Privacy Policy

Effective date: October 30, 2025

1. Who We Are and Scope

serfsUp (together with its affiliates, "we," "us," "our") is a hybrid technology company and law firm platform. We provide legal information services (including a 24/7 simple legal question service) and facilitate legal services delivered by licensed attorneys. Today we operate in California, New York, and Texas through independent contractor relationships with partner attorneys. We communicate only through written channels—SMS, WhatsApp, and email—and, on request, can arrange video or phone meetings with attorneys. As we expand nationwide, we will update this Policy to reflect new states.

We expect to operate an Arizona Alternative Business Structure (ABS)–owned law firm affiliate. An ABS allows non-lawyer ownership/participation in law firms under Arizona Supreme Court rules; it is licensed and regulated by Arizona's program. If/when our ABS is live, it will be included as an affiliate under this Policy.

This Privacy Policy applies to our websites and apps (if any), SMS/WhatsApp/email communications, our 24/7 question-answering service, intake conversations (even when no agreement is signed), and legal services delivered by partner attorneys or our ABS-owned law firm.

2. How We Work (Short Version)

We do not sell or share your personal information for cross-context behavioral advertising. If this ever changes, we will provide the required "Do Not Sell or Share" controls and honor recognized opt-out preference signals (e.g., Global Privacy Control) as required by California law.

AI subprocessors

We use OpenAI, Anthropic, and Google as subprocessors to automate parts of intake, routing, drafting, and quality control. Our enterprise accounts are configured with no training on your data and zero data retention by those providers; we instruct them to process data only under our direction. However, we cannot guarantee absolute compliance by third-party AI providers with these contractual terms. In the event of a breach or non-compliance by an AI subprocessor, we will notify affected users as required by applicable law and take reasonable steps to mitigate harm.

Attorney involvement

Licensed attorneys (independent contractor partner attorneys now, and later attorneys of our ABS-owned law firm) review matters as appropriate.

Prospective client confidentiality

We treat intake communications (including our question-answering service) as confidential; however, attorney-client privilege may not attach until a formal engagement is established. Ethical rules restrict lawyers' use/disclosure of information learned from prospective clients.

3. Personal Information We Collect

Information you provide directly

Contact details (name, email, phone), identity and demographic details you choose to provide, chat/message content, documents you upload, billing/subscription information (handled by our payment processor), matter facts, and scheduling preferences.

Information we collect automatically

Service logs and metadata (timestamps, message routing, delivery/read status, IP addresses, device and network data). If you use our website, we may use limited cookies or similar technology for operations and security.

Information from others

Referrals, opposing/related parties, courts and agencies, public records, and service providers (e.g., communications and analytics vendors).

Sensitive personal information

Depending on your matter, you may share sensitive data (e.g., government IDs, financial/immigration/health-related facts). We use this only to provide services or meet legal/ethical obligations, not for advertising or unrelated purposes. California residents may have a right to limit the use of Sensitive Personal Information; see Section 9.

AI-generated information

Our AI tools may generate summaries, analyses, suggestions, or draft documents based on information you provide. These AI outputs become part of your matter file and are subject to the same confidentiality protections as your original information. AI-generated content may contain errors or inaccuracies; such outputs are reviewed by licensed attorneys before being used in legal deliverables.

4. How We Use Personal Information

  • Provide and improve our services (intake, routing, drafting, scheduling, conflicts checks, quality assurance).
  • Enable communications by SMS/WhatsApp/email and (when requested) by phone/video.
  • Operate subscriptions and flat-fee/hourly engagements; process payments through a PCI-compliant payment processor.
  • Comply with law and professional obligations (ethics, recordkeeping, trust accounting, conflict screening).
  • Protect our services and clients (fraud/security monitoring).
  • We do NOT use your personal information, communications, or case data to train, fine-tune, or improve AI models operated by us or third parties, except: (i) aggregated, de-identified usage analytics that cannot reasonably identify you or your matter; and (ii) as necessary to debug, secure, or maintain system functionality. Any such use will comply with professional confidentiality obligations.
  • AI tools assist with matter routing, complexity assessment, and resource allocation, but final decisions regarding service delivery are made or reviewed by humans.
  • We do not use AI to make solely automated decisions that would deny you legal services or produce adverse legal effects without human involvement.

