response procedures;

disaster recovery planning;

business continuity planning;

vendor risk management;

AI-assisted security monitoring;

future security technologies.

No security program can guarantee absolute protection against every threat.

For an expressly activated Zero-Knowledge Enabled Service, administrative access is designed to be limited to ciphertext, key envelopes and operational metadata. The Company will not maintain a universal document master key for those services.

4.12 Data Breach Response

If the Company becomes aware of a confirmed security incident involving personal information, it will investigate, contain, mitigate, and respond in accordance with applicable law and its incident response procedures.

Where notification is legally required, the Company will provide notice to affected individuals and, where applicable, regulatory authorities within the timeframes required by law.

4.13 Contact Information

For privacy requests and questions, please refer to Section 1.9 ("Contact for Privacy Questions") of this Privacy Policy. Additional privacy contacts may be designated where required by applicable law.

4.14 Changes to this Privacy Policy

The Company may revise this Privacy Policy from time to time to reflect:

changes in law;

new Platform services;

technological developments;

security enhancements;

operational improvements;

business changes;

regulatory guidance.

Material changes will be communicated through reasonable electronic means where required by applicable law.

Continued use of the Platform following the effective date of an updated Privacy Policy constitutes acceptance of the revised policy to the extent permitted by applicable law.

4.15 Relationship to Other Policies

This Privacy Policy forms part of the Portal Platform Legal Suite™ and should be read together with:

LEGAL-001 — Master Terms of Service;

Communications Policy;

Security Policy;

AI Services Policy;

Cookie Policy;

Electronic Signature Disclosure;

Trust Center™ Policy;

Record Retention Policy;

Enterprise Terms;

Developer & API Terms; and

other applicable legal documents adopted by the Company.

Where another policy governs a more specific subject, that policy shall control with respect to that subject matter, while this Privacy Policy continues to govern the Company's general privacy practices.