1. Who we are and what this policy covers

Phaselab, Inc., ("Phaselaw", "we", "us"), provides the Phaselaw software that helps organisations respond to regulated disclosure obligations.

This policy explains how we handle personal data in two different roles.

Where we are the controller. This policy covers personal data about:

  • visitors to our website, phase.law;
  • people who contact us, book a demo, attend our events or receive our communications;
  • users of our platform, such as the name, email and login details of people who hold an account; and
  • contacts at our customers, prospects, partners and suppliers.

Where we are the processor. When a customer uses Phaselaw to handle a request, it uploads documents that may contain personal data about requesters, employees and other people. We process that content only on the customer's documented instructions, under a data processing agreement. The customer is the controller of that data and decides how it is used. If your personal data is in material a Phaselaw customer is processing, for example because you made a subject access request to that organisation, please contact that organisation to exercise your rights. If you contact us instead, we will pass your request to the relevant customer where we can identify them.

2. Personal data we collect

Category
Examples
Where it comes from
Contact and account data
Name, work email, phone number, job title, employer, login credentials
You, your organisation when it sets up your account, or your single sign-on provider
Communications
Emails, demo requests, support tickets, survey responses, call notes
You
Billing data
Billing contact, billing address, invoice history. Card details are collected directly by our payment processor, Stripe; we see only card type and last four digits
You, Stripe
Usage and device data
IP address, browser and device type, pages viewed, features used, timestamps, error logs
Automatically, through our platform and cookies
Approximate location
Country or city derived from IP address
Automatically
Marketing data
Whether you opened our emails, events you attended, how you found our website
Automatically, event organisers, business contact data providers, and publicly available sources such as LinkedIn and company websites

We do not ask for special category data (for example health information) about our contacts or users. Customer content uploaded to the platform may contain any kind of personal data; we handle it as a processor under section 1.

3. How we use personal data and our lawful bases

Under UK and EU data protection law we must have a lawful basis for each use. We rely on the following.

Purpose
Lawful basis
Providing the platform: creating accounts, authenticating users, delivering features and support
Performance of our contract with you or your organisation; our legitimate interest in serving our customers' users
Billing and account administration
Performance of a contract; legal obligation (tax and accounting records)
Keeping the platform secure, preventing fraud and fixing errors
Legitimate interest in protecting our service and our customers
Understanding how the website and platform are used, to improve them
Legitimate interest; consent where cookies require it (section 7)
Responding to enquiries and demo requests
Legitimate interest in answering business enquiries; steps taken at your request before a contract
Sending business-to-business marketing about our products and events
Legitimate interest, or consent where the law requires it. You can opt out at any time
Complying with law, responding to lawful requests and establishing or defending legal claims
Legal obligation; legitimate interest
A merger, acquisition or sale of our business
Legitimate interest. We will tell you before your data becomes subject to a different privacy policy

Where we rely on legitimate interests, we have weighed them against your rights and expectations. You can ask us for details of that assessment.

We do not sell personal data. If you accept marketing cookies, we use Google Ads and LinkedIn tags to measure our advertising, relying on your consent. Some US state laws treat this as "sharing" for targeted advertising; you can withdraw consent at any time through Cookie Preferences.

4. AI and automated processing

Phaselaw uses AI models to help customers find, classify and redact information in documents. These models run on Amazon Web Services' Bedrock service within our own AWS environment in the same AWS region where the customer's account is hosted.

  • No training on customer data. We do not use customer content, or personal data within it, to train, fine-tune or otherwise improve AI models, or for any other product development. Our model providers do not use it either.
  • Human review. Phaselaw suggests redactions and classifications. The customer's own staff review the output and decide what is disclosed. We do not make decisions based solely on automated processing that produce legal or similarly significant effects on anyone.
  • Usage data. We may use usage and performance data, such as feature use and error rates, to improve the platform. This data does not include the content of customer documents.

5. Who we share personal data with

We share personal data only with the parties below, and only as far as they need it.

  • Service providers. These act on our instructions under written contracts. They include cloud hosting and AI inference (Amazon Web Services), authentication (Auth0), analytics (PostHog), CRM and marketing (HubSpot) and payments (Stripe). Our current list of sub-processors for customer data is on our Trust Center.
  • Advertising platforms. If you accept marketing cookies, Google and LinkedIn receive information about your visit, such as pages viewed and demo requests, to measure our campaigns. They handle it under their own privacy policies.
  • Your organisation. If your account is provided by your employer, your organisation's administrators can see your account details and activity.
  • Professional advisers. Lawyers, accountants and auditors, under a duty of confidentiality.
  • Authorities. Regulators, courts or law enforcement, where the law requires it or to protect our rights or others' safety.
  • Buyers or investors. A party involved in a merger, acquisition or financing, under confidentiality obligations.

We may share aggregated or de-identified information that cannot reasonably identify anyone.

6. Where data is stored and international transfers

Each customer chooses where its account is hosted: the United Kingdom, the European Union or the United States, on Amazon Web Services. Customer content and AI processing for that account stay in the chosen region. Product analytics from the platform (PostHog) is processed in the EU for UK and EU accounts, and in the US for US accounts.

