Privacy Policy

INTRODUCTION

GetCounsel, Inc. ("GetCounsel," "we," "us," or "our") is committed to protecting the privacy and security of personal information we collect and process through our services ("Services"). This Privacy Policy explains how we collect, use, share, and protect personal information following applicable data protection laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), General Data Protection Regulation (GDPR), and applicable state privacy laws in Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, and Maryland. By using our Services, you agree that we may collect, use, and share your personal information.

PRIVACY AND LEGAL PRIVILEGE

The confidentiality and privacy standards outlined in this Privacy Policy are based on consumer privacy principles and do not constitute a guarantee of legal privilege. GetCounsel is not a law firm, and using our Services does not create an attorney-client relationship or provide the same protections as legal privilege. While we strive to maintain the privacy and security of the information shared through our platform, the content shared on GetCounsel may not be subject to legal privilege.

PERSONAL INFORMATION WE COLLECT

We collect the following categories of personal information from our Subscribers and their authorized End Users in connection with providing our Services:

• Identifiers: Name, email address, postal address, phone number, unique identifiers, and similar information.
• Commercial Information: Records of products or services purchased, obtained, or considered.
• Communication Information: Information provided when you communicate with us, such as support inquiries or feedback.
• Google User Data: If you connect your Google account, we may access Gmail metadata and related information via Google APIs, with your consent, to provide requested features.
• Payment Information: Payment card and billing information are collected when you purchase our Services.
• Technical Information:
  • Log data: IP address, browser type, operating system, referral source, and similar information collected automatically when you use our Services.
  • Usage data: Information about how you interact with our Services, such as features used and actions taken.
  • Device information: Information about the devices you use to access our Services, such as device type, operating system, and unique device identifiers.
  • Cookies: Small data files stored on your device that help us recognize your device, remember your preferences, and analyze usage of our Services. We use essential, performance/analytics, and functional cookies.
• Social Information: Information collected when you interact with our social media pages, such as comments or likes.
• Support Information: Information provided when you contact us for customer support, such as your name, contact details, and inquiry details.
• Professional or Employment-Related Information: Job title, employer, and similar information.
• Inferences: Inferences drawn from any of the information identified above to create a profile about preferences, characteristics, and behaviors.

AI PROCESSING OF PERSONAL INFORMATION

GetCounsel uses artificial intelligence technologies, including services provided by third parties such as Anthropic and OpenAI, to process certain personal information in order to provide and improve our Services. When we use AI technologies:

• We only share the minimum personal information necessary for the specific processing purpose
• We implement appropriate technical and organizational safeguards to protect your information
• We prohibit our AI service providers from using your data to train their general AI models without your explicit consent
• We maintain oversight of AI processing activities to ensure compliance with our privacy commitments

You can learn more about our AI service providers in our Subprocessor List (Exhibit B).

HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of purposes, including providing and maintaining our Services, communicating with Subscribers and End Users about our Services, responding to inquiries and providing customer support, improving and developing our Services, personalizing user experiences, detecting, preventing, and addressing security incidents, protecting against malicious, deceptive, or illegal activity, complying with legal obligations, and establishing, exercising, or defending legal claims. This includes using Google user data only to provide or improve requested features, in compliance with the Google API Services User Data Policy.

In accordance with data minimization principles, we collect and process only the personal information that is reasonably necessary and proportionate to achieve the purposes for which it was collected, as described in this Privacy Policy.

By using personal information in these ways, we strive to deliver a seamless, secure, and tailored user experience while meeting our legal and contractual obligations.

HOW WE SHARE PERSONAL INFORMATION

We may share personal information with various third parties to facilitate the provision of our Services. This includes service providers who assist us with hosting, data analysis, customer support, and other essential functions, all of whom are contractually obligated to maintain the confidentiality and security of the personal information they receive and are prohibited from using it for any other purpose. We also share end-user personal information with the Subscribers who authorized their access to our Services. In the event of a merger, acquisition, or sale of all or a portion of our business, we may share personal information with the relevant parties involved in the transaction. Lastly, we may disclose personal information if legally required to do so, such as in response to valid requests by public authorities for national security or law enforcement purposes. We do not share Google user data except as required to provide the Services, comply with law, or with your explicit consent.

