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Privacy Policy

Edition of October 5, 2026. The current Ukrainian edition of 15 October 2026 changes clauses 4.1.3, 5.1.6, 8.2, 8.6, 10.2, 15.5 and 15.7, which this translation does not yet reflect; the Ukrainian version prevails · Українська версія

1. General Provisions

1.1. This Privacy Policy (the "Policy") sets out which personal data, for what purposes, on what grounds and for how long are processed by LEXERY co-founder Andriy Serediuk (clause 1.3), together with the project team members acting on his instructions (together, the "LEXERY Team" or the "Team"), in connection with providing access to the LEXERY software product (the "Service") under the early access programme, including the team pilot (the "Programme"), and when people visit lexery.com.ua and apply to take part.

1.2. LEXERY is a non-profit research initiative. The AI-based Service for working with sources of Ukrainian law is provided to Programme participants (each a "Participant") free of charge in order to test a technological hypothesis before a possible commercial launch.

1.3. LEXERY is not a legal entity or a registered sole entrepreneur and carries out no business activity: the Service is not sold and no fee is charged for taking part. The controller of the personal data the Team processes for its own purposes (clause 2.2) is the natural person Andriy Serediuk (Андрій Середюк), co-founder of LEXERY (Article 2 of the PDP Law; a controller within the meaning of Article 4(7) GDPR). He determines the purposes, scope and procedures of that processing and is responsible for compliance with this Policy. Other Team members access that data only on his instructions, within their tasks, and must keep it confidential. Contact for all personal data matters: lexery.ai@lexery.com.ua. The controller's place of residence is provided to a data subject on request (item 1 of part two of Article 8 of the PDP Law). If a legal entity is set up to develop the Service, the controller's rights and obligations may pass to it only after Participants are notified as described in Section 16; no such entity exists as of the date of this edition.

1.4. This Policy has been drawn up taking into account:

• the Constitution of Ukraine (Article 32);
• the Civil Code of Ukraine;
• the Law of Ukraine "On Personal Data Protection" No. 2297-VI of 01.06.2010 (the "PDP Law");
• the Law of Ukraine "On Information" No. 2657-XII of 02.10.1992;
• the Law of Ukraine "On the Bar and Practice of Law" No. 5076-VI of 05.07.2012 (as regards attorney-client privilege);
• Regulation (EU) 2016/679 (GDPR), where it applies (Section 15).

1.5. By accepting the LEXERY Early Access Programme Terms, the Participant confirms that they have read this Policy, understand its provisions and consent to the processing of personal data on the terms set out in this Policy, in accordance with item 1 of part one of Article 11 of the PDP Law. Consent is the ground for those kinds of processing for which Section 4 names consent; all other processing relies on the other grounds set out in Section 4.

1.6. The Policy describes processing that the Team carries out as a personal data controller (clause 2.2) and the terms on which the Team processes data as a processor on behalf of a Participant or a team pilot organisation (clause 2.3, Sections 11 and 14).

1.7. This edition applies from the day of its publication to people who apply or sign in to the Service for the first time. For Participants who accepted the previous edition, it takes effect 10 (ten) calendar days after a notice about it is sent to them; provisions that only reduce processing or extend Participants' rights apply from the day of publication.

2. Terms, Controller and Processor

2.1. The terms "personal data", "personal data subject", "personal data controller" (володілець), "personal data processor" (розпорядник), "processing of personal data", "consent of the personal data subject", "depersonalisation of personal data" and "third party" are used as defined in Article 2 of the PDP Law. "Content" means queries, messages, documents, files, cross-chat memory entries (if this feature is enabled) and Service answers in the Participant's workspace.

2.2. The Team (in the person of Andriy Serediuk, clause 1.3) is the controller of personal data it collects for its own purposes: application data, account data, technical data, usage metadata, correspondence with the Participant and data needed to keep the Service secure.

