Legal

Privacy Policy

Last updated: March 2026

LexSutra is a compliance infrastructure company. We hold ourselves to the same standards we help our clients meet. This policy is written in plain language — if something is unclear, email us at hello@send.lexsutra.com.

1. Who We Are

Data Controller: LexSutra, Netherlands.

Contact: hello@send.lexsutra.com · lexsutra.com

Supervisory Authority: Autoriteit Persoonsgegevens (AP), Netherlands — autoriteitpersoonsgegevens.nl

LexSutra provides EU AI Act compliance diagnostic services to businesses. We are not a law firm and do not provide legal advice. This privacy policy applies to our website (lexsutra.com), our client portal, and our diagnostic platform.

2. What Data We Collect

DataPurposeLawful Basis
Name, email, company nameDemo requests and enquiries from our websiteLegitimate interest — responding to business enquiries
Company website URLAutomated public footprint scan as part of the diagnosticLegitimate interest — service delivery
Google account details (name, email)Authentication via Google SSO for portal accessContract performance
Questionnaire responsesCore input to the EU AI Act compliance diagnosticContract performance
Uploaded documentsEvidence base for diagnostic findings (OTP-confirmed)Contract performance
Activity logs (who did what, when)Security, audit trail, and compliance record-keepingLegitimate interest — security and legal obligation
IP address, browser typeSecurity and fraud preventionLegitimate interest — security
Error logsPlatform reliability and debuggingLegitimate interest — service improvement

We do not collect or process special category data (health, biometric, political, religious data) and we do not collect data about individuals under 18.

3. How We Use Your Data

We use your data only for the purposes listed above. Specifically:

  • To deliver the compliance diagnostic service you have contracted with us
  • To generate AI-assisted findings drafts (see Section 5 — AI Processing)
  • To send you your diagnostic report and related communications
  • To respond to demo requests and pre-sales enquiries
  • To maintain security, prevent fraud, and keep an audit trail
  • To comply with our own legal obligations

We do not sell your data. We do not use your data for advertising. We do not share your data with third parties except as described in Section 4.

4. Data Processors & Third Parties

We share data with the following processors, all under written data processing agreements. These companies act only on our instructions and cannot use your data for their own purposes.

Supabase

EU region (Frankfurt, Germany)

Database, file storage, and authentication. All client data, documents, and questionnaire responses are stored here.

supabase.com/privacy

Anthropic

United States (EU transfer covered — see Section 5)

AI-assisted findings generation. Questionnaire responses are sent to Claude (Anthropic) to generate initial diagnostic drafts, reviewed by our team before delivery.

anthropic.com/legal/data-processing-addendum

Resend

United States

Transactional email — OTP codes, portal access links, diagnostic notifications.

resend.com/privacy

Vercel

EU edge network

Hosting and serving the LexSutra platform.

vercel.com/legal/privacy-policy

We will notify you if we add or change processors that handle your personal data.

5. AI-Assisted Processing

Transparency about AI use

LexSutra uses Claude, an AI model developed by Anthropic, to assist in generating initial diagnostic findings. This is disclosed here, in our Terms & Conditions, and on every report we deliver.

When you submit your questionnaire, your responses are transmitted to Anthropic's API to generate a first-draft assessment of your EU AI Act compliance position. This draft is then reviewed, edited, and approved by a LexSutra human expert before it is included in your report. No AI-generated finding is delivered to you without human review.

Legal basis for transfer to Anthropic (US): The transfer is covered under Standard Contractual Clauses (SCCs) incorporated into Anthropic's Data Processing Addendum, effective 24 February 2025. Anthropic processes data only as a data processor acting on our instructions.

Anthropic's DPA is available at: anthropic.com/legal/data-processing-addendum

6. International Data Transfers

Your data is stored in the EU (Supabase, Frankfurt). The only transfer outside the EU is to Anthropic (US) for AI-assisted analysis, covered by SCCs as described in Section 5. Resend (email) also processes data in the US — covered under their standard DPA and SCCs.

We do not transfer data to countries without adequate protection unless SCCs or equivalent safeguards are in place.

7. Data Retention

DataPurposeLawful Basis
Client documents (uploaded)18 months minimum from upload date, then deleted unless actively used in an ongoing engagementLegal obligation + contract
Diagnostic questionnaire responsesDuration of client relationship + 5 years for audit purposesLegitimate interest — legal compliance
Diagnostic reportsDuration of client relationship + 5 yearsContract + legitimate interest
Demo request data2 years from enquiry date if no contract is formedLegitimate interest
Activity & audit logs12 months rollingLegitimate interest — security
Error logs90 days rollingLegitimate interest — service reliability
Authentication dataUntil account deletion is requestedContract performance

When retention periods expire, data is permanently deleted from all systems including backups. You can request early deletion — see Section 8.

8. Your Rights Under GDPR

You have the following rights. To exercise any of them, email hello@send.lexsutra.com. We will respond within 30 days.

AccessRequest a copy of all personal data we hold about you.
RectificationAsk us to correct inaccurate data.
ErasureAsk us to delete your data ('right to be forgotten'). We will comply unless we have a legal obligation to retain it.
PortabilityReceive your data in a structured, machine-readable format.
ObjectionObject to processing based on legitimate interest. We will stop unless we have compelling grounds.
RestrictionAsk us to pause processing while a dispute is resolved.
Withdraw consentWhere processing is based on consent, you can withdraw at any time without affecting prior processing.

If you are unsatisfied with our response, you have the right to lodge a complaint with the Autoriteit Persoonsgegevens: autoriteitpersoonsgegevens.nl

9. Cookies

We use only technically necessary cookies — session cookies required for authentication and security. We do not use advertising cookies, tracking pixels, or third-party analytics cookies. No cookie consent banner is required for technically necessary cookies under the ePrivacy Directive.

If we add analytics in future, we will update this policy and implement a consent mechanism before doing so.

10. Changes to This Policy

We will notify active clients by email of any material changes to this policy at least 14 days before they take effect. The “last updated” date at the top of this page always reflects the current version.

11. Contact

For any privacy-related questions, data requests, or complaints: