Privacy Policy

PRIVACY POLICY

ProCounsel, is an AI-based eDiscovery platform that enables its users to upload and analyze case discovery data using advanced AI models (collectively referred to as the ‘Services’), and is owned and operated by Counsel Artificial Intelligence Inc., a company incorporated in Delaware, bearing Registration Number 332798921, and having its registered office in Maryland (hereinafter referred to as the “ProCounsel”, “Company”, “we”, “us”, “our”, or “ourselves”). This Privacy Policy (“Policy”) informs about our policies and procedures regarding the collection, use and disclosure of Information/Data that we collect from or about you when you use/visit our website (hereafter referred to as the “Platform”).

This Policy is an electronic record in the form of an electronic contract formed under the Applicable Law. This Policy does not require any physical, electronic or digital signature. This Privacy Policy is a legally binding document between you and us.

In this Privacy Policy, “you” or “your” or “yourself” means the person using the Platform and/or the person on whose behalf you are acting, if any. We collect and process your Personal Information/Data, Sensitive Personal Information/Data and third-party information carefully, only for the purposes described in this Policy and the associated Terms and Conditions, and only to the extent necessary as defined herein and within the scope of the applicable legal regulations. This Policy seeks to ensure that any Personal Information/Data, Sensitive Personal Information/Data, or third-party information handled by us is managed in a way that is ethical, compliant and adheres to best industry practices.

Please read this Privacy Policy carefully, before accessing or using our Platform, to understand our policies and practices regarding your Information/Data and how we will treat it. By accessing or using our Platform, including our Services, you agree and accept the terms of this Policy, and you understand and agree to the collection, use, sharing and processing of Information in the manner described herein. If you accept this Policy on behalf of another person or company or other legal entity, you represent and warrant that you have full authority to bind such person, company, or legal entity to these terms.

Our Policy describes the types of Information/Data we collect, why and how we use the Information/Data, with whom we share it, and the rights, choices you have about our use of the Information/Data. We also describe the measures we take to protect the security of the Information/Data and how you can contact us about our privacy practices.

This Policy describes our current data protection policies and practices and may be amended/updated from time to time. Any changes to this Policy will become effective upon posting of the revised Policy on the Platform. We suggest that you regularly check this Policy to apprise yourself of any updates. Your continued use of our Platform or provision of Information thereafter will imply your unconditional acceptance of such updates to this Policy.

By mere use of the Platform, you expressly consent to our use and disclosure of your Personal Information/Data (as defined below), Sensitive Personal Information/Data (as defined below) and third-party information in accordance with this Policy. If you do not agree with the terms of this Policy, please do not use this Platform. This Policy shall be deemed to be incorporated into the terms and conditions (“Terms and Conditions”) of the Platform and shall be read in addition to the Terms and Conditions.

This Privacy Policy applies to Information we collect through the use of the Services offered by us and our affiliates, agents, representatives, employees, including the services offered on third-party sites, such as advertising services. Our Privacy Policy applies to all the Users, Visitors and others who access our Platform. This Privacy Policy does not apply to information we process on behalf of you. With respect to any Personal Information/Data or Sensitive Personal Information/Data contained in the documents, files, or other materials that you upload or otherwise submit to the Platform for analysis or processing (“Case Materials”), you determine the purposes and means of processing, and accordingly, you are the Controller of such Case Materials. We process such Case Materials solely on your instructions, for the limited purpose of rendering Services. For Information/Data that we collect directly from you outside of your Case Materials, such as account-registration data, billing information, device identifiers, usage analytics, communications data and other such data, we determine the purposes and means of processing, and accordingly in that context, we act as the Controller of such collected Information/Data.

This Privacy Policy does not apply to—

● Any third-party applications or software accessible via the Services or that integrate with the Services or any other third-party products, services, or businesses. If you have any questions about the specific settings and privacy practices of such third parties, please contact the relevant third-party product, service, or business to review its privacy notice/policy/practice.

● The information practices of other companies, consultants or organizations that advertise on our Platform.

● The services offered by other companies or individuals, including sites that may include our Services, be displayed to you in search results, or be linked from our web pages.