2.3. For personal data of other people in Content (in particular clients, counterparties, witnesses, employees), the controller is the Participant or the team pilot organisation, which determines the purpose and scope of such data. The Team processes it as a processor only so that the Service performs the actions the Participant asks for, and does not use it for its own purposes. The provisions of this Policy and of the Early Access Programme Terms on such processing constitute a processing agreement within the meaning of part four of Article 4 of the PDP Law.

2.4. The Team engages the cloud and infrastructure providers listed in Section 8 as processors under their data processing agreements.

2.5. Google, Microsoft and ClickUp process data in their own services as independent controllers under the rules the Participant accepts directly with them (Sections 9 and 13).

3. Categories of Personal Data

3.1. The Team processes the following categories of personal data:

3.1.1. Application data: first and last name, email address, role (for example lawyer, advocate, law firm), organisation name, and other details the applicant chooses to enter in the form (in particular the number of seats for a team, the EDRPOU code, a comment).

3.1.2. Account data: email address, name, Google or Microsoft account identifier (if the Participant signs in with them), registration and sign-in dates, role and status in a team, settings. Sign-in uses a one-time code sent by email, or Google or Microsoft; the Service does not store Participants' passwords.

3.1.3. Technical data: IP address, browser and device information (user agent), interface language, timestamps, session and request identifiers, event log records.

3.1.4. Content within the meaning of clause 2.1 of this Policy.

3.1.5. Usage metadata: number of requests, limits used and processing cost, duration, names of models and tools, error codes. Metadata contains no Content text.

3.1.6. Team pilot data: team membership, roles, statuses, email addresses of invited people, limits, the log of administrator actions (Section 14).

3.1.7. Enquiries and feedback: emails to the Team, error reports and answer ratings together with any excerpts the Participant adds to them.

3.1.8. Integration data: the name of the connected Google, Microsoft or ClickUp account and the files, folders, lists and tasks the Participant selects (Sections 9 and 13).

3.2. The Team does not purposefully collect special categories of personal data within the meaning of Article 7 of the PDP Law. They may be contained in Content if the Participant enters them. In that case the ground for processing is the Participant's ground as controller, in particular the need to substantiate, satisfy or defend a legal claim (item 5 of part two of Article 7 of the PDP Law). The Team processes such data only as a processor within Section 11.

4. Legal Grounds for Processing

4.1. The Team processes personal data on the following grounds under part one of Article 11 of the PDP Law:

4.1.1. Reviewing an application, correspondence about it and granting access: steps taken before entering into a transaction at the request of the data subject (item 3).

4.1.2. The account, sign-in, providing the Service features, tracking limits, running the team workspace, service notices (including about access, the participation period, changes to terms, new features and changes to how the Service works): entering into and performing a transaction to which the Participant is a party, namely the Early Access Programme Terms (item 3).

4.1.3. Service security, abuse prevention, logging, tracking usage and costs, depersonalised statistics on how the Service works and evaluating Programme results: the Team's legitimate interest in a secure and stable Service (item 6). Technical data and metadata are used for this, not Content.

4.1.4. Reviewing Content that the Participant sends to the Team as feedback or in an error report, and emails with Programme news, invitations and surveys: the Participant's consent (item 1), which may be withdrawn at any time. Consent to news emails is given separately: it does not follow from accepting the Terms (clause 1.5), and without it such emails are not sent.

4.1.5. Compliance with obligations set by law, including responses to lawful requests from competent authorities (item 5).

4.2. The Team processes personal data of other people in Content as a processor on behalf of the Participant (clause 2.3). The legal ground for that processing is held by the Participant as controller.

4.3. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal or processing on the other grounds set out in this Section. The withdrawal procedure is set out in Section 10.

5. Purpose of Processing

5.1. The Team processes personal data for the following purposes:

5.1.1. Reviewing an application to participate in the Programme and deciding whether to grant or refuse access to the Service.

5.1.2. Identifying and authenticating the Participant when using the Service.

5.1.3. Running the Service: generating answers and documents at the Participant's request, searching sources of law, running integrations, tracking limits, running the team workspace.

