Privacy Policy

Including notices for California and European residents

Last Updated: July 7, 2026

Introduction

OGTW, Inc. DBA “Arabella” (“Arabella,” “Company,” “we” or “us”) operates Arabella (the “Service”), an AI-assisted legal platform available at our website (the “Site”). The Service includes contract review and redlining, a library of customizable form agreements, business formation support, a document workspace tied to your account, and related features. 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 Arabella Handles Your Documents

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

• You have an account. Arabella offers user accounts. You sign in with an email link or code, or with Google. Member features (redlining, the contract library, formation, and your workspace) require an account.
• Your documents are saved to your private workspace. Contracts you upload for redlining, the resulting analyses and edits, and agreements you customize from our library are stored in your account so you can reopen them later. They stay in your workspace until you delete them or your account is deleted. Your stored documents are private to your account.
• Document content is sent to our enterprise AI provider solely to generate your analysis, explanations, and suggested edits. Under the provider’s commercial terms, it is not used to train AI models. See “Third-Party Processors” below.
• Payments run through Stripe. Card details are collected directly by Stripe. We do not see or store your card number.
• We use analytics and an advertising pixel. We use PostHog to understand how the Service is used and a Meta (Facebook) pixel to measure our advertising. These tools receive usage events such as page views and checkout steps. They do not receive the contents of your documents.

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.

Account Information

When you create an account or sign in, we collect your email address and authentication identifiers. If you sign in with Google, we receive basic profile information from Google (such as your name and email address) in accordance with your Google settings. We use a third-party authentication and database provider to manage sign-in; we do not receive or store passwords.

Business Profile Information

You may provide facts about your business through our intake and profile features, such as your business name, entity status, what your business does, your home state, team size, typical clients, and a notice email address. We use this information to personalize contract analysis, prefill agreements and questionnaires, and tailor the Service to your business. You can review and update these facts in the Service.

Documents and Content You Submit

When you use Arabella, you may upload a contract file (PDF or Word), paste contract text, answer intake and customization questionnaires, or generate agreements from our library. We process and store this material in the following way:

• Your contract text and questionnaire answers are transmitted to our AI provider to generate the analysis, suggested edits, and explanations.
• When you save a redline to your workspace, we store the contract text, the analysis results, your questionnaire answers, your accept and reject decisions, and (if you uploaded a Word file) the original file, so the redline can be reopened later.
• When you customize an agreement from our library, we store the finished document in your workspace under saved agreements.
• Stored documents remain in your workspace until you delete them from the Service or your account is deleted.

Formation Information

If you use our business formation feature, we collect the information required to prepare and coordinate your state filing, such as your company name, entity type, state of formation, principal address, and management or ownership details. We check proposed business names against state records through a third-party name-availability service, which receives only the business name and the state being searched. Formation details are shared with our registered agent partner and the state filing office as needed to complete your filing.

Payment Information

Payments are processed by Stripe. When you start a membership or pay for a formation filing, your card details are collected directly by Stripe and are subject to Stripe’s privacy policy. We do not receive or store your card number. We store records of your subscription and payment status (such as your Stripe customer identifier, plan, and trial or billing state) to operate your membership.

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 and advertising providers may automatically collect technical and usage 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
• Product events such as starting a questionnaire, opening checkout, or completing a purchase
• Standard server log information (e.g., timestamps, referring URLs, errors)
• Information collected through cookies, pixels, 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.

Third-Party Processors and Information Collection

We use a small number of third-party providers to operate the Service. Listed by role:

Hosting, Database, and File Storage

We use third-party providers to host the Site and application and to store your account data, business profile, and workspace documents. Our database and file storage provider (Supabase) stores your account records and documents with access controls that restrict each workspace to its owner. These providers process information on our behalf and under contractual obligations consistent with this Privacy Policy.

AI Provider

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

Payments (Stripe)

Stripe processes membership subscriptions and one-time formation payments. Stripe collects your card details directly and processes them under its own privacy policy. We receive confirmation of payment, subscription status, and related billing metadata, but not your card number.

Analytics (PostHog)

We use PostHog, hosted in the United States, to collect usage analytics such as page views and product events. We use this information to understand how the Service is used and to improve it. PostHog does not receive the contents of your documents.

Advertising Measurement (Meta)

We use the Meta (Facebook) pixel on the Site to measure the effectiveness of our advertising. The pixel collects events such as page views, checkout starts, and completed purchases, along with cookie and device identifiers, and shares them with Meta. Meta may use this information in accordance with its own data policy, including to match events to Meta accounts for ad measurement and to support ad delivery. The pixel does not receive the contents of your documents. See “Advertising and Your Choices” below for opt-out options.

Email Delivery (Resend)

We use Resend to deliver transactional email, including formation confirmations and documents you choose to email from the Service. When you email a document to a recipient, we process the recipient’s email address, your email address (used as the reply-to), any note you include, and the document itself for the purpose of delivering that message.

