Privacy Policy

1. Introduction

1.1This privacy policy applies to all customers of Clerk'r, including administrators and users who access the Clerk'r platform on behalf of their organisation (collectively "you" or "the Customer"). Parts of this privacy policy further apply to visitors on our website clerkr.ai.

1.2Clerk'r is a legal document management and agentic AI platform for law firms. In providing this platform, Clerk'r processes personal data about users and, indirectly, personal data contained in the documents that customers upload to the platform.

1.3This policy explains which personal data Clerk'r collects and processes, how and why it is processed, the legal basis for that processing, who has access to the data, and what rights you have. It also describes how Clerk'r protects personal data and how you can contact us with any questions.

2. Data Controller

2.1Clerk'r is the data controller for the processing of personal data relating to user accounts, usage data, and cookies.

2.2In relation to documents and other content uploaded by the Customer to the platform, the Customer (the law firm) is the data controller and Clerk'r acts as a data processor pursuant to Article 28 of the GDPR. Processing of uploaded content is governed by the Data Processing Agreement ("DPA") entered into between Clerk'r and the Customer.

2.3Contact details for Clerk'r can be found in section 11 below.

3. Personal Data Processed

3.1Personal data means all information that can directly or indirectly be attributed to a natural person. The personal data that Clerk'r collects and processes includes:

User account data (information provided when creating and maintaining a user account)

• Name
• Work email address
• Password (stored as a bcrypt hash; the plaintext password is never stored or logged)
• Organisational affiliation and role (e.g. admin, lawyer, user)

Usage and technical data (data generated through use of the platform)

• Log data, including IP address, browser type, operating system, timestamps and pages visited
• Chat history, including queries submitted and responses generated
• Document metadata, including file name, upload time, matter reference, and document category
• Session tokens and authentication events

Content data (uploaded documents)

3.2When the Customer uploads documents to the platform, those documents may contain personal data about the Customer's own clients, counterparties, employees, or others (collectively "End-Client Data"). Clerk'r processes such End-Client Data solely on behalf of the Customer, in accordance with the DPA and the Customer's instructions.

3.3End-Client Data may include information such as:

• Names, addresses, and contact details of natural persons
• Financial information, such as salary, fees, and bank details
• Employment information, such as employment terms, leave, and HR records
• Health information, where uploaded as part of legal case documents
• Any other personal data contained in legal documents uploaded by the Customer

3.4Clerk'r does not access, review, or use End-Client Data for any purpose other than operating the platform.

Cookie data

3.5Information collected through cookies and similar technologies is described in section 7 below.

(collectively "Personal Data")

4. Legal Basis and Purpose

Performance of the contract (Article 6(1)(b) GDPR)

4.1Clerk'r processes user account data and usage data to provide the platform and fulfil its obligations under the subscription agreement with the Customer. This includes:

• Creating and maintaining user accounts
• Enabling access to the platform and its features
• Storing, parsing, and retrieving uploaded documents
• Processing chat queries and generating AI-assisted responses

Legitimate interests (Article 6(1)(f) GDPR)

4.2Clerk'r may process certain Personal Data on the basis of legitimate interests, where those interests are not overridden by the data subject's rights and freedoms. This includes:

• Product analytics and error tracking to monitor platform performance and identify technical issues (using PostHog EU Cloud, which records event metadata only, never document content)
• Security monitoring, access control, and fraud prevention
• Session recordings configured to mask all text inputs and document content areas

Legal obligations (Article 6(1)(c) GDPR)

4.3Clerk'r may process Personal Data to comply with applicable legal obligations, including obligations under GDPR, Danish data protection law, and other applicable regulation.

Consent (Article 6(1)(a) GDPR)

4.4Where Clerk'r processes Personal Data based on consent (e.g. for optional analytical cookies), such consent is voluntary and may be withdrawn at any time without negative consequences for the Customer's access to the platform.

Processing as data processor

4.5Where Clerk'r processes End-Client Data on behalf of the Customer, the legal basis for that processing is determined by the Customer as data controller. Clerk'r processes such data solely on documented instructions from the Customer.

5. Recipients and Sub-processors

Disclosure to third parties

5.1Clerk'r does not sell or rent Personal Data to third parties. Clerk'r may disclose Personal Data to:

• Sub-processors engaged to operate the platform (see section 5.3 below)
• Public authorities or courts, where required to do so by applicable law or a binding legal order
• Professional advisors, such as lawyers and auditors, where necessary and subject to confidentiality obligations

5.2Clerk'r always seeks to limit access to Personal Data to what is strictly necessary for the recipient to perform their task or deliver their service.

Sub-processors

5.3Clerk'r engages sub-processors for cloud hosting, customer support, analytics, payment processing and IT security.

Cross-organisational isolation

5.4Every database query is scoped by organisation at the SQL layer. A document uploaded by one Customer organisation is structurally inaccessible to any other Customer organisation's users: not by application policy, but by the database query itself.

6. Transfer of Personal Data to Third Countries

6.1All systems that process or store Customer document content are hosted within the European Union. Clerk'r's primary infrastructure is located in the EU.