5.1.4. Testing the technological hypothesis regarding the Service: analysing answer quality, identifying and fixing errors, improving the Service based on depersonalised aggregated quality indicators, without using the Participant's queries and documents or the Service's answers to train models. Answers are generated by language models provided by Amazon Web Services through Amazon Bedrock in the European Union; scan recognition and web search are provided by Google Cloud Vertex AI, also in the EU. Under these providers' terms, queries and answers are not used to train models. For this purpose the Team does not read Content, except Content the Participant has sent as feedback.

5.1.5. Security: detecting and preventing unauthorised access, abuse and exceeding limits, investigating incidents.

5.1.6. Communicating with the Participant about access, the participation period, changes to terms and to how the Service works, technical and organisational matters of the Programme, and, with the Participant's separate consent, Programme news and surveys.

5.1.7. Compliance with the legislation of Ukraine.

5.2. The Team does not sell personal data, does not use Content for advertising, profiling or training artificial intelligence models, does not build training or test datasets from Content, and does not take decisions that have legal effects for the Participant solely on the basis of automated processing.

5.3. Personal data may be processed for another purpose only after notifying the Participant and, where the law requires, obtaining their consent.

6. Data Retention Periods

6.1. Account and contact data are kept for the period of the Participant's participation in the Programme and for 12 (twelve) months after it ends, unless a different period is set by the legislation of Ukraine. Data from an application that did not lead to access is kept for no more than 12 (twelve) months from the date it was submitted.

6.2. Content is kept until the Participant deletes it or for as long as their account exists. The Participant can delete a chat and its related data in the Service at any time. After the Participant's participation or the Programme ends, the Team deletes Content within 90 (ninety) days; before that, the Participant can export their data (Section 10).

6.3. Technical logs and metadata are kept for no longer than: server logs up to 30 days; technical diagnostic events up to 180 days; metadata of requests to language models (without the content of requests and answers) up to 400 days; security, administrative access and privacy key access logs up to 400 days; error reports up to 90 days after they are closed; usage and cost records for the period of participation and 12 (twelve) months after it ends.

6.4. When the relevant periods expire, personal data is deleted or depersonalised so that the person can no longer be identified.

6.5. Regular backups of the Service databases are kept for no more than 30 (thirty) days and are then deleted automatically. One-off backups that the Team makes before migrating or upgrading databases are kept in secure storage for no more than 90 (ninety) days; such copies made before the date of this edition will be deleted no later than 31 December 2026. Data deleted from the production databases disappears from backups within these periods.

7. Personal Data Protection Measures

7.1. The Team takes organisational and technical measures to protect personal data against accidental loss or destruction and against unlawful processing, including unlawful destruction or access (Article 24 of the PDP Law), taking into account the capabilities available to a group of natural persons at the Programme stage.

7.2. In particular, the following are applied:

• encryption of data in transit (TLS) and encryption of storage by the providers;
• separation of different Participants' and teams' data in every request; internal Service components accept requests only with service keys;
• Team members' access to systems on a need-to-know basis and a log of administrative actions recording the purpose of access;
• passwordless sign-in: a one-time code by email or sign-in with Google or Microsoft;
• event logs without the text of queries and answers: content fields are replaced by their length;
• an optional privacy key, where this feature is enabled for the Participant: the key is created and kept in the Participant's browser and is not passed to the Team, and the content of new chats, runs and files is stored in the databases in encrypted form;
• regular backups (clause 6.5).

7.3. To produce an answer, a language model has to read the text of the query. Therefore, during processing the text is decrypted in the memory of the Service servers, of the Cloudflare network while in transit (including the AI Gateway) and of Amazon Bedrock even when the privacy key is enabled. Document drafts, file names and metadata are not encrypted with the privacy key.

7.4. Team members do not view a Participant's Content, except when the Participant asks for help and provides the relevant excerpt, when this is necessary to investigate a security incident, or when the law requires it. The Team records who obtained such access, when and for what purpose.

