Privacy Policy

Updated: August 19, 2025

Documate, Inc. d/b/a Gavel ("Gavel"). ("Gavel", "we", "us" and "our") is committed to protecting the privacy of our website visitors, customers, business partners, and end users through our compliance with this "Privacy Policy." Throughout this Privacy Policy, we refer to any person accessing or using this Website as "you," or the "User."

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website www.gavel.io (our "Website") and our practices for collecting, using, maintaining, protecting and disclosing that information.

This Privacy Policy applies to information we collect:

• On or through this Website.
• In email, text, and other electronic messages between you and this Website.
• When you interact with our advertising on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website or social media platform profile operated by Gavel or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any integration or plug-in that may be used in conjunction with the Website. Please be aware that we have no control over the content and policies of those third-parties, and cannot accept responsibility or liability for their respective privacy practices.

Please read this Privacy Policy carefully to understand our policies and practices regarding your "Personal Information" (as defined below in "What Information Do We Collect About You?" ) and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Website after we make changes is deemed to be your acceptance of those changes, so please check the Privacy Policy periodically for updates.

1. How We Collect Data

The information we obtain generally consists of information (1) you give us about yourself, (2) you give us about others, (3) automatically collected about your interactions with the Website and our content or ads on third-party websites, apps or other media, and (4) we get from other sources.

2. What Information Do We Collect?

A. Information You Provide Directly To Us

Some information is provided by you, such as:

• Contact information (e.g., your name or email address) when you sign up for our newsletter or you send us an email. This information is considered personally identifiable information, or “Personal Information.”
• Comments, photos, videos, and other content or information you choose to publish on the Website or otherwise share with us.
• Information you provide when you choose to participate in surveys, polls, contests, or promotions.
• Location information, which may include precise location information when you permit the Website to access device location. To prevent the collection of precise location information, please refer to instructions provided by your mobile service provider or device manufacturer.
• Transactional and activity information.

B. Information We Collect Automatically

When you visit our Website, we may also automatically collect information about your device or usage, such as:

• Information about your computer, device, browser and operating system (e.g., type, model, or version).
• Internet protocol (IP) address, tenant URL, which may be used to derive your general geographic area (e.g., city and country).
• Device identifiers (e.g., mobile advertising IDs or universal unique identifiers/globally unique identifiers).
• Information about your interactions with the Website, including event names, browsing activities and clickstream data that reflect the content you have accessed, clicked on, or viewed, or error states.
• User role, as either a workflow builder or end-user/client of a workflow builder.
• Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.

C. Information We Obtain From Other Sources

We receive information about you from other sources and it may be combined with other information about you. For example, we may obtain data from:

• Payment information for subscriptions or purchases made through the Website (e.g., payment card number, expiration date, and billing information). This information will be gathered through Stripe, a third-party service provider.
• Operators of third-party sites or apps, voice-activated assistants, or other devices and technologies when you interact with our ads available on those channels and platforms. The information we receive may include information about the content you view or access as well as your demographic information and information about your interests. Cookies and other similar technologies may be used by our third-party data partners to associate your website visits with other personal information about you, including your email address or home address. We or active service providers (on our behalf) may then send you communications and marketing based on this information. You may opt out at any time (see "How to Contact Us").
• Social Media Platforms and similar services (“Social Media Platforms”). When you engage with our content or ads on Social Media Platforms, or interact with features on the Website that contain content or features provided by Social Media Platforms (e.g., login or sign in features or tools that allow you to share our content with others on Social Media Platforms), we may obtain information from Social Media Platforms, including your username, user ID, demographic information, and other information, subject to the settings and privacy practices of the relevant Social Media Platform. We may obtain this information directly from the Social Media Platform or through plug-ins, integrations or applications. Please keep in mind that the operators of the Social Media Platforms may also gather information about your use of the Website and their features and tools.

D. Information You Give Us About Others

You may give us information about other people when you use our Website. Do not give us information about others unless you are authorized or have their consent to do so. We will use their information for the purposes described in this Privacy Policy.

3. Data Collection Policy

The technologies we use for automatic data collection on this Website may include the following technologies:

A. Cookies (or Browser Cookies)

Cookies are small files that a site transfers to your computer’s hard drive through your web browser that enables it to recognize your browser and capture and remember certain information. A cookie cannot read data off of your hard drive or read cookie files created by other sites. Cookies may do things like allow you to navigate faster through the site, remember your preferences, passwords, and generally improve the user experience. You can turn off the ability to receive cookies by adjusting your browser settings — please note that if you do so, this may affect the functionality of the website and the information you can access through it. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. Gavel uses cookies to compile aggregate data about Website traffic and interaction so that we can offer better site experiences and content in the future. We use third-party companies, such as Google Analytics, to assist us in understanding our site visitors. We do not share with these third parties any information that would readily identify you (such as email address); however, these third parties may have access to information about your device (such as IP or MAC address). We do not have access to, or control over, the technologies that these third parties may use to collect information about your interests, and the information practices of these third parties are not covered by this Privacy Policy. Other than as discussed in this document, we have no control over these third parties.

B. Flash Cookies

Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

C. Web Beacons

Pages of the Website, and our emails, may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Gavel to, for example, count users who have visited those pages, or opened an email, and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

4. "Do Not Track" Signals

"Do Not Track" is a preference you can set in your browser to let websites you visit know that you do not want them collecting certain information about you. We do not respond to Do Not Track (DNT) browser signals because no common industry standard for DNT has been adopted. We do, however, honor the Global Privacy Control (GPC) signal as an opt-out preference signal where required by applicable law.

5. How Will We Use The Information We Collect?

We may use information collected when you visit our Website for the following business purposes:

• Provide you with Gavel products and services, and to process transactions related to those products and services.
• Respond to your requests or provide information requested by you.
• Send administrative or account-related information to you.
• Manage your account and provide support or other services, such as product updates, fixes and product and service recommendations.
• Obtain and understand your feedback or user experience.
• Better understand our customers and end-users and the way they use and interact with Gavel websites, mobile apps, products, and services.
• Provide a personalized experience, and implement the preferences you request.
• Improve service reliability or improve features and functionality. For example, we may analyze workflow builders’ anonymized intake questions (e.g., the question "What is your name?" but never the answer to that question) to help Gavel suggest and generate questionnaires for your workflows.
• Enhance security, monitor and verify identity or service access, combat spam, or other malware or security risks.
• Provide you with marketing and promotional communications (where this is in accordance with the law).
• Determine the effectiveness of marketing and promotional campaigns.
• Post testimonials publicly (with your prior consent).
• Interact with you on third-party social networks (subject to that network's terms of use and privacy policies).
• Administer product downloads and to confirm your compliance with our licensing and other terms of use.
• Communicate with you about our events or our partner events.
• Provide quality control and staff training.
• To prevent fraud.
• For internal record keeping and administrative purposes.
• To fulfill any other purpose for which you provide your information and consent.
• To comply with our legal obligations and resolve any disputes that we may have.

6. To Whom Do We Disclose Information We Collect?

We may share Personal Information about you with third parties in the following circumstances.

A. Partners

We may provide your information to our channel partners, such as distributors and resellers, to fulfill product and information requests, to effectively deliver unified support, and to provide customers and prospective customers with information about Gavel and its products and services.

B. Service Providers

We may share your information with third parties, such as vendors, consultants, agents, and other service providers who work on our behalf. Examples include vendors and service providers who provide assistance with marketing, billing, processing credit card payments, data analysis and insight, technical support and customer service.

C. Others for Compliance with Laws

Compliance with laws or any competent law enforcement body, regulatory body, government agency, court or third party: we may disclose information where we believe disclosure is necessary or required (i) by law or regulation, in order to comply with legal process or government requests (including in response to public authorities to meet national security or law enforcement requirements); or (ii) to exercise, establish or defend our legal rights, including but not limited to for the purposes of debt collection or in the course of receiving legal advising.

D. Others in the Event of Change in Ownership

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Gavel’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by Gavel about our Website users is among the assets transferred. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your Personal Information according to this Privacy Policy.

E. Others for Legitimate Business Purposes

We may share your Personal Information when it is necessary for other legitimate purposes such as protecting Gavel's confidential and proprietary information or where necessary to support, respond to, and to provide our products and services to our customers. This includes disclosing your Personal Information for any purpose for which you have provided consent.

7. How We Secure Your Information

Gavel maintains (and requires its service providers to maintain) appropriate organizational and technical measures designed to protect secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:

• Employing physical access controls, encryption, Internet firewalls, intrusion detection and network monitoring depending on the nature of the information and the scope of processing.
• Providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible.
• Requiring our employees to keep all Personal Information confidential.

8. Your Privacy Rights

A. Updating Your Information

If you would like to update Personal Information that you have provided to us, please log on to https://www.gavel.io and update your profile or send an email to hello@gavel.io.

B. Marketing Communications

You can opt-out of receiving marketing communications from Gavel by clicking “unsubscribe” in any marketing email communications we send you, or by sending an email to hello@gavel.io.

C. Third Parties

Some content or applications, including payment processing through Stripe, on the Website are served by third-parties. These third parties may use cookies (alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Website.

D. California Privacy Rights

California Civil Code section 1798.83 requires us to disclose to our California customers, upon request, the identity of any third parties to whom we have disclosed Personal Information within the previous calendar year, along with the type of Personal Information disclosed, for the third parties' direct marketing purposes.

E. EU-U.S. Data Privacy and International Data Transfers

For users who are collecting, requesting, or otherwise compiling third-party data, complete this survey to determine whether it is appropriate for you to sign a Data Processing Addendum (DPA) with Gavel.

9. How Long Do We Retain Your Information?

We retain Personal Information and account data for as long as your account is active or as needed to provide you with our services. When your account is canceled or terminated, we retain your account data for seven (7) days solely to allow for account reactivation. After this period, your account data will be permanently deleted, except where a longer retention period is required by law or necessary for legitimate business purposes such as maintaining backups, complying with audits, or resolving disputes.

10. Minors/Children

Our Websites, products, and services are not directed to individuals under the age of 18, or the age of majority wherever a User may be located (collectively, “Minors”). We do not knowingly collect Personal Information from Minors. If you are a Minor, do not use or provide any information on this Website, or on or through any of its features/functionality, make any purchases through the Website, use any of the interactive or public comment features that may be available on this Website, or provide any information about yourself to us, including your name, address, telephone number, or email address.

11. Additional information for European visitors

In order to address our legal obligations in Europe (including the UK), Gavel provides the following additional information for Europe-based visitors to Gavel’s Website.

A. Who is Responsible for Your Information?

Gavel remains responsible for personal data it transfers to third-party agents for processing on its behalf, and requires those agents to provide a level of protection consistent with applicable data protection laws and the Standard Contractual Clauses incorporated into our Data Processing Addendum.

12. Changes to This Privacy Policy

Gavel will review and update this Privacy Policy periodically in response to changing legal, technical and business developments. When we update this Privacy Policy, we will note the date of its most recent revision above. If we make material changes to this Privacy Policy, we will take appropriate measures to inform you in a manner that is consistent with the significance of the changes we make and is in accordance with applicable law.