3.1 “Consent” of the User means any freely given, specific, informed, and unambiguous indication of the User’s wishes by which the User, or User’s legal guardian, a person who has power of attorney, or a person acting as a conservator for the User, including by a statement or by a clear affirmative action, signifies agreement to the processing of Personal Information/Data and/or Sensitive Personal Information/Data relating to the User for a particular purpose.

3.2 “Contractor” means a person to whom we make available your personal information for a business purpose, pursuant to a written contract with the us which prohibits sale/sharing of your Personal Information.

3.3 “Controller” shall mean natural person or legal entity that, alone or jointly with others, determines the purpose and means of collecting and processing personal information. For the purpose of this Privacy Policy, you are the Controller of the Information upload or otherwise submit to the Platform for analysis (Case Materials) and for information that we collect directly from you outside of your Case Materials, such as account-registration data billing information, device identifiers, usage analytics, and communications data, we determine the purposes and means of processing, we are the Controller.

3.4 “Information/Data” means and includes Personal Information, Non-Personal Information, Deidentified Information and Sensitive Personal Information.

3.5 “Non-personal Information/Data” or “Deidentified Information/Data” means information that does not specifically identify an individual, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system. We may gather any Non-Personal Information / Deidentified Information regarding how many people visit this Platform, the pages they visit, and the type of browser they used while visiting the Platform. We may also collect Non- Personal Information that you voluntarily provide, such as information included in response to a questionnaire or a survey conducted by us.

3.6 “Personal Information/Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with or could reasonably be linked, directly or indirectly with a particular User, it includes but not limited to:

Personal Information does not include Deidentified Information, Aggregate Information or Publicly Available Information. We limit our collection of Personal Information to that which is necessary for its intended purpose.

3.7 “Processing” means any operation or set of operations that are performed on any information/data or on sets of information, whether or not by automated means.

3.8 “Publicly Available Information” means information that a person: (i) lawfully obtains from a record of a governmental entity; (ii) reasonably believes you or widely distributed media have lawfully made available to the general public; or (iii) if you have not restricted the information to a specific audience, obtains from a person to whom you disclosed the information.

3.9 “Sensitive Personal Information/Data” (“SPI” / “SPD”) of a person means such personal information/data of the User which reveals—

i. social security numbers, driver’s license, state identification card, or passport number.

ii. Account log-in, financial account, credit card or debit card number in combination with any required security or access code, Password or credentials allowing access to an account;

iii. Precise geolocation data;

iv. racial or ethnic origin, citizenship or immigration status, religious or philosophical beliefs, or union membership;

v. Contents of mail, email, text messages unless we are the intended recipient of the communication;

vi. Genetic data;

vii. Neural data (information that is generated by measuring the activity of your central or peripheral nervous system, and that is not inferred from nonneural information.)

viii. The processing of biometric information for the purpose of uniquely identifying User.

ix. Personal information collected and analyzed concerning a User’s health.

x. Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

xi. Provided that, any information that is publicly available information and freely available or accessible in public domain shall not be regarded as sensitive personal information for the purposes of this Policy.

We collect information about you through the means discussed below. We collect a variety of information based on your interactions with our Services and the choices you make, the products and features you use, we may collect information from you directly, indirectly, or automatically. Please note that we need certain types of information, without which we may be unable to provide the Services to you.

4.1. Information You Provide to Us

The information you may provide to us includes:

4.1.1. Account Information: Information about you that you provide to us at the time of creating, updating an Account created to avail our Services includes:

● First Name and Last Name;

● Email address;

● Phone Number;

● Username, Organization, Position, City, State;

● Log-in credentials, password, any other information when you provide when you create a user account on the Platform;

● Billing information, such as credit or debit card number, verification number, and expiration date, at the time of paying the subscription fees for the subscription plan selected by you;

● Information about purchases or other transactions with us;

● Information about your customer service interactions & communications with us.

● Demographic information such as your gender (if required) or other information you choose to provide as part of your User Account;

● Information relating to your registration for our newsletter;

● Any other information you provide to us for Account registration and administration of your Account.

4.1.2. User content/ Service Generated Data: When you use our Services, you may create, upload, submit, or receive files, documents, images, videos, audio recordings, or other types of content (“User Content”) through the Platform. We collect and temporarily store this User Content solely for the purpose of providing the requested Services and features to you.

We do not use User Content to train or improve our AI models, and we do not share it with third parties except as necessary to operate the Platform, comply with legal obligations, or protect our legal rights.

User Content may include:

We implement industry-standard technical and organizational measures to protect your User Content against unauthorized access, use, or disclosure. Unless otherwise required to provide Services or comply with legal obligations, User Content is retained only as long as necessary for processing and is deleted thereafter as outlined in the Terms and Conditions.

By uploading or submitting User Content, you confirm that you have the necessary rights and permissions to do so, and that such Content does not violate Applicable Laws or infringe the rights of any third party.

4.1.3. Communication Information: If you communicate with us, such as via email, calls, messages, our pages on social media sites or otherwise, for purposes of customer support and technical assistance, submission of reviews, requests or questions you submit to us via online forms or otherwise; we may collect Personal Information that you provide to us like your name, contact information, and the contents of the written and audio messages you send and communication made between us and our agents, affiliates, representatives and you based on our exchanges with you, email, or otherwise.

4.1.4. Social Media Information: Our Site may use social media features, and we and the social media network may receive information about you based on your engagement with us such as your username, email address, content of your interaction, etc. Your interactions with social media features are governed by the privacy and user policies of the companies that provide them, and we are not responsible for how those companies collect, use, or disclose your information so we encourage you to review the privacy policies of those companies.

4.1.5. Any other: Any other additional Information you voluntarily provide to us.

4.2 Information We Collect Through Automated Means: When you use the Platform, we collect certain information as described in this Section. As discussed further below, we and our service providers (which are companies that work on our behalf) may use a variety of technologies, including cookies and similar tools, to assist in collecting this information.

● Usage Data: We collect information about how you interact with our Service, such as features used, time spent on the platform, and actions taken.

● Websites. When you use our website, we collect and analyse information such as your IP address, browser types, browser language, operating system, software and hardware attributes (including device IDs) referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, date and time of use, content watched, total minutes watched, error logs, and other similar information about how you use the website.

● Location Information. When you use the Platform, we and our Service Providers may automatically collect geolocation information (e.g., IP address, city/state and or postal code associated with an IP address) from your computer or mobile device. Some of our Services allow you to choose to provide more precise location information from your device, such as location information from your device’s GPS.

● Use of Cookies and Similar Technologies: We use Internet server logs, cookies, tracking pixels, and other similar tracking technologies. We use these technologies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences. Cookies are small text files that are placed on your computer or mobile device when you visit a site that enable us to: (i) recognize your computer; (ii) store your preferences and settings; (iii) understand the web pages of the Services you have visited; (iv) enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions. As we adopt additional technologies, we may also gather information through other methods such as web beacons. Please note that you can opt out of sharing cookies by changing your settings to notify you when a cookie is being set or updated or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Google Chrome; Mozilla Firefox; or Apple Safari etc.). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Platform.

4.3 Information We Collect from Other Sources: We may receive additional information such as demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts, and other parties that we may attribute to you based on your assignment to certain statistical groups. We use this information to supplement the information that we collect directly from you in order to derive your possible interests and to provide more relevant experiences for you and improve our products, analytics, and advertising.

We may use your information that we collect for our legitimate business purposes, sometimes in aggregated or de-identified form- for the following purposes:

5.1. To Provide and Maintain the Service: To operate, maintain, and provide you with access to the Platform and its features, including processing your uploaded Case Materials for analysis, Image Captioning, Audio Transcription, AI Chatbot Document Classification, Data Extraction, Document Summarization, File Highlight & Redaction, Responsiveness Marking along with other features that we may develop or make available in the future.

5.2. AI Model Processing and Analysis: To utilize advanced AI models to analyze the uploaded case discovery data, generate insights, and provide the core functionality of the Services. After subscription, when you provide your information by uploading documents or data, we perform text extraction followed by AI processing. The data is then processed through large language models ("LLMs") deployed on GPU-based environments of third-party service provider. All AI processing is conducted within controlled environments managed by the Company or its infrastructure partners. No user data is sent to or processed by external APIs, unless explicitly authorized by the User in writing. AI-processed documents are converted into vector embeddings and stored using vespa database. These embeddings power the Platform’s chatbot, summarization, and semantic search capabilities. All the AI processing is strictly limited to the purposes of providing the requested analysis for the benefit of our Users, within the scope of the Services.

5.3. Service Improvement and Development: We may use your information to understand how Users interact with our Services, identify areas for improvement, conduct research, develop new features, and enhance the performance and accuracy of our AI models. This may involve using aggregated or de-identified data for research and development.

5.4. Customer Support: To respond to your inquiries, provide technical assistance, and resolve issues related to your use of the Service.

5.5. Account Management: To manage your user Account, process payments (as and when applicable), and send you Service-related communications.

5.6. Security and Fraud Prevention: To detect, prevent, and respond to security incidents, malicious activity, fraud, and other illegal activities, and to protect the integrity and security of our Service and data.

5.7. Legal and Compliance: To comply with our legal obligations, enforce our terms of service, and protect our rights and the rights of others.

5.8. Aggregate/Anonymous Data. We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors.

We will only process your Personal Information for purposes that are reasonably necessary for, or compatible with, the disclosed purposes for which such personal information was initially collected, unless we obtain your consent for a new purpose.

We do not sell your Personal Information to third parties for monetary or other valuable consideration. All processing is handled entirely within our infrastructure, ensuring its privacy and security. We may share User’s information in the following ways:

6.1. Affiliates and Subsidiaries: We may share Information we collect through our Platform, to perform Services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.

6.2. Service Providers: We may provide access to or share your information with select third parties who perform services on our behalf for business purposes. They have access to perform these services but are prohibited from using your information for purpose other than the intended purpose under this Policy. They provide a variety of services to us, including billing, sales, marketing, product content and features, advertising, analytics, research, customer service, data processing, data conversion, data storage, security, fraud prevention, payment processing, and legal services.

6.3. Protection of our rights and interests: By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith and belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order); (b) enforce our Terms and Conditions, the terms of usage/service, or other contracts with you, including investigation of potential violations thereof; (c) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (d) respond to claims that any content violates the rights of third parties; (e) respond to your requests for customer service; and/or (f) protect the rights, property or personal safety of us, our agents and affiliates, its users and/or the public; (g) to detect or prevent fraud or other illegal activity; or (h) to protect against legal liability. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.

6.4. Business Transfers: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. Your Information may be disclosed in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that Transaction along with other assets. We ensure that any third parties with whom we share your data are subject to a duty of confidentiality and are required to adhere to applicable privacy laws.

6.5. Public Forums or Other Users: When you share Personal information (for example, by posting comments, contributions or other content on our Websites or our social media platforms). Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, it is advisable to take utmost care when using these features.

6.6. Business Account Administrators: While you use our Platform, if you create an account using an email address belonging to your employer or another organization, we may share the fact that you have an account and certain account information, such as your email address, with your employer or organization.

6.7. Third Parties: We may need to share your Personal Information that you provide us with certain third parties, such as:

• other entities within our group as part of our regular reporting activities on company performance, in the context of a business reorganization or group restructuring exercise, or for assistance in relation to marketing and business development.

• professional advisers including lawyers, bankers, auditors and insurers to the extent such information is relevant to the performance of their Services;

• regulators; and

• any of our service providers where such information is relevant to their performance of such Services.

However, we will make our best efforts to ensure that the third party with whom the data is shared affords the same level of data protection as offered by us, or even better and secure protection of your personal information as compared to our data protection services.

6.8. Legal purposes: We reserve the right, in our sole discretion, to share or disclose your Personal Information in encrypted form, when required to do so by law or regulation, or under any legal obligation or under law or in response to a written request from a law enforcement or governmental agency or judicial, quasi-judicial, or any other statutory or constitutional authority:

• to respond to subpoenas, court orders, or legal process;

• in order to investigate, prevent, defend against, or take other action regarding violations of our Terms and Conditions, illegal activities, suspected fraud, or situations involving potential threats to the legal rights or physical safety of any person or the security of our network, sites or Platform;

• to respond to or defend against legal claims, without your consent;

• in an emergency, to protect the health and safety of our Platform, Users or the general public; or

• to establish or exercise our legal rights; or

• as otherwise required by any Applicable Law.