7.5. In the event of a security incident affecting a Participant's personal data, the Team notifies the Participant without undue delay, and for the team pilot also the team pilot organisation, describing the likely consequences and the measures taken.

7.6. Personal data protection is organised by the controller named in clause 1.3, who also handles data subject requests and incident reports.

7.7. No measure guarantees absolute protection of personal data against unlawful acts of third parties; however, the Team makes reasonable efforts to minimise the related risks.

8. Processors, Transfers and Cross-Border Transfers

8.1. The Team does not sell personal data and does not transfer it to third parties for commercial purposes.

8.2. To run the Service, the Team engages the following processors:

• Amazon Web Services (Amazon Bedrock): answers generated by Anthropic Claude models, search vectors and result ranking by Cohere models; AWS regions in the EU. Receives the query text for the time of processing; the model developers get no access to queries or answers.
• Google Cloud: Service servers (Cloud Run, Frankfurt), logs, analytical storage of technical events, key and secret management; Vertex AI (EU) for scan recognition and web search. During web search Google Search keeps the search query for up to 3 days and may process it outside the EU, so names, addresses, amounts and identifiers are removed from the query before it is sent, and web search is switched off with the privacy key or in strict mode.
• Cloudflare: the network that delivers and protects the site and the Service, through which all traffic between the Participant's browser and the Service passes (TLS encryption, DDoS protection, a web application firewall (WAF), filtering of automated traffic, Turnstile checks in forms); only public pages and files of the site are cached, Content is not cached. Cloudflare also provides search services over sources of law, R2 file storage (EU jurisdiction), cookieless Web Analytics and the AI Gateway, through which the Service servers send requests to language models in Amazon Bedrock and receive the answers. Logging of content and caching are switched off on the gateway for every request, so it keeps neither requests nor answers. The gateway keeps only metadata: time, model, token counts, cost, duration, result code and pseudonymised identifiers of the Participant, the team and the run (hash codes without a name or email address that only the Team can match to its own records), to account for each Participant's limits and costs (the retention period is in clause 6.3). In plain words: Cloudflare sees the text of a request and an answer only while passing it on and keeps no copy. Cloudflare acts as a processor under its data processing agreement (DPA) with the EU standard contractual clauses; the transit may go through data centres outside the EU (clause 8.6).
• MongoDB Atlas: the agent and cross-chat memory databases (EU).
• Supabase: authentication and the database of accounts, chats and documents (EU).
• Qdrant Cloud: the vector index of the legislation corpus (EU). Receives only the vector of a search query, without text.
• Zoho (ZeptoMail, Zoho Mail): sending sign-in codes, invitations and service emails, the support mailbox (EU data centre).
• Sequenzy (USA): sending Participants emails about changes to the Service and the Programme, such as new features or a new look of the Service (service notices, item 4.1.2), and emails with Programme news, invitations and surveys only to those who have given separate consent (item 4.1.4). Receives the email address, the participant tag and a flag showing whether consent to news has been given; receives no Content. Emails are delivered via Amazon SES (Amazon Web Services). For mailing statistics, Sequenzy may record delivery, opens and link clicks (via links.lexery.com.ua) together with technical data (IP address, browser, time) on the basis of the Team's legitimate interest (item 4.1.3). The provider is located outside the European Economic Area; the transfer safeguard is a data processing agreement (DPA) with the EU standard contractual clauses (clause 8.6). Every such email has an unsubscribe link; unsubscribing does not stop emails about access, security and changes to the Terms and the Policy, which the Team sends while participation lasts.

8.3. Google, Microsoft and ClickUp receive data only when the Participant connects the relevant integration or signs in with it (Sections 9 and 13).

8.4. Personal data may also be disclosed to competent public authorities in the cases and manner provided by law, and to the Team's successor, in particular a legal entity registered to develop the Service further, with notice to Participants.

8.5. The Team adds a new processor to the list in clause 8.2 before any data is transferred to it. The Team announces changes to the list on this page and emails team pilot organisations.