State Name Availability (Cobalt)

When you check whether a business name is available during formation, we send the proposed business name and the state being searched to Cobalt Intelligence, a service that queries Secretary of State records. Cobalt receives only the business name and state, not your identity or other formation details.

Cookies and Web Beacons from Third Parties

We allow the third-party providers described above to place cookies, pixels, and similar technologies on the Site for analytics and advertising measurement. Information collected by those third parties is subject to their own policies and practices.

How We Use Your Information

We use the information we collect or process to:

• Provide the Service: read your contract, generate intake questions, produce flagged issues and suggested edits, build downloadable Word documents, customize library agreements, and prepare formation filings
• Operate your account and workspace, including saving, reopening, and emailing your documents at your direction
• Personalize the Service using your business profile, such as prefilling agreements and tailoring analysis to your business
• Process payments, manage subscriptions and trials, and prevent fraud
• Maintain, debug, secure, and improve the Service
• Understand how the Service is used and measure the effectiveness of our advertising
• Send transactional communications such as sign-in links, confirmations, and documents you ask us to send
• Respond to inquiries, feedback, and support requests
• Comply with legal obligations and enforce our Terms of Use

Advertising and Your Choices

We use the Meta pixel to measure our advertising and to help us reach people likely to be interested in Arabella, which may include retargeting people who have visited the Site. We do not use the contents of your documents, your business profile, or your formation details for advertising.

California residents (and anyone else) can opt out of this sharing at Your Privacy Choices. Opting out stops the Meta pixel from loading in your browser. We also honor the Global Privacy Control (GPC) browser signal as a valid opt-out of sharing, automatically.

Choosing What to Upload and Store

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, and you can delete saved documents from your workspace at any time.

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 Opt-Outs

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. You can also manage how Meta uses data collected through its pixel in your Meta ad settings. 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 hosting, database, and storage providers, our enterprise AI provider, our payment processor, our analytics and advertising providers, our email delivery provider, and our name-availability service, each as described above. These providers act on our behalf under contractual restrictions, except where their own policies apply as noted.

Formation Filings. If you ask us to form an entity, we share the information required for the filing with our registered agent partner and the applicable state filing office.

Recipients You Choose. If you use the Service to email a document, we send that document and your reply-to email address to the recipient you specify.

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 Arabella and the users of the Service; enforce our Terms of Use; 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 Sign-In

You can sign in to Arabella with your Google account. When you do, Google shares basic profile information with us (such as your name and email address) in accordance with your Google settings. We do not post to any social networking service on your behalf. If we add additional sign-in providers or social 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 Arabella. Such links do not constitute an endorsement by Arabella 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 and Global Privacy Control Signals

California Business & Professions Code Section 22575(b) provides that California residents are entitled to know how we respond to browser privacy signals. We honor the Global Privacy Control (GPC) signal: when your browser sends GPC, we treat it as a valid request to opt out of the sharing of your information for cross-context behavioral advertising, and the Meta pixel will not load. You can also opt out manually at Your Privacy Choices. We do not respond to the older “Do Not Track” signal, which lacks a settled standard.

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.

• Workspace documents (uploaded contracts, saved redlines and their analyses, customized agreements): retained in your workspace until you delete them or your account is deleted.
• Account and business profile information: retained while your account is active and deleted or anonymized within a reasonable period after account deletion, except where we must keep records to comply with law.
• Formation records: retained as needed to complete and document your filing and to comply with legal and tax obligations.
• Payment and subscription records: retained as required for accounting, tax, and legal compliance. Card numbers are held by Stripe, not by us.
• Usage analytics and advertising events: retained per our analytics and advertising providers’ standard retention practices.
• 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, Correcting, and Deleting Your Information

You can view and manage the documents saved to your workspace, and delete them, from within the Service. You can review and update your business profile in the Service. To request access to, correction of, or deletion of other personal information we hold about you, or to request deletion of your account, please contact us at hello@usearabella.com and we will respond consistent with applicable law. We may need to verify your identity before acting on a request, and we may retain certain information where required or permitted by law.

Security

We take reasonable steps to protect information processed through the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Your documents and personal information are transmitted over encrypted connections and stored with providers that encrypt data at rest. Access to your workspace is restricted to your account through database-level access controls. Card details are handled by Stripe and never stored on our systems. 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, Arabella 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 sell personal information, and we do not share personal information with third parties for those third parties’ own direct marketing purposes, except that our use of the Meta pixel for advertising measurement is described above under “Advertising Measurement (Meta).” If you are a California resident and would like to make such a request, or to opt out of pixel-based advertising measurement, please send an email to hello@usearabella.com.

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@usearabella.com.

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@usearabella.com.

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.

You can exercise many of these rights directly in the Service by updating your business profile or deleting documents from your workspace. For anything else, including account deletion or a copy of your data, please contact us at hello@usearabella.com.

Contact Information

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