1. Introduction
Counsely ("the App", "we", "our") is an AI-powered contract assistant for iOS that helps users analyze and create legal documents. We are committed to protecting your privacy and being transparent about how your data is handled.
This Privacy Policy describes what information we collect, how we process it, and your rights regarding your data.
2. Data We Collect
2.1 Data Processed On-Device (Never Leaves Your Phone)
- Document images and scans: Photos taken with the camera or imported from your device are processed entirely on-device using Apple Vision (OCR). These images are never uploaded to any server.
- Extracted text: The text extracted from your documents via OCR remains on your device unless you explicitly choose to send it for AI analysis.
- Generated titles: Document titles are generated on-device using Apple NaturalLanguage framework. No network request is made.
- App preferences: Settings such as onboarding status and display preferences are stored locally via AppStorage.
2.2 Data Sent to External Services (With Your Consent)
- Contract text for AI analysis: When you choose to analyze a contract with AI, the extracted text is sent to an external AI provider for risk assessment. This only happens after you explicitly confirm a consent dialog.
- Contract answers for AI generation: When you create a contract, your answers to the Q&A wizard are sent to an external AI provider to generate the contract draft. This also requires your explicit consent.
Important: We do not send any data to external services without your explicit, per-document consent. Each analysis or generation request requires a separate confirmation.
2.3 Data We Do NOT Collect
- We do not collect personal information (name, email, phone number) through the App.
- We do not use advertising frameworks or tracking pixels.
- We do not collect device identifiers for advertising purposes.
- We may collect anonymous usage analytics (such as feature usage frequency, screen views, and crash reports) to improve the app experience. This data does not include your document content, contract text, or personal information.
- We do not access your contacts, location, microphone, or any data beyond camera access (for document scanning) and the files you explicitly import.
3. How We Process Your Data
3.1 On-Device Processing
All document scanning (OCR) is performed using Apple Vision framework directly on your device. Your document images are never transmitted over the network. This is a core design principle of Counsely.
3.2 AI Processing
When you consent to AI analysis or contract generation:
- Your text is sent via encrypted HTTPS connection to an external AI provider.
- The AI provider processes your text to generate analysis results or contract drafts.
- The AI provider does not store your data for model training purposes.
- The AI provider does not retain your data beyond the duration of the API request.
- We do not maintain a backend server — requests go directly from your device to the AI provider.
3.3 Local Storage
All app data — documents, analyses, generated contracts, and usage history — is stored locally on your device using Apple's SwiftData framework. We do not have access to this data. It is not synced to any cloud service.
3.4 Analytics
We use Firebase Analytics to collect anonymous usage data, including:
- Feature usage frequency (e.g., how often analysis or creation features are used)
- Screen views and navigation patterns
- Crash reports and performance metrics
- General device information (device model, OS version, app version)
This data helps us improve the app experience. Analytics data never includes your document content, contract text, or personal information. Analytics data is processed by Google Firebase in accordance with their privacy policy.
3.5 Purchase Data
In-app purchases and subscriptions are processed entirely by Apple through StoreKit. We do not have access to your payment information. Apple's privacy policy governs the handling of purchase data.
4. AI Transparency (EU AI Act)
In accordance with the EU AI Act (Regulation 2024/1689, Article 50):
- All content generated by Counsely — including contract drafts, risk analyses, and summaries — is clearly marked as AI-generated within the App and on exported PDF documents.
- AI-generated content does not constitute legal advice. Users should consult a qualified legal professional before acting on any AI-generated analysis or contract.
- The AI system used by Counsely is a general-purpose large language model accessed via API. It is not a high-risk AI system under Annex III of the EU AI Act.
5. Data Retention
- On-device data: Retained until you delete it (via swipe-to-delete in History) or uninstall the App.
- AI provider data: Not retained by the AI provider beyond the API request duration. No data is stored for training.
- Analytics data: Retained by Firebase per Google's data retention policies. You can opt out of analytics collection in your device settings.
- Purchase history: Managed by Apple per their data retention policies.
6. Data Sharing
We do not sell, rent, or share your data with third parties, except:
- AI provider: Contract text is sent to the AI provider solely for the purpose of analysis or generation, only with your explicit consent, as described in Section 3.2.
- Firebase (Google): Anonymous usage analytics and crash reports are collected as described in Section 3.4. No document content or personal information is shared.
- Apple: Purchase transactions are processed by Apple via StoreKit.
- Legal obligations: We may disclose data if required by law, court order, or governmental request.
7. Your Rights
Under GDPR (EU/EEA Users)
You have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase your data ("right to be forgotten")
- Restrict processing
- Data portability
- Object to processing
- Withdraw consent at any time
Since all data is stored locally on your device, you can exercise most of these rights directly by managing or deleting data within the App. To erase all data, simply uninstall the App.
Under LGPD (Brazilian Users)
You have equivalent rights under Brazil's Lei Geral de Proteção de Dados (LGPD), including the right to access, correct, anonymize, block, or delete your data. Contact us at the email below for any LGPD-related requests.
Under CCPA (California Users)
You have the right to know what personal information is collected and to request its deletion. We do not sell personal information.
8. Children's Privacy
Counsely is not directed at children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us and we will delete it promptly.
9. Security
- All communications with the AI provider use HTTPS encryption (TLS 1.2+).
- API credentials are stored in the iOS Keychain, which provides hardware-backed encryption.
- On-device data is protected by iOS data protection (encrypted at rest when the device is locked).
10. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be reflected in the "Last Updated" date above. Continued use of the App after changes constitutes acceptance of the updated policy.
11. Contact
For questions, concerns, or data rights requests:
Email: caetano.neto@gmail.com