8.6. The Service databases and files are stored in states of the European Economic Area, which are recognised as ensuring an adequate level of personal data protection (part three of Article 29 of the PDP Law). Some providers have parent companies outside the European Economic Area, and the Cloudflare network handles traffic, including the transit of requests to language models through the AI Gateway, in the data centre nearest to the user or to the Service servers; Cloudflare does not guarantee that this data centre is in the EU. For such cases, the appropriate safeguards are these providers' data processing agreements with the EU standard contractual clauses (item 5 of part four of Article 29 of the PDP Law). Team members work with the data from Ukraine.

9. Integration with Google Services (Google Docs, Google Drive)

9.1. LEXERY is a non-profit research initiative. The integration with Google services is an optional feature that the Participant enables on their own. We chose Google as a provider because of the level of data protection in Google's infrastructure; authentication and access to files are performed by Google tools (Google Identity Services, Google Picker, Google Drive API) under Google's Terms of Service and Privacy Policy, which the Participant accepts directly with Google.

9.2. Scope of access. The Service requests only the drive.file permission, that is, access to files the Participant creates through LEXERY or selects in the Google picker. The Service has no access to other Google Drive files, mail, contacts, calendar or any other Google account data, except the name and email address needed for sign-in.

9.3. Purpose. (a) Export: a document produced in LEXERY is created as a Google Docs file in the Participant's Google Drive; the file is then stored and processed by Google under Google's rules. (b) Import: a copy of the file the Participant selects is placed in the Participant's LEXERY workspace for analysis at their request. There are no other purposes.

9.4. Storage. The Google access token is short-lived, is kept only in the Participant's browser for the session and is not stored on LEXERY servers; refresh tokens are not requested. Imported copies are kept in the Participant's workspace under Section 6 and are deleted at the Participant's request or together with the account.

9.5. Data received from Google is not sold, not used for advertising or for training artificial intelligence models, and not transferred to third parties other than the infrastructure providers needed to run the Service.

9.6. LEXERY's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

9.7. Responsibility. Storage, availability and security of files in Google Drive and of the Google account are provided by Google; LEXERY does not control Google's infrastructure and, to the extent permitted by law, is not liable for its operation, outages or Google's actions. The Participant chooses the files to import or export and is responsible for having the right to deal with them, including with regard to attorney-client privilege. The feature is provided "as is" within the research early access programme.

9.8. The Participant may revoke LEXERY's access at any time in the Google account settings (myaccount.google.com/permissions). Questions about data processing: support@lexery.com.ua.

10. Rights of the Personal Data Subject

10.1. Under Article 8 of the PDP Law, the Participant as a personal data subject has the right:

10.1.1. to know the sources of collection and the location of their personal data, the purpose of processing, the location or place of residence (stay) of the personal data controller or processor, or to instruct authorised persons to obtain this information, except in cases established by law;

10.1.2. to receive information on the conditions of access to personal data, in particular information about third parties to whom their personal data is transferred;

10.1.3. to access their personal data;

10.1.4. to receive, no later than thirty calendar days from the date the request is received, except in cases provided by law, an answer as to whether their personal data is being processed, and to receive the content of such personal data;

10.1.5. to submit a reasoned objection to the personal data controller against the processing of their personal data;

10.1.6. to submit a reasoned demand to any personal data controller or processor to change or destroy their personal data if the data is processed unlawfully or is inaccurate;

10.1.7. to protection of their personal data against unlawful processing and accidental loss, destruction or damage due to deliberate concealment, non-provision or untimely provision, and to protection against the provision of information that is inaccurate or discredits the honour, dignity and business reputation of the individual;

10.1.8. to lodge complaints about the processing of their personal data with the Ukrainian Parliament Commissioner for Human Rights or with a court;

10.1.9. to use legal remedies in the event of a breach of personal data protection legislation;

10.1.10. to make reservations limiting the right to process their personal data when giving consent;

10.1.11. to withdraw consent to the processing of personal data;

10.1.12. to know the mechanism of automated processing of personal data;

10.1.13. to protection against an automated decision that has legal consequences for them.

10.2. In the Service settings, the Participant can export their data ("Download my data"), delete chats and memory entries, and delete the account themselves or on request. News emails and emails about changes to the Service can be unsubscribed from via the link in each such email; emails about access, security and changes to the Terms and the Policy are sent while participation lasts. Other requests, including withdrawal of consent or an objection to processing, are sent to the address in Section 17.

10.3. The Team answers whether personal data is processed, and provides its content, no later than 30 (thirty) calendar days from the date the request is received. The Team handles other requests within the periods established by law.

10.4. The Team may ask the person making a request to provide information sufficient to identify them, so as not to disclose personal data to unauthorised persons.

10.5. Requests from people whose data the Participant has entered in Content (for example clients) should be addressed to the Participant or the team pilot organisation as the controller of that data. The Team helps fulfil them.

11. Third-Party Data and Attorney-Client Privilege

11.1. The Team recognises that Programme Participants are mostly people engaged in professional legal practice, including advocates, and that Content may contain personal data of other people and information constituting attorney-client privilege (advocate's secrecy) within the meaning of part one of Article 22 of the Law of Ukraine "On the Bar and Practice of Law".

11.2. The Participant decides on their own and at their own responsibility whether to enter personal data of other people and information constituting advocate's or other legally protected secrecy into the Service. The Team recommends depersonalising such information where this does not defeat the purpose of the query.

11.3. By entering personal data of other people into the Service, the Participant confirms that they have a legal ground to do so and acts as the controller of such data. As a processor, the Team processes it only to perform the actions the Participant asks for; does not disclose it to anyone other than the processors listed in Section 8; ensures confidentiality on the part of Team members; helps the Participant handle data subject requests and respond to incidents; and deletes the data within the periods in Section 6 or at the Participant's request.

11.4. The duty to ensure conditions that prevent outsiders from accessing advocate's secrecy rests with the advocate, the law office or the law firm (part three of Article 22 of the Law of Ukraine "On the Bar and Practice of Law"). The Service provides tools for this: the privacy key, a strict mode without web search, data deletion, and, in the team pilot, no administrator access to members' private chats (Section 14). All places where Content is processed or passes in transit are listed in clauses 7.3 and 8.2.

11.5. The Team discloses Content to public authorities only in the cases and manner expressly provided by law, taking into account the guarantees of the practice of law, and, unless the law prohibits it, informs the Participant of such a request.

11.6. The Team is not liable for the consequences of the Participant's disclosure of advocate's, banking, medical or other legally protected secrecy by passing it to the Service, provided the Team has performed its obligations under this Policy.

12. Cookies, Local Storage and Analytics

12.1. LEXERY uses only strictly necessary cookies and browser local storage. There are no advertising or analytics cookies and no third-party tracking cookies, so no separate cookie consent is requested. If the Team ever adds non-essential cookies, it will ask for consent before setting them.

Cookies

12.2. The site pages (home, product description, application, legal documents) do not set cookies. Cookies appear after signing in to the workspace or while connecting an integration:

12.3. The Google and Microsoft sign-in windows may set their own cookies under those companies' rules. Cloudflare may set technical security cookies (for example __cf_bm or cf_clearance) when a request needs an automated-traffic check. The Team does not control such cookies and receives no tracking data from them.

Browser local storage

12.4. The browser's local storage on the Participant's device holds interface settings, the draft of the current message, service flags, a workspace cache for fast loading, the names of connected integrations and the privacy key (if one has been created). Microsoft and ClickUp access tokens are kept only in the browser tab and disappear when it is closed. This data is not passed to third parties; it can be removed by clearing the site data in the browser settings.

Analytics

12.5. For visit statistics the site uses Cloudflare Web Analytics. This service sets no cookies, uses no local storage and builds no visitor profile. The Team sees only aggregated figures: page views, the page address without query parameters, the referrer, browser and device type, country and loading speed.

