Last Updated:

January 1, 2025

Copilex Data Protection and Privacy Policy

Last update: 1st January 2025

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1. Preamble

This Privacy Policy (“Privacy Policy”) applies to all processing activities by Gatewai technologies & Services SAS, a company registered under the laws of France, having its seat at 61 rue de Lyon, 75012 Paris, operator of the Legal-AI assistant “Copilex” and owner of the Copilex Brand (thereafter “Gatewai”), in its capacity as a data controller.

This Privacy Policy may be modified in the future to reflect changes in the applicable legislation, or for any other reason justifying its change.

The most recent version is the one into force and remains accessible on our website at the following location: www.copilex.com/legal/data.

Our relationship with you may result in the collection, storage, and processing of personal data relating to you, or, if you represent a company, your employees or representatives (“personal data”). This relationship can arise out of a contractual relationship between you or your company and Gatewai, recent interactions, or visits or actions on our website (www.gatewai.tech, or www.copilex.com, including their respective related sub-domains, thereafter “Website”).

This Privacy Policy details (i) how we gather, handle, and store personal data; (ii) the rights you can exercise regarding your personal data; and (iii) the measures we implement to secure and safeguard your personal data.

Gatewai respects your privacy and is committed to complying with applicable privacy laws, including (but not limited to): (i) the General Data Protection Regulation 2016/679 of April 27, 2016 (“GDPR”), (ii) the French Loi n° 78-17 du 6 janvier 1978 relative à l'informatique, aux fichiers et aux libertés, including future modifications and updates thereof; and (iii) any future national, regional or international legislation concerning the implementation of the GDPR applicable to Gatewai (collectively: “Privacy Legislation”).

2. Data Controller

Gatewai develops and provides Legal AI solutions branded under the name “Copilex”, as presented on the Website (the “Solution”), and delivers corresponding services (“Service”).

In terms of the Privacy Legislation, Gatewai acts as the DATA CONTROLLER for personal data for the purposes detailed in this Privacy Policy.

This implies we are in charge of (and thus, accountable for) your personal data.

3. Gatewai’s Processing Activities

The types of personal data we gather, store, and process, as well as the purposes for these processing activities, are tailored to the needs of your relationship with Gatewai.

In keeping with our commitment to privacy and data minimization, we limit the data we collect to only those necessary for providing our services and improving user experience.

When you create an account with Copilex, we store the following personal data:

  • First name
  • Last name
  • Email address
  • Organization Name (optional)
  • Role in your organization (optional)

The collection of this information allows us to provide personalized services, manage your account, facilitate customer support, and maintain the security of our platform. This data is kept secure and is not shared with third parties without your explicit consent.

In addition to the above, we process documents that you upload into the Solution for analysis or drafting assistance purposes

Depending on your contract with us, these documents can be stored in our servers, based in Europe, or in any other country contractually agreed between your organization and us. In some cases, based depending on the contract passed by your organization and Gatewai, documents are pseudonymized on your organization’s premise before storage, meaning all identifiable information is removed. We maintain the pseudonymized contract content in our systems to enhance our services and provide relevant insights.

The specific data collected, and the ways we use it may further vary depending on the nature of your interaction with Gatewai (browsing our website, receiving marketing information, seeking a business relationship with us, or being a client, a partner or supplier). We strive to be transparent and will inform you about specific processing activities where necessary.

4. Legal Basis for Processing

The legal grounds for the processing activities are based on consent, the execution of a contract, or our legitimate interests, such as improving our services and protecting our users' security. We retain this data according to legal requirements and as long as it is necessary for the purposes for which it was collected.

As per Privacy Legislation, you have specific rights relating to your personal data, including the right to access, correct, delete, restrict or object to our use of your data.

Whenever the legal basis for processing is legitimate interest, Gatewai will carefully balance this interest against the purpose for which your personal data was collected and your reasonable expectations. We will also ensure that your fundamental rights and freedoms are not infringed. If we cannot guarantee this balance, we will cease to store/use your personal data or establish a new legal basis.

5. Data Retention Periods

Gatewai will retain your personal data for as long as necessary to fulfill the purpose for which it was collected unless a longer storage period is mandated or justified by law or other legal obligations.

As the solution evolves and varies according to each contract, we remain at your disposal to give you the most relevant information applicable to you. Contact us at data@copilex.com

6. Disclosure of Personal Data to Third Parties

Gatewai will only disclose your personal data to third parties if required for the purposes outlined in this Privacy Policy. This might involve sharing your personal data with: Software and cloud service providers, Freelancers or other service providers

We have implemented necessary contractual measures to ensure that these third parties treat your personal data in accordance with applicable privacy regulations (e.g. Article 28 GDPR).

Additionally, we may disclose your personal data:

  • In M&A context: If Gatewai or its assets are acquired by a third party, your personal data may be part of the transferred assets. In this event, you will be informed in advance of any transfer.
  • To competent authorities: if legally required or necessary to protect our rights, or in the context of (future) legal proceedings.

7. Cross-border Processing of Personal Data

If any of the third parties mentioned above are located outside the European Economic Area, Gatewai ensures the implementation of EU-approved safeguards, such as:

  • European Commission adequacy decisions
  • Data transfer agreements (per the Standard Contractual Clauses provided in the European Commission Implementing Decision (EU) 2021/914 of 4 June 2021, including a transfer impact assessment)
  • Binding corporate rules
  • Certification mechanisms

8. Your Privacy Rights

You have certain rights over your personal data under privacy regulations (e.g., GDPR). These rights can be exercised by contacting us, as detailed in Section 11, and by using the Data Subject’s Rights Form.

9. Security

Gatewai is committed to taking appropriate physical, technological, and organizational precautions to prevent unauthorized access, loss, misuse, or alteration of your personal data.

10. Updates to this Policy

We reserve the right to update this Privacy Policy by posting a revised version on our website, with the revision date indicated at the top. We recommend regularly checking this page to stay informed about any changes.

11. Contact

For notifications under this Privacy Policy (such as exercising your rights as a data subject) and/or any queries or concerns about this Privacy Policy, please reach out to our Data Protection Officer at data@copilex.com

If you are dissatisfied with how we collect, store, or process your personal data, please let us know and we will take necessary steps to rectify this situation.

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