We do not use your message content for third-party advertising. We do not use solely automated decision-making to deny access to legal services.

5. How We Share Information

Attorneys and law firms

Independent contractor partner attorneys (today) and, once licensed, our ABS-owned law firm affiliate (future). They are bound by professional rules of confidentiality and by our agreements.

Service providers / subprocessors

Communications vendors (for SMS, WhatsApp, email delivery), cloud hosting and security providers, e-signature, e-billing, and the foundation-model providers named above. We require confidentiality and use limitations by contract.

Counterparties / authorities

With your direction or as necessary to deliver legal services (e.g., filings with a court/agency) or to comply with law or enforce our rights.

Corporate transactions

In connection with mergers, financing, or sale of assets, subject to confidentiality commitments.

6. Communications Channels and Confidentiality

SMS, WhatsApp, and email are our standard channels. While we implement strong safeguards, these channels inherently involve third-party networks and providers. For highly sensitive data, ask us about alternative secure options.

Prospective client information

Lawyers have duties to prospective clients—even if no engagement follows—restricting the use/disclosure of information learned. We honor those duties and limit internal access accordingly.

Marketing texts/emails

We rarely send marketing; if we do, you may opt-out at any time (e.g., reply STOP to SMS).

7. Generative AI Subprocessors (OpenAI, Anthropic, Google)

We use enterprise accounts with settings configured to disable training on your content and to avoid provider retention; we send only the minimum data needed for a task, and we bind these providers to contractual privacy and security terms. We supervise outputs before they are used in client work. (If these settings or vendors change, we will update this Policy.)

8. AI Specific Privacy Risks and Limitations

Inherent AI Risks

While we implement safeguards, AI technologies present unique privacy considerations:

  • Data Processing Scope: AI models may process your information to generate responses, which involves analyzing content, context, and patterns in ways that may not be immediately apparent
  • Inference and Derivation: AI may infer or derive information beyond what you explicitly provide based on patterns and context
  • Output Unpredictability: AI may occasionally generate outputs that inadvertently reference or combine information in unexpected ways
  • Third-Party Infrastructure: AI subprocessors operate on infrastructure we do not directly control, creating dependencies on their security practices

Our Mitigation Measures

  • Minimum necessary data transmission to AI systems
  • Contractual data protection requirements with all AI vendors
  • Attorney review of AI outputs before client delivery
  • Ongoing monitoring of AI vendor security practices and compliance
  • Regular security assessments of AI integrations

Your Acknowledgments

By using our AI-assisted features, you acknowledge these inherent risks and our mitigation efforts, and you agree that we are not liable for privacy harms caused by AI subprocessor conduct that violates our contractual terms, provided we exercised reasonable care in vendor selection and oversight.

9. Your Privacy Rights (U.S. State Laws)

California (CCPA/CPRA)

California residents may have the right to know/access, delete, correct, portability, opt-out of sale or sharing, limit use of Sensitive Personal Information, and non-discrimination for exercising rights. We also honor the Global Privacy Control for opt-outs as required. You may use our Privacy Request Form, email privacy@serfsup.com, or use the browser signal.

California residents also have the right to know:

  • What categories of personal information are processed by AI systems
  • The purposes for which AI processes your information
  • Whether AI-generated insights or profiles are created about you
  • Whether automated decision-making affects your access to services

You may request this information using the mechanisms described below.

Our current status: We do not sell or share personal information for cross-context behavioral advertising. If that changes, we will provide a prominent "Do Not Sell or Share My Personal Information" link and a "Limit the Use of My Sensitive Personal Information" control.

Other comprehensive state privacy laws

We extend comparable rights (access, deletion, correction, portability, and opt-out of sale/targeted advertising/profiling; appeals where required) to residents of states with active comprehensive privacy laws, including Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Delaware, Tennessee, and Texas.

How to exercise rights (all states)

Submit a request via our Privacy Request Form or email privacy@serfsup.com. We will verify your identity, respond within the time required by law, and honor authorized agents where permitted. If we decline your request, you may appeal by replying to our decision (we'll include appeal instructions). If you remain unsatisfied, you may contact your state Attorney General.