12.6. In the workspace the Team collects technical events to find errors, speed up the Service and manage limits: for example, that an answer finished or an error occurred, how long it took and how much processing cost. These events and the usage statistics for each Programme Participant contain pseudonymous identifiers and metadata but no text of queries, answers or documents. A team administrator sees such statistics only for their own team workspace (Section 14).

12.7. The Team does not use Google Analytics, advertising pixels or social widgets, does not track visitors across sites, does not sell data and does not record application form data in analytics.

How to manage

12.8. The Participant can delete or block cookies in the browser settings. Without the strictly necessary cookies, signing in to the workspace is not possible. Questions about cookies and analytics: support@lexery.com.ua.

13. Microsoft and ClickUp Integrations

13.1. The Microsoft and ClickUp integrations are optional. The Participant enables them on their own, and in the team pilot only once an administrator has allowed the integration for the team.

13.2. Microsoft. The Participant may sign in with a Microsoft account; the Service then receives the name, email address and account identifier. To work with OneDrive and Word, the Service requests the offline_access, User.Read and Files.ReadWrite permissions. The Files.ReadWrite permission technically gives access to the Participant's OneDrive files, but the Service uses it only for files the Participant opens or saves through LEXERY.

13.3. ClickUp. Once connected, the Service reads the lists, tasks and task fields in the ClickUp workspace chosen by the Participant or the team administrator, to show matters and deadlines, and creates or updates tasks only at the Participant's command. Each team member connects ClickUp with their own account and sees only what they can access in ClickUp itself.

13.4. Microsoft and ClickUp access tokens are handed only to the Participant's browser tab, are not stored in the Service databases, cookies or logs, and disappear when the tab is closed. Data from OneDrive or ClickUp that the Participant uses in a chat is processed as Content.

13.5. The Participant may revoke access at any time in the Microsoft or ClickUp account settings. Microsoft and ClickUp process data in their own services under their own rules as independent controllers.

14. Team Pilot

14.1. In the team pilot, a law firm, a law office, an advocate or another organisation (a "team pilot organisation") receives a team workspace, and its employees and colleagues join it by invitation. For Content in the team workspace, the team pilot organisation is the controller and the Team is the processor (clause 2.3). For accounts, security and usage metadata, the Team is the controller.

14.2. The owner and administrators of a team workspace see only metadata: team membership, roles and statuses, the date of last activity, the number of requests and the credits spent in the team workspace, limits. They do not see and cannot obtain members' private chats, memory, files and templates, content encrypted with the privacy key, or members' activity in their personal workspace. The Team does not give the team pilot organisation access to this data, except where expressly required by law.

14.3. To invite a colleague, an administrator enters their email address. The Team uses this address only to send an invitation with a link to this Policy and for sign-in. An invitation is valid for 14 days; if it is not accepted, the address is removed from the access list.

14.4. A member decides whether to share a document with the team. Colleagues see the text of the shared document and its version history, but not the chat it came from. During the pilot, colleagues can view a shared document and make their own copy. The member can stop sharing at any time, and colleagues lose access immediately. Documents from chats under the privacy key are not shared.

14.5. If a member is removed from the team or disabled, they immediately lose access to the team workspace, including the documents they shared. Before removal, the administrator may keep copies, for the team, of documents that this member shared earlier. The member's private chats, memory and files in the team workspace stay closed to everyone; they become available to the member again if the member is re-invited within 90 (ninety) days, and are deleted after that period. The member's personal workspace and account remain theirs.

14.6. A team pilot lasts 30 (thirty) calendar days from the day the team workspace is created, unless the Team has set a different period (clause 4.6 of the Early Access Programme Terms); the pilot end date is shown in the team settings. After it, new requests in the team workspace are not accepted, while viewing and exporting data remain available for 90 (ninety) days. If the pilot is not extended, the Content of the team workspace is deleted after that period (clause 6.2).

