Privacy Policy

How we protect your data

A transparent account of what personal data KGM Technologies collects, why, who sees it, and how long we keep it — grounded in what the platform actually does.

GDPR compliant
Data hosted in France
DRAFT — pending legal review

Session cookie duration

7 days

Hosting region

EU — Paris

EU transfer safeguard

SCCs

Pseudonymisation

Local only

Section

1. Who we are

KGM Technologies SAS ("KGM", "we", "our") operates the AI-assisted legal workflow platform available at app.kgm-technologies.com. KGM is the data controller within the meaning of the GDPR (Regulation (EU) 2016/679).

KGM Technologies SAS
[Registered address — to be completed before publication]
SIREN: [to be completed]
Data Protection contact: privacy@kgm-technologies.com

Section

2. Data we collect

2.1 Identity & authentication data

  • Account: email address, display name, profile picture URL, OAuth provider identifier (Google, Notion), user role.
  • Session: session token (stored in an HttpOnly cookie), IP address, browser user-agent string.
  • Email verification: one-time passcode (OTP) used for passwordless sign-in; not persisted after use.

2.2 Professional profile

Collected during onboarding via an AI-assisted conversation. Fields vary by professional domain:

  • All users: first name, last name, job title, working languages, professional domain (vertical).
  • Legal professionals: seniority level, legal specialisations, jurisdictions, bar registration number, contract types handled.
  • Software professionals: engineering role, tech stack, team name.

2.3 Documents you upload

  • Raw files: PDF, DOCX, and other supported formats. Stored on Scaleway object storage (EU, Paris region).
  • Extracted text: plain-text version produced by our OCR pipeline, stored in our database.
  • Document embeddings: vector representations (768 dimensions) computed using a local embedding model — no text leaves our servers for this step.
  • Pseudonymisation map: when you use the contract-analysis feature, a mapping between detected entities and their placeholders is encrypted and stored. The original entity text is retained encrypted so you can restore it.

VLM-assisted OCR

If this optional feature is enabled by your organisation, page images of your document may be sent to OpenAI or Anthropic for higher-quality text extraction. See Section 5.

2.4 Conversation history

  • All messages exchanged with the AI assistant, stored per thread.
  • Agent state snapshots ("checkpoints") — at most the last 50 per thread by default.

2.5 Usage & billing data

  • Per-request token counts (input, output), AI model used, cost estimate, and thread identifier — linked to your account.
  • Credit wallet balance and credit transaction history.
  • Subscription plan identifiers (Paddle IDs) — planned feature, not yet live.

Section

4. How we process your documents

Documents pass through the following steps, in order:

  1. OCR (local): text is extracted from your file using our on-premises OCR engine. No data leaves our infrastructure at this step.
  2. Optional VLM correction: if enabled, page images are sent to OpenAI or Anthropic to improve extraction quality for complex layouts.
  3. Chunking & embedding (local): the extracted text is split into chunks and converted to vector embeddings using a local E5 embedding model. No data is sent externally for this step.
  4. Pseudonymisation (local): named entities (persons, organisations, locations, dates, bar numbers, etc.) are detected and replaced with pseudonyms using GLiNER and Presidio — both running entirely on our servers. The pseudonymised text, not the original, is sent to the AI model.
  5. AI analysis: pseudonymised or raw text is sent to the configured AI provider (OpenAI or Anthropic) for reasoning, clause analysis, or summarisation.

Section

5. Sub-processors & international transfers

We use the following third-party processors. Where they process data outside the EU, the legal safeguard is Standard Contractual Clauses (SCCs) under GDPR Art. 46.

ProcessorPurposeData transferredRegion
OpenAI, Inc.LLM inference, optional VLM OCR, knowledge-base embeddingsChat messages, (pseudonymised) document text, query text; optionally page imagesUS — safeguard: SCCs
Anthropic, PBCLLM inference, optional VLM OCRSame as OpenAI pathUS — safeguard: SCCs
Resend, Inc.Transactional email (OTP codes, invite emails)Email address, OTP or invite bodyPer Resend DPA
Scaleway SASApp hosting (VPS), block storage, PostgreSQL & Redis (self-hosted), and object storage for uploaded filesAll persisted data and raw uploaded filesEU — Paris (fr-par-1)
Google LLCOAuth sign-in (optional)Email address, display name, OAuth tokenUS — safeguard: SCCs
Notion Labs, Inc.OAuth sign-in (optional)Notion identity (name, email)US — safeguard: SCCs

Local processing

NER / pseudonymisation (GLiNER + Presidio) runs entirely on our own infrastructure and is not a sub-processor — no data is transferred externally for this component.

Section

6. Retention periods

  • Session tokens: 7 days from creation, or until sign-out.
  • Conversation messages & checkpoints: retained until you delete your account. Checkpoints are capped at 50 per thread automatically.
  • Uploaded documents: retained until you delete them or your account is closed. Automated expiry is not yet implemented; document deletion is available on request.
  • Usage records: retained for accounting and audit purposes for up to 5 years, after which they are deleted or anonymised.
  • Account data: deleted within 30 days following a verified erasure request, subject to our legal retention obligations.

Section

7. Your rights

Under GDPR you have the following rights:

Access (Art. 15)
You may request a copy of the personal data we hold about you.
Rectification (Art. 16)
You may correct inaccurate data via your profile settings, or by contacting us.
Erasure (Art. 17 — "right to be forgotten")
You may request deletion of your account and associated data. Note: a self-service document deletion endpoint is planned but not yet available; erasure requests can currently be submitted by email.
Data portability (Art. 20)
You may request your data in a structured, machine-readable format.
Restriction of processing (Art. 18)
In certain circumstances you may request that we limit how we use your data.
Objection (Art. 21)
You may object to processing based on legitimate interest.

To exercise any of these rights, contact us at privacy@kgm-technologies.com. We will respond within 30 days.

Supervisory authority

You have the right to lodge a complaint with the CNIL (Commission Nationale de l'Informatique et des Libertés) — 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07 — www.cnil.fr

Section

8. Cookies

We use exactly one cookie: better-auth.session_token (or __Secure-better-auth.session_token in production). It is strictly necessary to keep you authenticated. It is HttpOnly, SameSite=Lax, and expires after 7 days.

No tracking cookies

We do not use analytics, advertising, or any third-party tracking cookies. No cookie consent banner is required.

For full detail see our Cookie Policy.

Section

9. Security measures

  • Data in transit: TLS 1.2+ for all connections.
  • Data at rest: encrypted storage volumes on Scaleway.
  • Pseudonymisation maps: encrypted at rest using Fernet symmetric encryption.
  • Access controls: role-based access control (RBAC) at application and database level.
  • Session management: HttpOnly, short-lived session cookies; no tokens in localStorage.

Section

10. Contact & changes to this policy

For any privacy-related questions or to exercise your rights: privacy@kgm-technologies.com

We may update this policy from time to time. When we make material changes, we will notify you by email and update the "Last updated" date at the top of this page. Continued use of the service after the effective date constitutes acceptance of the revised policy.

DRAFT — PENDING LEGAL REVIEW — Last updated: 13 May 2026