6.2Where a sub-processor operates outside the EU/EEA, for example if Resend routes transactional email through non-EEA infrastructure, Clerk'r ensures that any such transfer is subject to appropriate safeguards under the GDPR, including Standard Contractual Clauses or an adequacy decision.

6.3The Anthropic direct API (US-hosted) is a last-resort fallback that is disabled by default. If it is ever activated, Standard Contractual Clauses apply.

7. Cookies

What are cookies?

7.1Cookies are small text files placed on your device when you access the Clerk'r platform. They allow the platform to remember your session and preferences, and help Clerk'r understand how the platform is used.

Types of cookies used

7.2Clerk'r uses the following categories of cookies:

7.2.1Strictly necessary cookies

7.2.1.1These cookies are essential for the platform to function. They cannot be disabled. They include session cookies which manage your authenticated session. This cookie is secure (only sent over HTTPS), and valid for 30 days (refreshed every 24 hours of activity).

7.2.2Analytics and performance cookies (PostHog)

7.2.2.1With your consent, Clerk'r uses PostHog EU Cloud to collect anonymised event data about how the platform is used (e.g. "document uploaded", "chat message sent"). PostHog does not receive document content, file names, or any personal data beyond a pseudonymous user ID and event metadata. Session recordings are configured to mask all text inputs and the entire document content area.

7.2.2.2No third-party advertising or tracking cookies are used on the Clerk'r platform.

Cookie consent and management

7.3You can manage your cookie preferences through the cookie settings available in the platform. Consent to analytics cookies can be withdrawn at any time without affecting your use of the platform.

8. Security

8.1Clerk'r has implemented technical and organisational security measures to protect Personal Data against unauthorised access, alteration, and deletion. These measures include:

• Encryption in transit: all traffic to the Clerk'r application uses HTTPS (TLS). Internal service-to-service calls within the same private network use plain HTTP; calls between Railway services that cross the public internet use HTTPS.
• Encryption at rest: AWS S3 objects are encrypted at rest using AES-256 (SSE-S3). The PostgreSQL database is encrypted at rest by Railway. Application secrets and OAuth tokens are encrypted using AES-256-GCM before being stored in the database.
• Authentication and access control: passwords are stored as bcrypt hashes (cost factor 10). Session tokens are single-use and time-limited. Every user belongs to exactly one organisation, and cross-organisation access is structurally prevented at the database level. Role-based access control limits features to authorised roles (e.g. only admin users can manage team members).
• Data isolation: all database queries are scoped by organisation, ensuring complete logical separation between customers.
• Backup and recovery: automated database backups are performed daily. Backup retention periods are described in Clerk'r's Data Processing Agreement.
• Sub-processor oversight: Clerk'r requires all sub-processors to maintain appropriate security standards and process Personal Data only for the purposes for which it was disclosed.

9. Retention

9.1Clerk'r retains Personal Data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

• User account data is retained for the duration of the Customer's subscription and deleted within a reasonable period following contract termination.
• Uploaded documents and content data are retained for the duration of the subscription. On contract termination or written request, Clerk'r deletes the Customer's S3 objects, database rows, and chunk embeddings. Exports in DOCX or PDF format are available from the platform at any time.
• Usage logs and analytics data are retained in accordance with the relevant sub-processor's retention policy (PostHog EU) and Clerk'r's internal retention schedule.
• Backup data is subject to a separate retention period as described in the DPA.

9.2When data is no longer needed, it is deleted or anonymised.

10. Your Rights

10.1Under the GDPR, you have the following rights in relation to the Personal Data that Clerk'r processes as data controller:

• Right of access to the Personal Data processed about you (Article 15 GDPR)
• Right to rectification of inaccurate Personal Data (Article 16 GDPR)
• Right to erasure of Personal Data in certain circumstances ("right to be forgotten") (Article 17 GDPR)
• Right to restriction of processing in certain circumstances (Article 18 GDPR)
• Right to data portability (Article 20 GDPR)
• Right to object to processing based on legitimate interests (Article 21 GDPR)
• Right to withdraw consent at any time, where processing is based on consent (Article 7(3) GDPR)
• Right to lodge a complaint with a supervisory authority (Article 77 GDPR)

10.2In Denmark, the supervisory authority is Datatilsynet (www.datatilsynet.dk).

10.3Requests relating to your rights can be submitted to Clerk'r using the contact details in section 11 below. Clerk'r will respond within 30 days.

Note on End-Client Data

10.4Where you wish to exercise rights relating to personal data contained in documents uploaded by your organisation (End-Client Data), those rights must be directed to the Customer (law firm) as data controller. Clerk'r will assist the Customer in responding to such requests.

11. Contact

11.1If you have questions about this policy or about how Clerk'r processes your personal data, please contact:

12. Updates to This Policy

12.1Clerk'r may update this policy from time to time. Where changes are material, Clerk'r will notify Customers with reasonable advance notice. The current version of the policy is always available at https://clerkr.ai/en/privacy-policy.