Phaselab, Inc. is based in the United States, and some of our team and service providers are outside the UK and EU. Our staff access customer content from outside its hosting region only when a customer specifically asks us to, for example to resolve a support issue. Business data that is not customer content, including website analytics (PostHog) and our CRM and marketing records (HubSpot), may be processed in the United States.

When personal data leaves the UK or the European Economic Area, we protect it with the UK International Data Transfer Agreement, or the EU Standard Contractual Clauses with the UK Addendum, together with additional safeguards where needed. You can ask us for a copy of the relevant safeguards.

7. Cookies and similar technologies

We use cookies and similar technologies on our website and platform. Strictly necessary cookies are always on. In the UK, the EU, the EEA and the United States, analytics and marketing cookies stay off until you accept them. You can change your choice at any time through the "Cookie Preferences" link at the bottom of every page.

Type
What it does
Providers
Strictly necessary
Keeps you signed in, secures the platform and remembers your cookie choices
Phaselaw, Auth0, HubSpot (cookie banner)
Analytics
Shows us how the website and platform are used so we can improve them
PostHog (website: US; platform: EU or US, matched to the customer's hosting), HubSpot
Marketing
Measures how people find us and whether our ads lead to demo requests
Google Ads, LinkedIn Insight Tag, HubSpot

Until you accept, and if you decline, our website sets only the cookie that remembers your choice. HubSpot still records an anonymous page view without cookies or any identifier that persists between pages. Google receives a cookieless signal that consent was refused, which it uses only for aggregate measurement. PostHog, Google Ads and LinkedIn do not load.

You can also block or delete cookies in your browser settings, though some features may then stop working. The UK Information Commissioner's Office explains cookies at ico.org.uk.

8. Security

We protect personal data with technical and organisational measures suited to the sensitive material our customers handle. These include:

  • encryption at rest (AES-256) and in transit (TLS 1.2 or higher);
  • single sign-on, multi-factor authentication and role-based access controls;
  • annual penetration testing by a CREST-accredited firm;
  • an independent SOC 2 report and Cyber Essentials certification.

Details and reports are available on our Trust Center. No system is perfectly secure, and if a breach affects your personal data we will notify you and the regulator as the law requires.

9. How long we keep personal data

We keep personal data only as long as we need it for the purposes in section 3.

Data
Retention
Account data
For the life of the account, then 90 days
Billing records
7 years, to meet tax and accounting rules
Security and access logs
12 months
Prospect and marketing contacts
2 years after our last meaningful contact, or until you opt out
Website analytics
26 months in identifiable form; aggregated reports may be kept longer
Customer content
As set out in the customer's contract and data processing agreement, and deleted at the customer's instruction

We may keep data longer where the law requires it or to resolve a dispute, and we may keep anonymised data indefinitely.

10. Your rights

To exercise any right below, email privacy@phase.law. We will respond within one month, which we may extend by up to two further months for complex requests; we will tell you if we do. We may need to verify your identity first. We do not charge a fee unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or decline and explain why.

UK, EU and EEA. You have the right to:

  • access your personal data and receive a copy;
  • have inaccurate data corrected;
  • have your data erased;
  • restrict how we use your data;
  • object to processing based on our legitimate interests, and to direct marketing at any time;
  • receive data you gave us in a portable format;
  • withdraw consent at any time, where we rely on it; and
  • complain to a data protection regulator. In the UK this is the Information Commissioner's Office (ico.org.uk). In the EU or EEA it is the authority where you live or work (list). We would welcome the chance to address your concern first.

United States. Depending on where you live, state law may give you rights to know, access, correct and delete your personal data and to opt out of its sale or use for targeted advertising. We do not sell personal data. We will honour these requests wherever the law gives you the right, and we will not discriminate against you for making one.

Canada. You can access and correct your personal data, and withdraw consent, under PIPEDA and applicable provincial law. You can also complain to the Office of the Privacy Commissioner of Canada.

Data in customer content. If your data is in material a Phaselaw customer is processing, see section 1. The customer handles your request, and we help them.

11. Children, changes to this policy, and contact

Children. Phaselaw is a business service and is not directed at children under 16. We do not knowingly collect their personal data as a controller. If you believe we have, contact us and we will delete it.

Changes. We will update this policy when our practices change and show the new effective date at the top. For material changes we will also notify account holders by email or in the platform before the change takes effect.

Contact. Questions or requests about this policy go to:

Phaselab, Inc. (Phaselaw)
228 Park Ave S #52518, New York, NY 10003, USA
privacy@phase.law
+1 (646) 631-0601

Representatives. Individuals and data protection supervisory authorities in the EU/EEA, and individuals and the ICO in the UK, may also contact our representatives under Article 27 of the EU GDPR and UK GDPR:

  • EU: DP-Dock GmbH, Attn: Phaselab, Inc., Ballindamm 39, 20095 Hamburg, Germany
  • UK: DP Data Protection Services UK Ltd., Attn: Phaselab, Inc., 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom

Both can be reached at phaselab@gdpr-rep.com (dp-dock.com).