Privacy Policy

1 About CAMNY LTD and this notice

1.1 Who we are

CAMNY LTD (“CAMNY”, “we”, “our”, “us”) is a private limited company registered in England & Wales (company no. [•••]) with its registered office at 20 Wenlock Road, London, N1 7GU.

1.2 What we do

We provide AI-native legal-services software and attorney-review workflows (“Services”) via the domains clarisign.aiand camny.co (“Sites”) and through related mobile or desktop applications (“Apps”).

1.3 Why this notice matters

This Privacy Policy explains what personal data we collect, how and why we process it, the lawful bases we rely on, the rights you have, and how you can exercise those rights.

It applies to:

  • visitors to our Sites or Apps;

  • registered users (clients, attorneys, collaborators);

  • newsletter subscribers and event attendees;

  • job applicants and contractors.


1.4 Key laws we comply with

Region

Applicable law

United Kingdom

UK GDPR (as incorporated by the Data Protection Act 2018)

European Economic Area

EU GDPR (Regulation 2016/679)

United States (California)

CCPA / CPRA (California Civil Code § 1798.100 ff.)

Other regions

Local data-protection and e-privacy statutes as applicable

2 The data we collect and how we obtain it


Data category

Typical examples

How we obtain it

Purposes (linked to legal bases in § 3)

Identity Data

full name, title, date of birth, bar-admission ID

provided by you during signup / KYC

A-1, A-2, B-1

Contact Data

e-mail, phone, postal address, social-media handle

provided by you; obtained from public sources (e.g., Companies House)

A-1, B-1

Account Data

username, hashed password, MFA token

created by you in the App

A-1

Matter Content

contracts, exhibits, litigation briefs, comments

uploaded by you or your authorised users

A-2

Usage Data

login timestamps, feature clicks, error logs, heat-maps

collected automatically via cookies / SDKs

C-1, D-1

Payment Data

last 4 digits of card, Stripe token, invoice history

processed via Stripe Payments (we never store raw card numbers)

A-3

Marketing Preferences

newsletter opt-in status, event RSVP

provided by you

C-2

Recruitment Data

CV, cover letter, interview notes, right-to-work docs

provided by candidate; created by us during hiring

E-1

(Internal reference keys A-1 … E-1 map to the lawful-basis table in § 3.2.)

3 Why we process your data and our lawful bases

3.1 Purpose matrix


Code

Purpose description

A-1

Create and administer user accounts; provide secure login and access tokens.

A-2

Deliver the core Services (AI drafting, red-lining, attorney review, e-signature, storage).

A-3

Process payments, issue invoices, manage collections.

B-1

Respond to support tickets, product-feedback requests, dispute-resolution inquiries.

C-1

Monitor, debug and improve Site / App performance and security.

C-2

Send product updates, newsletters, and event invitations (only if you opt-in).

D-1

Compile anonymous analytics and usage statistics to guide product development.

E-1

Conduct recruitment, background checks and onboarding of staff or contractors.

3.2 Legal-basis table (UK GDPR / EU GDPR Article 6)


Purpose codes

Lawful basis

Explanation

A-1, A-2, A-3, B-1

Contract (Art 6 (1)(b))

Processing is necessary to perform the contract with you.

C-1

Legitimate interests (Art 6 (1)(f))

We need minimal logs to keep our platform reliable and secure.

C-2

Consent (Art 6 (1)(a))

We only send marketing if you have opted in; you can withdraw any time.

D-1

Legitimate interests

Aggregated analytics do not override your privacy rights.

E-1

Pre-contractual steps / legal obligation (Art 6 (1)(b),(c))

Required to assess suitability and comply with employment law.

For residents of California, UK GDPR lawful bases align with “Business Purpose” or “Commercial Purpose” categories in CPRA § 1798.140.


4 Cookies, SDKs and similar technologies

4.1 Types used

  • Essential cookies (session token, CSRF)

  • Performance cookies (page-load timing)

  • Functional cookies (language selection)

  • Analytics SDKs (Plausible Analytics self-hosted)

  • No third-party advertising cookies.

4.2 Opt-out / consent

On first visit we present a GDPR-compliant banner. Non-essential cookies are disabled until you click “Accept” or customise settings.

5 Data sharing and sub-processors


Category

Recipient

Location

Safeguards

Payment processing

Stripe Payments Europe Ltd.

IE / US

Standard Contractual Clauses (SCC 2021)

Cloud hosting

AWS (eu-west-2), Cloudflare (UK)

UK

UK Binding Corporate Rules; ISO 27001

Document storage

AWS S3 encryption-at-rest (AES-256)

UK

Same as above

E-mail delivery

Postmark (Wildbit LLC)

US

SCC 2021

AI model hosting

OpenAI - Azure OpenAI Service, West Europe region

NL

EU Data Boundary, SCCs

Video-call provider

Whereby UK Ltd.

UK

DPA 2018 compliant

Analytics

Plausible self-host (DigitalOcean AMS3)

NL

No personal data stored

We update this table in real time at clarisign.ai/termsofuse.

6 International transfers

  • All primary data reside in UK Amazon datacentres.

  • When we engage a US sub-processor, we rely on SCCs and supplement with encryption in transit (TLS 1.3) and at rest (AES-256).

  • We do not rely on Privacy Shield.


7 Retention schedule


Data type

Standard retention

Deletion / destruction method

Account & Identity

6 years after final invoice (HMRC audit window)

Encrypted archival → secure erase

Matter Content

90 days after workspace deletion (configurable to 0)

S3 object purge + version wipe

Payment tokens

As long as active subscription + 13 months for chargebacks

Stripe automatic purge

Support logs

24 months

Logrotate + encryption key shred

Analytics (aggregated)

Indefinite (no personal data)

N/A


8 Your rights

8.1 For UK / EU data subjects:


  • Right of access (Art 15)

  • Rectification (Art 16)

  • Erasure / “right to be forgotten” (Art 17)

  • Restriction (Art 18)

  • Portability (Art 20)

  • Objection (Art 21)

  • No automated decision-making with legal effect (Art 22)


8.2 To exercise: e-mail privacy@clarisign.ai with subject line “Data-rights request” and include details to verify your identity. We respond within 30 days.


8.3 Complaints: You may lodge a complaint with the UK Information Commissioner’s Office (ICO) at ico.org.uk or your local EU supervisory authority.

9 Security measures

  • ISO 27001-aligned risk management programme.

  • SOC 2 Type II audit in progress (expected Q3 2025).

  • All traffic encrypted in transit (TLS 1.3 with HSTS).

  • Data encrypted at rest (AES-256-GCM, AWS KMS).

  • MFA enforced for admin accounts; optional for users.

  • Daily off-site backups; quarterly disaster-recovery tests.

  • Independent penetration testing every 12 months.

10 Children

Our Sites and Services are not directed to individuals under 18. We do not knowingly collect children’s data. If you believe a minor has provided personal data, contact privacy@clarisign.ai and we will delete it promptly.

11 Links to third-party sites

Our Sites may contain links to external sites (e.g., HM Land Registry, Companies House). We are not responsible for their content or privacy practices.

12 Changes to this Policy

Version 1.0 – 21 May 2025.

We will post any future changes at clarisign.ai/privacy and, for material changes, notify registered users by e-mail at least 14 days before they take effect.

13 Contact us

Data Controller

CAMNY LTD

20 Wenlock Road

London, N1 7GU

United Kingdom


Data Protection Officer

Nikita Bezotosnyi

E-mail: privacy@clarisign.ai

Tel: +49 170 175 0619