We shall not be held liable for any privacy violation in this regard.

6.9. Security Purposes: We may use your device ID for security purposes. For example, if you have activated a feature that limits access to a Platform from a specific device, our systems will access the device ID from each device you attempt to access the Platform with to determine if the device is the specific authorized device. Additionally, we may use device IDs to monitor suspicious activity. For example, if we detect that a single Account on a site is being accessed from multiple devices, as determined by tracking the device IDs that access an Account, we may contact the User to ensure that such access has been authorized by the User.

6.10. Links: Our website contains hyperlinks, which may direct you to websites that we do not own or control. This Privacy Policy does not apply to these websites, which are governed by their own rules and policies. We urge you to read the privacy and security policies of those websites.

6.11. Change Of Ownership: If the ownership or control of all or part of our Services or their assets changes, we may transfer your information to the new owner.

6.12. Aggregate/De-identified Information. From time to time, we may share Aggregate/De-identified Information about use of the Services, such as by publishing a report on usage trends. In such case, the anonymized data shall no longer be associated with you and will not be deemed a Personal information. The sharing of such data, in anonymized and/or aggregate form, shall be unrestricted.

6.13. Any Other Person with Your Consent: We may share your Personal Information with other third parties with your express consent.

We keep your information for no longer than necessary in order to provide our Services to you and for the purposes for which such data is collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements, and our legitimate interests in maintaining such Personal Information in our records, and strictly use it and/or as required to comply with Applicable Laws. In doing this, we will have regard to the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. All uploaded data is stored in a secured infrastructure. For Information that you provide us, we retain that data in accordance with the Terms and Conditions of our Platform. Depending on the status of subscription or requirement as per applicable laws and regulations we will retain the Users’ data/information. In some circumstances, your Personal Information may be anonymized so that it can no longer be associated with you, in which case it is no longer Personal Information. Once we no longer require your Personal Information for the purposes for which it was collected, we will securely destroy your Personal Information in accordance with applicable laws and regulations.

We follow reasonable security practices and procedures designed to protect the confidentiality, integrity, and accessibility of Information, and to secure Information during both storage and use from unauthorized acquisition, access, disclosure, alteration, or destruction. We regularly review and update our security measures to adapt to evolving threats. However, no absolute guarantee of security and error free services on the Internet or IT platforms can be fully given, and hence we cannot guarantee the absolute security of data that is physically or electronically stored or transmitted over the internet, and there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our safety and security safeguards. The security of your Information also depends on you. If you provide us with any Sensitive Personal Information when you use the services, you must consent to our processing and use of such Sensitive Personal Information in accordance with this Privacy Policy. If you do not consent to our processing and use of such Sensitive Personal Information, you must not submit such Sensitive Personal Information through our Services. Therefore, you should take special care in deciding what information you provide to the Services. In addition, we are not responsible for the circumvention of any privacy settings or security measures contained on the Platform, or third-party websites. You are advised to use the Platform at your own risk.

The Platform may contain links to third-party websites such as social media sites and third-party plug-ins. If you choose to use these sites or features, you may disclose your information not just to those third parties, but also to their users and the public more generally depending on how their services function. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information will be subject to the privacy policies of such third-party websites or services, and not the Terms and Conditions or this Privacy Policy. We request you to read the privacy and security policies of such third parties.

Depending on your jurisdiction of residence, you may have certain rights with respect to your information as further described in this section.

Your Privacy Rights: you may have the right to:

i. Right to know/access your Personal Information and information relating to how it is processed.

ii. Right to update or correct your Personal Information.

iii. Right to Delete your Personal Information from our records.

iv. Right to data portability allowing you to transfer your Personal Information to a third party.

v. Right to Opt-Out (Opt-Out of the sale of their Personal Information, its use for targeted advertising, and/or certain types of profiling)

vi. Right to restrict/object how we process your Personal Information.

vii. Withdraw your consent—where we rely on consent as the legal basis for processing at any time.

viii. Lodge a complaint with your local data protection authority.

ix. Right against Discrimination.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals.

Opt-out of communications: You may opt out by instructing us not contact you by email, postal mail, or phone regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. Please note that, regardless of your request, you may continue to receive Service-related and other non-marketing emails. For example, you may not opt-out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications based on the content accessed by you.

Declining to provide information. We need to collect Personal Information to provide certain Services. If you do not provide such information we identify as required or mandatory, we may not be able to provide those Services.

We will consider all requests and provide our response within the time period stated by Applicable Law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with the information necessary to confirm your identity before responding to your request.

Sensitive Personal Information: We do not use or disclose Sensitive Personal Information other than to provide you our Services as permitted by Applicable Law. We will not process Sensitive Personal Information concerning a User without first obtaining your explicit opt-in consent, or, in the case of processing Sensitive Personal Information concerning a known child, without processing such data in accordance with Children's Online Privacy Protection Act (“COPPA”), 1998. We do not sell or share Sensitive Personal Information for the purpose of cross-context behavioral advertising/ targeted advertising. We collect Sensitive Personal Information based on one or more of the following legal grounds:

• You have given explicit consent to the collection for one or more specified purposes;

• Where the collection of Sensitive Personal Information is manifestly made public by you; and/or

• Where the collection is necessary for exercise or defense of legal claims.

Children's Privacy: Our Service is not directed at children under the age of 13 years. We do not knowingly collect Sensitive Personal Information or Personal Information from children under the age of 13 years. If we become aware that we have collected Sensitive Personal Information or Personal Information from a child under the age of 13 years without appropriate consent, we will take steps to delete such information. We do not engage in targeted advertising or sale of Sensitive Personal Information or Personal Information, and therefore these specific consent requirements for minors in those contexts are not applicable to our Platform.

You can exercise privacy rights described in this section by submitting a request through support@procounsel.ai.

Appeals: Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights. To appeal a decision, please send your request to support@procounsel.ai.

You agree to defend, indemnify, and hold harmless us and our affiliates, officers, directors, employees, and agents from and against any and all claims, demands, cause of actions, proceedings, liabilities, losses, damages, judgments, settlements, fines, penalties, and costs (including reasonable attorneys’ fees) arising out of or related to (i) the legality, accuracy, or illegality of any Case Materials or User Content or other content you supply, or our processing of such content in accordance with your instructions; (ii) your misuse or unauthorized use of the Platform; or (iii) any allegation that your content or conduct infringes, misappropriates, or otherwise violates the intellectual-property, privacy, or other rights of a third party.

This section is for California residents and supplements the information contained in Our Privacy Policy. It provides additional information as to how you may exercise your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

SOURCES OF PERSONAL INFORMATION:

We obtain the categories of personal information listed above from the following categories of sources:

• You, through the use of our Services;

• Automatically from You;

• From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

CATEGORIES OF PERSONAL INFORMATION:

The following sections provide, categories of Personal Information from California residents collected, the Business/ commercial purpose, and with whom we may disclose Personal information with for business/ commercial purposes, in the last twelve (12) months.

We may collect the following Personal Information:

• Identifiers: Account information, Contact data, Demographic data, Profile data, Transactional data, Communications data, User content, Third-party sources data and other identifiers, Legally protected classifications, and Gender.

• Commercial information: Your transaction history, payment information, and payment history.

• Communication information: Your contact information when you send us email/message/call/ otherwise and its contents.

• Social Media Information

• Network activity information: Cookies Information, Device data, Online activity data.

• Geolocation data: Based on IP address, precise location information you choose to provide.

• Professional or employment-related Information: Such as name of your employer/ organization.

• Education Information: where you voluntarily provide us with such information.

• Inferences drawn: From other information we collect

PURPOSE OF COLLECTION

We collect, use, disclose the categories of Personal Information for the following purposes:

• Provide, analyze, and maintain our Services;

• Utilize advanced AI Model for Processing and Analysis of the uploaded information;

• Service Improvement and Development;

• Customer Support and Communication with Users;

• Maintain Account Management;

• Prevent fraud, illegal activity, or misuses of our Services, and to protect the security of our systems and Services;

• Comply with legal obligations and protect the rights, privacy, safety, or property of our users, or third parties.

We may disclose such collected information with your consent for business purposes or commercial purposes to the following:

• Affiliates and Subsidiaries;

• Service providers, and affiliates to process in accordance for business purposes;

• Business Transfers as detailed above;

• Marketing and Advertisement partners;

• Government authorities, Judicial authorities or other third parties for the legal reasons described above;

• Business account administrators for the reasons described above;

• Other users and third parties you interact or share information with;

• Others with your consent.

SENSITIVE PERSONAL INFORMATION:

We may collect Sensitive Personal Information as per the CCPA for the following purposes:

• To provide and improve our Services;

• To maintain the quality and safety of our Services and products;

• To prevent, detect, investigate security incidents;

• To resist illegal, fraudulent actions against Us;

We do not use or disclose Sensitive Personal Information for purposes for which you have a right to limit under the CCPA. We also do not process Sensitive Personal Information for the purposes of inferring characteristics about a User.

DO NOT SELL OR SHARE MY PERSONAL INFORMATION

We do not sell your Personal Information. We do not “sell” or “share” Personal Information for cross-contextual behavioral advertising, and we do not process Personal Information for “targeted advertising” purposes. We do not knowingly “sell” or “share” the Personal Information of Users under 16 years of age.

YOUR CALIFORNIA PRIVACY RIGHTS: As a California resident, you have the rights listed below. However, these rights are not absolute, and, in certain cases, we may decline your request as permitted by law:

i. Right to deletion of your Personal Information: You have the right to request us to delete your Personal Information that you provided us and may be collected by us.

ii. Right to correct your Personal Information: You have the right to request correction of any inaccurate personal information regarding you that we may have maintained.

iii. Right to know: You have the right to request us to disclose (i) The categories of personal information it has collected about that you; (ii) The categories of sources from which the personal information is collected; (iii) The business or commercial purpose for collecting, selling, or sharing personal information; (iv) The categories of third parties to whom we disclose personal information; (v) The specific pieces of personal information it has collected about you. You have the right to know what Personal Information is being sold or shared and with whom or discloses for any business purpose.

iv. Right to Opt-Out of Sale/Sharing of your Personal Information: If you are a California resident, you have the right to request to opt-out of the sale or sharing of your Personal Information being sold/ shared outside of the permitted purposes.

v. Right to Limit Use of Personal Information: You have the right to request to limit use of Sensitive Personal Information for purposes other than those for which right to limit use is not applicable.

vi. Right to Non-Discrimination: You are entitled to exercise the rights described above free from discrimination.

HOW TO EXERCISE YOUR RIGHTS:

You can exercise privacy rights described in this section by submitting a request through support@procounsel.ai. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity with us. Authorized agent requests can be submitted to support@procounsel.ai.

Verification: For security purposes, we may request additional information from you to verify your identity when you request to exercise your rights related to your personal information. If we cannot verify your identity, we will not be able to honor your request.

Appeals: To appeal a decision, you may send your request to support@procounsel.ai.

RETENTION OF YOUR PERSONAL INFORMATION:

Please refer to Section-7 above.

The most current version of this Privacy Policy document will govern our use of your data and can be found on our Platform (see “Privacy Policy” section). We reserve the right to update this Privacy Policy, at any time, and we will make an updated copy of such Privacy Policy available to you and notify you when we make any substantial updates. We advise you to review the Privacy Policy at regular intervals.

For any questions or reasonable inquiry related to the protection of your data at ProCounsel or regarding this Policy in general, you can contact ProCounsel’s Privacy Office at support@procounsel.ai.

Please keep in mind that email communication is not always secure. Therefore, please do not include Sensitive Personal Information in your emails to us.

We will do our best to address your request in time and free of charge, except where it would require a disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request. If you are unsatisfied with the reply received, you may then refer your complaint to the relevant regulator in your jurisdiction.