14.7. The log of administrator actions contains only metadata (who did what, when and to whom) and no Content. It is kept for as long as the team workspace exists and for 12 (twelve) months after it is closed.

14.8. The team pilot organisation informs its employees about the use of the Service and is responsible for the lawfulness of entering its clients' data into the team workspace.

15. Individuals in the European Union (GDPR)

15.1. The Programme is aimed at lawyers in Ukraine. Where Regulation (EU) 2016/679 (GDPR) applies to the processing, this Section supplements the Policy. The controller within the meaning of Article 4(7) GDPR is the natural person named in clause 1.3; his identity and contact details (Article 13(1)(a) GDPR) are given there.

15.2. The grounds for processing under Article 6(1) GDPR correspond to Section 4: performance of a contract (b) for clauses 4.1.1 and 4.1.2, legitimate interests (f) for clause 4.1.3, consent (a) for clause 4.1.4, legal obligation (c) for clause 4.1.5.

15.3. The individual has the right of access (Article 15), rectification (Article 16), erasure (Article 17), restriction of processing (Article 18), data portability (Article 20; the "Download my data" feature provides the data in a machine-readable format), objection to processing based on legitimate interests (Article 21), withdrawal of consent (Article 7(3)), and the right to lodge a complaint with a supervisory authority of the EU Member State of habitual residence, place of work or place of the alleged infringement (Article 77).

15.4. For Content containing other people's data, the Participant or the team pilot organisation is the controller and the Team is the processor (Article 28 GDPR). The Team processes such data only on documented instructions, namely the Terms, the settings and the Participant's actions; engages the processors in Section 8 under a general authorisation with notice of changes (clause 8.5); ensures confidentiality on the part of Team members and security measures (Section 7); assists with data subject requests and incidents; deletes the data once processing ends (Section 6); and provides the information needed to demonstrate these obligations.

15.5. Data is stored in the EEA. Access by Team members from Ukraine and transfers to providers with parent companies outside the EEA are covered by the EU standard contractual clauses (Article 46(2)(c) GDPR) in the providers' agreements. An organisation in the EU may ask to sign standard contractual clauses with the Team.

15.6. The Team does not take decisions that have legal effects for an individual solely on the basis of automated processing (Article 22 GDPR).

15.7. The Team has no establishment in the EU. The Service is not targeted at people in the EU (it is a Ukrainian-language service for working with Ukrainian law), and the Team does not monitor the behaviour of people in the EU within the meaning of Article 3(2)(b) GDPR (profiling or tracking on the internet), so no representative in the EU under Article 27 GDPR has been designated. If the Team starts offering the Service to people in the EU, it will designate a representative before doing so, unless the exception in Article 27(2) GDPR applies, and will give the representative's contact details in this Section. There are no grounds requiring the designation of a data protection officer (Article 37 GDPR).

16. Amendments to the Policy

16.1. The Team reserves the right to amend this Policy unilaterally in connection with changes in legislation, the technical implementation of the Service or the organisational and legal status of the Team (in particular in connection with the registration of a legal entity).

16.2. The current edition of the Policy is published on the official website of the Service with the date of its approval. In the event of material changes, the Team notifies Participants by sending a notice to the email address provided at registration no later than 10 (ten) calendar days before such changes take effect.

16.3. Continued use of the Service after a new edition of the Policy takes effect means the Participant agrees to the changes. If the Participant disagrees, they may stop using the Service, export their data and request its deletion.

17. Contact Information

17.1. For questions related to the processing of personal data, the exercise of data subject rights, and to send complaints and requests, you can contact the controller (clause 1.3) at: lexery.ai@lexery.com.ua; emails to support@lexery.com.ua reach the same mailbox.

17.2. The Team handles enquiries within the periods established by the legislation of Ukraine.

17.3. Team emails are sent from addresses in the lexery.com.ua domain (including updates.lexery.com.ua) and are signed "Команда LEXERY" (the LEXERY Team). The Team never asks you to send it a password, a sign-in code or payment details.

17.3. The Ukrainian version of this Policy prevails.