10. Illinois-Specific Disclosures (BIPA and Breach Notice)

Biometric Information Privacy Act (BIPA)

We do not collect "biometric identifiers" (e.g., retina/iris scan, fingerprint, voiceprint, or scan of hand/face geometry). If we ever need to collect biometric identifiers or biometric information (for example, to power identity verification), we will first provide a written policy with a retention schedule and obtain a written consent, will not sell or profit from such data, and will use reasonable safeguards—consistent with BIPA's requirements.

Illinois Personal Information Protection Act (PIPA)

In the event of a data breach involving Illinois residents, we will provide breach notifications as required by PIPA. If we implement AI-powered voice or video features (e.g., AI-assisted video conferences, voice transcription), we will:

  • Obtain your express consent before processing voice or video through AI
  • Disclose which AI systems process such data
  • Explain how long voice/video data is retained
  • Provide opt-out mechanisms for AI processing of voice/video

This is in addition to any BIPA obligations for biometric data.

11. New York Data Security (SHIELD Act)

For New York residents, we maintain a reasonable security program with administrative, technical, and physical safeguards designed to protect private information, consistent with the NY SHIELD Act's requirements.

12. Texas (TDPSA)

Texas residents have privacy rights under the Texas Data Privacy and Security Act. We recognize applicable rights (access, delete, correct, portability, and opt-out of targeted advertising/sale) and controller duties.

13. Data Retention

We retain personal information only as long as needed for the purposes described above, to provide services, for legitimate business needs (e.g., conflict checks), and to meet legal and professional obligations. Legal-matter files are retained consistent with applicable ethics rules and law. If you request deletion, we will delete or de-identify your data unless we must retain it (e.g., to comply with law, enforce agreements, or resolve disputes).

Information you provide that is processed by AI is retained according to the general retention rules above. AI-generated drafts, summaries, and analyses are retained as part of your matter file subject to legal and ethical retention requirements.

We retain logs of AI system queries and responses for quality assurance, security monitoring, and professional responsibility for the duration of engagement plus 7 years. We do not retain identifiable data for AI training purposes; any aggregated usage analytics are de-identified and retained indefinitely for system improvement.

14. Security

We use administrative, technical, and physical safeguards to protect personal information (e.g., access controls, encryption in transit, logging/monitoring, least-privilege access, staff training). No system is 100% secure, but we strive to meet or exceed industry and professional standards and applicable state-law baselines (e.g., NY SHIELD).

In addition to general security safeguards, we implement AI-specific protections:

  • AI systems access only the minimum data necessary for specific tasks
  • We employ technical safeguards to prevent manipulation of AI systems through malicious inputs
  • We monitor outputs to detect and prevent AI systems from inadvertently disclosing other users' information
  • We conduct regular reviews of AI subprocessors' security certifications, practices, and incident history
  • All data transmitted to AI subprocessors is encrypted in transit, and we require encryption at rest where available
  • We maintain procedures to detect and respond to AI-specific security incidents, including unauthorized data exposure through AI outputs

Despite these measures, AI systems may be vulnerable to emerging attack vectors including adversarial inputs, model extraction attempts, and prompt injection. We continuously monitor for such threats but cannot guarantee prevention of all AI-specific security risks.

15. Children's Privacy

Our services are not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe a child provided information, contact us and we will delete it.

16. International Users

We are a U.S.-based provider. Your information may be transferred to, stored, and processed in the United States or where our service providers operate. We apply the protections described in this Policy regardless of location.

17. Changes to This Policy

We may update this Policy to reflect operational, legal, or regulatory changes. We will post the updated Policy with a new effective date and, where material, provide additional notice.

18. AI Incident Reporting

If you suspect that an AI system disclosed information it should not have, that AI generated content about you that appears inaccurate or harmful, that an AI interaction violated your privacy expectations, or that an AI system was manipulated or behaved unexpectedly, please report it immediately to ai-incidents@serfsup.com.

We will:

  • Acknowledge receipt within 2 business days
  • Investigate the incident within 10 business days
  • Provide you with findings and any corrective actions taken
  • Implement measures to prevent recurrence where appropriate

This incident reporting process does not limit any legal rights you may have regarding privacy violations.

19. Contact Us

Privacy requests: privacy@serfsup.com

General inquiries: legal@serfsup.com

If you are in California: You may also use your browser's Global Privacy Control to opt out of sale/sharing (which we currently do not engage in).