Our subprocessors, as listed in Exhibit B, are contractually bound to process data only as instructed by GetCounsel and to implement appropriate security measures to protect personal information. We conduct due diligence on all subprocessors before engagement and periodically thereafter. We will notify Subscribers of material changes to our subprocessor list through our website or direct communication. Our use and transfer of Google user data received from Google APIs will adhere to the Google API Services User Data Policy, including the limited use requirements.

YOUR RIGHTS AND CHOICES

Depending on your location and subject to applicable law, you may have the following rights regarding your personal information:

• Right to Access: You have the right to request a copy of the personal information we have collected about you.
• Right to Restrict Processing: You have the right to request that we restrict processing your personal information in certain circumstances.
• Right to Erasure: You have the right to request that we delete your personal information, subject to certain exceptions.
• Right to Rectification: You have the right to request that we correct any inaccurate personal information we hold about you.
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights under applicable data protection laws.
• Right to Object: You have the right to object to processing your personal information in certain circumstances, such as for direct marketing purposes.
• Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
• Right to Data Portability: You have the right to request that we provide you with a copy of your personal information in a structured, commonly used, and machine-readable format and to have us transmit that information to another controller where technically feasible.

To exercise your rights, please submit a verifiable request as described in Contact Us section below. We will respond within the timeframes required by applicable law.

DATA RETENTION AND DELETION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Generally, we retain:

• Account information: For the duration of your account plus 2 years after account closure
• Payment information: 7 years for tax and accounting purposes
• Communications: 3 years from the date of communication
• Technical and usage data: 2 years from collection

We regularly review our retention practices to ensure compliance with applicable laws. You may request deletion of your personal information as described in the "Your Rights and Choices" section.

SECURITY

We implement and maintain reasonable security measures, including encryption, access controls, and regular risk assessments, to protect personal information from unauthorized access, use, alteration, or destruction.

INTERNATIONAL DATA TRANSFERS

We may transfer personal information to countries outside of the jurisdiction in which it was originally collected. We will ensure that such transfers comply with applicable data protection laws and that appropriate safeguards, such as standard contractual clauses, are in place to protect the transferred personal information.

CHILDREN'S PRIVACY

Our Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. We implement age-gating measures where appropriate to prevent the collection of children's data. If we learn that we have inadvertently collected personal information from a child under 16, we will promptly delete it and implement measures to prevent further collection. If you believe we have collected personal information from a child under 16, please contact us immediately at privacy@getcounsel.co.

COOKIES AND TRACKING TECHNOLOGIES

We employ cookies and similar tracking technologies to gather Technical Information and personalize your experience using our Services. These cookies, which are small data files stored on your device, serve various functions, such as recognizing your device, remembering your preferences, and analyzing how you interact with our Services. We use three main types of cookies: Essential Cookies, which are necessary for the website to function properly; Performance and Analytics Cookies, which help us analyze usage patterns and improve the performance of our Services; and Functional Cookies, which remember your preferences and help personalize your experience. You can manage your cookie preferences through your browser settings, but please be aware that disabling certain cookies may impact the functionality and performance of our Services.

THIRD-PARTY LINKS

Our Services may contain links to third-party websites or services that are not operated by GetCounsel. This Privacy Policy does not apply to those third-party sites, and we encourage you to review the privacy policies of those sites before providing any personal information to them. GetCounsel is not responsible for the privacy practices or content of any third-party sites.

CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post any updates on this page and indicate the effective date of the updated policy. We encourage you to review this Privacy Policy periodically for any changes.

CONTACT US

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at: