Privacy Policy

Last updated: 20 August 2026

Qfile B.V. ("we") processes personal data through OurDigitalContract. In this policy we explain which data we process, why, on what legal basis, for how long and what rights you have.

Who is responsible?

For the data of your own employees and signers, your organisation is the data controller and we then act as the processor (see the data processing agreement). For the data of our own account holders, we are the controller.

Which data do we process?

Cookies and analytics (with consent)

On our public website we use Google Tag Manager and Google Analytics only with your consent to measure how the website is used and to improve it. These measurement cookies are only placed after you click "Accept" on the cookie bar; your choice is stored in your browser (localStorage). Google Tag Manager loads with Consent Mode version 2: by default analytical consent is set to denied and no analytical cookies are placed; only after you click "Accept" do we enable that consent. We never use these measurement services on the secured app and signing pages.

This measurement may process data such as your (truncated) IP address, the pages visited, the time, device and browser information and the referring website. We use this solely for anonymised, statistical insights, not to identify you personally. The processor for this is Google Ireland Limited. You can withdraw your consent at any time by clearing your cookies; on your next visit the cookie bar will appear again. See our cookie policy for the full details.

Free model documents and the trial environment (with your consent). If you request a free model document by e-mail on one of our model pages, this is only possible by ticking a box that gives us consent to e-mail you the model, prepare a free trial environment for you, and send you a few short e-mails with tips and new models afterwards. For this we process your e-mail address, your first name if you provide it, and the model you requested; as proof of your consent we also store the literal text of the checkbox, the moment and the IP address at that moment (article 7(1) GDPR). Legal basis: your consent (article 6(1)(a) GDPR). You can withdraw your consent at any time via the unsubscribe link included in every e-mail; you will then no longer receive these e-mails. After you unsubscribe we only keep an encrypted derivative of your e-mail address on our suppression list, for the sole purpose of never e-mailing you again (legitimate interest). Data of requesters who do not create a trial environment is deleted no later than 6 months after the request. The box is never pre-ticked. Without a request, the beginning of the model remains readable on the page, and printing or saving as pdf from the page provides the full text.

Page views without a cookie. Independently of that choice, we count on our own server how often a page is viewed. No cookie is placed and nothing is read from or written to your device. We only keep the path of the page, the host name of the website you came from (not the search query), whether your screen is narrow or wide, and a counter. Your IP address is not stored: it is used in working memory only, combined with a secret that changes daily, to derive a key that lets us count visitors without recognising them. That daily key is deleted after 90 days. Legal basis: our legitimate interest in simple, privacy-friendly visit statistics (article 6(1)(f) GDPR). The data stays on our own server and is not shared with any other party.

Purposes and legal bases

Mandatory provision of data

Some of the data is needed to perform the contract or arises from a legal obligation. Without account data, for example, we cannot create an account, and without a signature and the associated verification data a document cannot be signed in a legally valid way. If you do not provide this data, we cannot deliver (that part of) the service. Data such as a national identification number (BSN) is only processed where it is legally required or permitted and the customer instructs us to do so.

Automated decision-making and profiling

We do not take decisions with legal effects or similarly significant effects based solely on automated processing, and we do not carry out profiling.

How do we secure it?

Encryption at rest with a separate key per customer (AES-256-GCM), encrypted connections (HTTPS with HSTS), separated storage with a dedicated database per customer, hashed passwords (bcrypt), role-based and permission-based access, revocable sessions, rate limiting and an append-only audit log.

If we discover a data breach, we act in accordance with our data breach procedure.

Electronic signature

Signing is done with a simple electronic signature (eIDAS SES): identity is evidenced through control of an email address and a one-time link, and integrity through a tamper-evident attestation and an audit log. There is no strong identity verification (no advanced or qualified signature, AES or QES).

Retention periods

We do not keep data longer than necessary for the stated purposes or than legally required. We keep account data for as long as you have an account and up to 6 months after termination, after which we delete or anonymise it. We keep invoices and accounting records for 7 years due to the statutory tax retention obligation. Data we hold as a processor on behalf of a customer is retained according to that customer's instructions and deleted or returned after termination (see the data processing agreement). Security and audit log data (including login events and the IP address at the moment of signing) is retained for as long as necessary to evidence signing and to secure the service, and at the latest until the associated record is deleted in accordance with the periods above.

Where does the data come from?

We receive account data directly from you. Data about signers and the individuals involved in a record we receive from the customer (the controller) who submits the document for signing, or directly from you when you sign yourself. If you are a signer and have questions about the origin or use of your data, you can turn to the organisation that sent you the document.

Sub-processors and recipients

We do not sell data.

A current overview of our sub-processors is available on the sub-processors page. The arrangements for the data we process as a processor are set out in the data processing agreement.

Transfers outside the EEA

No processing or storage of personal data takes place outside the European Economic Area (EEA).

Your rights

You have the right of access, rectification, erasure, restriction, objection and data portability. Where we process data on the basis of your consent (such as analytical cookies), you may withdraw that consent at any time; this does not affect the lawfulness of the processing carried out beforehand.

If you wish to exercise one of these rights, send a request to info@ourdigitalcontract.com. To prevent misuse, we may ask you to identify yourself. We respond within one month at the latest; for a complex or large number of requests we may extend this period by two months and will let you know within the first month. Requests about data we hold as a processor are handled through your own organisation (the controller).

You may also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl).

Changes

We may amend this policy. The current version is always available on this page. In the event of significant changes we will actively inform you, for example through a notification in the app or by email.