Privacy Policy

Including notices for California and European residents

Last Updated: June 3, 2026

Introduction

OGTW, Inc. DBA “Counsel Club” (“Counsel Club,” “Company,” “we” or “us”) operates Amicus.AI (the “Service”), an AI-assisted contract review tool available at our website (the “Site”). This Privacy Policy describes our practices for collecting, using, and disclosing information when you use the Service.

We ask that you read this Privacy Policy carefully. By accessing or using the Service, you agree to this Privacy Policy. If you do not agree with our policies and practices, your choice is not to use the Service.

This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and update the “Last Updated” date above. Material changes will be communicated through a notice on the Site. Your continued use of the Service after changes become effective constitutes your acceptance of the new policy.

Summary: How Amicus.AI Handles Your Contracts

Because contracts often contain sensitive business and personal information, we want to be direct about what happens when you use Amicus.AI today:

• No accounts. Amicus.AI does not currently offer user registration or login. You use the Service without creating an account.
• Contracts are not saved. The contract text you upload or paste is processed in memory only to produce your analysis. We do not store your contract, the proposed edits, or the downloadable Word document on our servers.
• Contract text is sent to our AI provider (Anthropic) solely to generate your analysis. It is not used to train AI models. See “Third-Party Processors” below.
• We retain only anonymized analytics about each analysis run — a random analysis ID, contract type (e.g., “MSA”), severity counts, and a build identifier. These records contain no contract text and no information identifying you.

Information We Collect and How We Collect It

This policy sets out what personal data we may collect, how we process and protect that data, and the lawful grounds for that processing. In most cases, the lawful ground will be that the processing (i) is necessary for our legitimate interests in carrying out our business, including to improve our Service, provided those interests are not outweighed by your rights and interests (“Legitimate Interests”), (ii) is necessary to perform a contract with you (“Contract”), or (iii) we have a legal obligation to carry out the processing (“Legal Obligation”). Where processing is based on your consent (“Consent”), we will identify the processing purposes and provide you with relevant information to make the processing fair and transparent.

Contract Content You Submit

When you use Amicus.AI, you upload a contract file (PDF or Word), paste contract text, or type information into the intake questionnaire. We process this material in the following way:

• Your contract text and intake answers are held in memory for the duration of your analysis session and are transmitted to our AI provider to generate the analysis, suggested edits, and explanations.
• We do not save the contract text, intake answers, generated edits, or downloaded Word document to a Company database. When you close or refresh the Service, that session state is gone from our systems.
• Because we do not retain a copy, we are not able to return, re-send, or re-generate your prior analyses. You are responsible for downloading and saving any output you wish to keep.

Information You Provide by Contacting Us

If you email us with questions, feedback, or a legal request, we will receive whatever information you choose to include in your message (such as your name and email address). We use this information solely to respond to you and to maintain records of the correspondence.

Information We Automatically Collect

When you visit the Site, we and our analytics providers may automatically collect limited technical information, including:

• Your browser type and operating system
• Your Internet Protocol (IP) address
• Approximate geographic region derived from your IP address
• Pages you view and links you click on within the Service
• Standard server log information (e.g., timestamps, referring URLs, errors)
• Information collected through cookies and similar technologies

Cookies are small bits of information stored by your browser. You can configure your browser to accept or reject cookies; if you choose to reject cookies, some features of the Service may not function properly.

Anonymized Analysis Telemetry

Each time the Service completes a contract analysis, our application writes a small anonymized record to our analytics database for product-quality monitoring. This record contains only a limited set of non-identifying technical and product-quality signals about the analysis run, such as the general contract category and high-level counts of the issues identified.

This telemetry does not contain your contract text, your intake answers, your IP address, or any direct identifier, and it cannot reasonably be used to re-identify you.

Third-Party Processors and Information Collection

Anthropic (AI Provider)

Amicus.AI uses Anthropic’s Claude models to read your contract, produce explanations, and draft suggested edits. To do this, the text of your contract and your intake answers are transmitted to Anthropic’s API. Anthropic processes that content as our service provider for the limited purpose of returning the analysis to you and, under Anthropic’s commercial terms, does not use API inputs or outputs to train its models. Your use of the Service is therefore also subject to Anthropic’s applicable terms and privacy disclosures.

Hosting and Analytics Providers

We use third-party providers to host the Site, run the application, and store the anonymized analysis telemetry described above. These providers process information on our behalf and under contractual obligations consistent with this Privacy Policy.

Cookies and Web Beacons from Third Parties

We may allow third-party service providers to place cookies, web beacons, and similar technologies on the Site for traffic measurement, research, and analytics. Information collected by those third parties is subject to their own policies and practices. We do not control these technologies or how the information they collect may be used.

How We Use Your Information

We use the limited information we collect or process to:

• Provide the Service — read your contract, generate intake questions, produce flagged issues and suggested edits, and build the downloadable Word document
• Maintain, debug, secure, and improve the Service
• Monitor aggregate quality metrics (e.g., what kinds of contracts are analyzed and at what severity profile)
• Respond to inquiries, feedback, and support requests
• Comply with legal obligations and enforce our Terms of Service

We do not currently use your information for behavioral or targeted advertising.

Choices About How We Collect, Use, and Disclose Your Information

Choosing What to Upload

Because contracts often contain personal information about parties, counterparties, and third parties, you have meaningful control simply by choosing what to upload. You may redact names, addresses, or other identifiers before uploading if you prefer.

Cookies

You have the option to accept or disable cookies at any time through your browser. If you choose to disable cookies, your user experience may be limited.

Third-Party Advertising

If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web advertisements through cookies set on the Site, you may visit networkadvertising.org/choices or aboutads.info/choices. These opt-out tools are provided by third parties; we do not control or operate them.

Disclosure of Your Information

We may disclose information that we process through the Service as follows:

Service Providers. We share information with the vendors that host and operate the Service, including our AI provider (Anthropic) and our hosting and analytics providers. These providers act on our behalf under contractual restrictions.

Legal Requirements and Protection of the Service. We may disclose information to third parties in order to protect the legal rights, safety, and security of Counsel Club and the users of the Service; enforce our Terms of Service; prevent fraud; and comply with or respond to law enforcement or a legal process or a request for cooperation by a government or other entity, whether or not legally required.

Business Transfers. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer information to one or more third parties as part of that transaction.

With Your Consent. We may share information with other third parties when you consent to such sharing.

Aggregate Information. We may disclose to third parties information that does not describe or identify individual users, such as aggregate usage data or anonymized analysis statistics.

You will be notified via a prominent notice on the Site of any change in ownership or material uses of personal information, as well as any choices you may have.

Social Networking Services

The Service does not currently integrate with social networking services or post content on your behalf. If we add such features in the future, we will update this Privacy Policy.

Links to Third-Party Sites and Services

The Service may contain links to other websites or online services that are operated and maintained by third parties and that are not under the control of or maintained by Counsel Club. Such links do not constitute an endorsement by Counsel Club of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of those third-party websites or services.

Do Not Track Signals

Third parties may keep track of your browsing activities across third-party websites. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to “Do Not Track” browser signals. Certain web browsers enable users to activate a “Do Not Track” signal, but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.

Data Retention

We strive to keep information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements.

• Contract text and intake answers: processed in memory during your session and not retained on our servers.
• Generated analyses and downloadable documents: produced for you and not retained on our servers.
• Anonymized analysis telemetry (analysis ID, contract type, severity counts, build hash): retained for product quality and historical reporting.
• Server logs and cookies: retained for a limited period consistent with standard hosting and analytics practices.
• Correspondence you send us: retained as long as reasonably necessary to respond and to maintain records of the exchange.

Accessing and Correcting Your Information

Because Amicus.AI does not currently maintain user accounts and does not store the contracts you analyze, there is generally no persistent profile of you to access, update, or delete. If you believe we hold information about you that you would like to access, correct, or delete (for example, an email exchange or a residual log entry), please contact us at hello@counselclub.co and we will respond consistent with applicable law.

Security

We take reasonable steps to protect information processed through the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Contract text and intake answers are transmitted over encrypted connections to our application and to our AI provider, and are not written to long-term storage by Counsel Club. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from the Service may not be secure. You should take care in deciding what information you send to us via e-mail. In the event that personal information is compromised as a breach of security, Counsel Club will promptly notify affected individuals in compliance with applicable law.

Notice to California Residents

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a calendar year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not currently share personal information with third parties for their own direct marketing purposes. If you are a California resident and would like to make such a request, please send an email to hello@counselclub.co.

If you are under 18 years of age, reside in California, and have submitted content through the Site, you have the right to request removal of unwanted data that you publicly post. To request removal of such data, please contact us using the contact information provided and include a statement that you reside in California. We will make sure that the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from our systems.

To request any other changes or information about our collection, use, or disclosure of your information, please email us at hello@counselclub.co.

Children Under the Age of 13

The Service is intended for users who are 13 years of age and older. If you are under the age of 13, you are not permitted to submit any personal information to us. If you believe we might have any information from or about a child under 13, please contact us at hello@counselclub.co.

International Users

The Service is directed toward users who reside in the United States. By using the Service, you consent to the collection, processing, and transfer of your information in and to the United States, or other countries and territories in which our service providers operate, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own.

Information Applicable to EU Users

The General Data Protection Regulation (“GDPR”) gives certain rights to individuals in the European Union in relation to their personal data. As available and except as limited under applicable law, the rights afforded to individuals are:

• Right of Access — the right to be informed of and request access to the personal data we process about you;
• Right to Rectification — the right to request that we amend or update your personal data where it is inaccurate or incomplete;
• Right to Erasure — the right to request that we delete your personal data;
• Right to Restrict — the right to request that we temporarily or permanently stop processing all or some of your personal data;
• Right to Object — the right, at any time, to object to our processing of your personal data on grounds relating to your particular situation, and the right to object to processing for direct marketing purposes;
• Right to Data Portability — the right to request a copy of your personal data in electronic format and the right to transmit that personal data to another party’s service; and
• Right not to be subject to Automated Decision-making — the right not to be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect. The Service uses AI to analyze contracts and suggest edits, but the resulting analysis is advisory only and not a binding decision; you choose whether to accept, modify, or reject any suggested edit.

Because we generally do not retain the contract content you submit and do not maintain user accounts, our ability to act on some of these rights with respect to that content is limited — there is typically no stored copy to access, rectify, or port. If you wish to exercise any of the above rights, please contact us at hello@counselclub.co.

Contact Information

If you have any questions about this Privacy Policy, please contact us at hello@counselclub.co.