Privacy Policy

01. Data Controller & Data Protection Officer (DPO)

The designated Data Controller responsible for processing your personal information is:

02. Categories of Personal Data Processed

We collect only the minimum data necessary to operate our cloud document automation platform:

03. Lawful Bases for Processing (GDPR Article 6)

We process your personal data strictly under established legal bases:

• Contractual Performance (Art. 6.1.b GDPR): Necessary to provision accounts, process template merges, generate output files, and maintain core services.
• Explicit Consent (Art. 6.1.a GDPR): For optional analytics (GA4, Microsoft Clarity) and conversion pixels (Meta, Google Ads).
• Legal Obligation (Art. 6.1.c GDPR): Retaining tax and accounting transaction records required by statutory law.
• Legitimate Interests (Art. 6.1.f GDPR): Safeguarding infrastructure against bots, fraud, and cyber threats via Google reCAPTCHA Enterprise and Cloudflare.

04. Comprehensive List of Subprocessors & Service Providers

Under GDPR Article 13(1)(e) and Article 28, we disclose our complete list of authorized third-party subprocessors:

Note on local client-side libraries (Syncfusion, SkiaSharp, QRCoder): Word and PDF processing occurs inside an isolated WebAssembly sandbox in your browser or within memory in our Google Cloud container; files are not sent to external Syncfusion servers.

05. AI Data Processing & Zero-Model-Training Guarantee

06. International Data Transfers & Cross-Border Safeguards

DocuCognito primary services operate in Google Cloud data centers located in the United States (us-central1). For users across the EEA, UK, Switzerland, Canada, Latin America, and APAC, cross-border transfers are legally protected by:

• Standard Contractual Clauses (SCCs): European Commission approved clauses under Implementing Decision (EU) 2021/914.
• EU-U.S. Data Privacy Framework (DPF): Participation in the EU-U.S. DPF, UK Extension to the DPF, and Swiss-U.S. DPF frameworks.

07. Data Retention, Backup Purge & Immutable Consent Records

We retain personal data only for as long as necessary to fulfill the operational purposes for which it was collected:

• Active Data: Stored while your account remains open.
• Account Deletion Process & Right to Erasure (GDPR Art. 17): When you request account deletion via the in-app profile settings, a secure multi-step process is executed to protect against accidental deletions:
  • Danger Zone: The deletion button is hidden within a collapsible "Danger Zone" section in your profile, with clear visual warnings.
  • Email Verification Code: A cryptographic 6-digit verification code is sent to your registered email address. The code expires after 15 minutes and is protected against brute-force attacks (maximum 5 invalid attempts before lockout).
  • Double Confirmation: In addition to the code, you must explicitly type the word "DELETE" to unlock the final deletion action.
  • 14-Day Grace Period: Deletion is scheduled 14 calendar days in the future. During this period, you retain full access to the platform and may cancel the deletion at any time via a prominent banner displayed at the top of the application.
  • Reminder Email: 72 hours (3 days) before the scheduled deletion date, an automated reminder email is sent with the exact purge date and time, along with instructions to cancel the process.
  • Permanent & Irreversible Purge: Upon expiration of the grace period, a comprehensive purge permanently deletes: (a) your user account and Firebase Authentication identity, (b) all forms, responses, templates, generated documents, and dashboards, (c) all e-signature envelopes, (d) all workspace data including members and invitations, (e) all files stored in Google Cloud Storage (general documents and signed documents), (f) active billing subscription (automatic cancellation via Paddle), (g) notifications, support tickets, and feedback records.
• Encrypted Backups: Encrypted backups are permanently erased within a 30-day rotating retention window following permanent deletion.
• Consent Records: Immutable audit trail entries are maintained in the consent_logs collection, recording policy version, timestamp, IP address, anonymous identifiers, and deletion actions to demonstrate compliance under GDPR Article 7. These records are retained as regulatory compliance evidence and do not contain personally identifiable data.

08. Global Data Subject Rights (GDPR, CCPA/CPRA, LGPD, PIPEDA)

Regardless of your geographic location, you enjoy comprehensive privacy rights:

Global Privacy Control (GPC) & DNT Signal Recognition: Our platform automatically honors GPC and Do Not Track signals transmitted by your browser, automatically denying marketing and targeting cookies.

Right to Lodge a Complaint with a DPA: You have the right to file a complaint with the Data Protection Authority in your habitual residence (e.g., AEPD in Spain, ICO in the UK, CNIL in France, FTC in the US, or statutory DPAs worldwide).

To exercise any privacy right, contact our team at support@docucognito.ai or our DPO at dpo@docucognito.ai.

09. Security Measures & Technical Safeguards

We enforce enterprise-grade security standards:

• Encryption: TLS 1.3 with strict HSTS in transit; AES-256 encryption at rest in Google Cloud Storage and Firestore.
• Cryptographic Key Management (Cloud KMS): Centralized key management isolating encryption keys from application code.
• Access Governance: Multi-factor authentication, least-privilege IAM policies, and continuous audit logging.

10. Children's Privacy (COPPA & Global Standards)

DocuCognito is strictly intended for enterprise professionals aged 18 and older. We do not knowingly collect personal data from children under 18. If we discover that a minor has provided personal information without verified parental consent, we will permanently purge the data immediately.