Privacy Policy

We are Crumb Topco Ltd ("Correm", "we", "us", "our"), a company incorporated in England and Wales. We are the data controller for personal data we process for our own purposes (such as running the Platform, marketing, and managing investor relationships). For matter-related data processed on behalf of a Lawyer in connection with their client work, the Lawyer is the data controller and we act as data processor under a data processing agreement.

You can contact us about this policy at kenzo@correm.ai.

This policy applies to:

• individuals who visit and use our website, mobile applications and platform (the "Site, Apps and Platform"), and engage with us through social media or in connection with any contracts or related matters;
• individuals we deal with in their business capacity, such as representatives of Companies, Lawyers, suppliers or investors; and
• individuals who apply for work with us.

Where you engage a Lawyer through the Platform, the Lawyer will provide a separate privacy notice in respect of personal data they process as data controller for the engagement.

Identity Data

first name and surname.

Contact Data

billing address, email address, telephone numbers.

Business Data

the name of the organisation you represent, your position, department and business ID numbers.

Personal Verification Data

passport or ID and proof of address where required for Lawyer onboarding or compliance purposes.

Financial Data

bank account details and payment information (handled via Stripe; we do not store card numbers).

Transactional Data

information about our business dealings, transactions and interactions.

Technical Data

IP address, browser type, device information, and login credentials when you use the Site, Apps or Platform.

Usage Data

information about how you use the Site, Apps and Platform including user preferences and notes.

Content Data

content uploaded by you (such as briefs, queries, communications with Lawyers).

Marketing and Communications Data

your preferences for receiving marketing from us and your communication preferences.

Investor Data

information related to investments in Correm.

Recruitment Data

data relating to applications to work with us.

We process personal data only where we have a lawful basis. The basis will usually be one of:

• Performance of a contract with you, or taking steps before entering into one (for example, providing you with access to the Platform);
• Our legitimate interests in operating our business (for example, communicating with users, improving the Platform, preventing fraud), where these interests are not overridden by your rights;
• Compliance with law where we are subject to a legal obligation; or
• Consent, where you have given consent to processing for a specific purpose (for example, marketing or non-essential cookies). You may withdraw consent at any time.

Correm provides AI-powered tooling (including the Morsel AI agent) and continues to develop those tools. We are explicit about how data is used in connection with AI:

• We do not use personal data to train AI models. Personal data of any individual — names, contact details, identifiable client information, identifiable counterparty information — is excluded from training data.
• We do not use confidential client work product to train AI models. Specific contract content, matter-specific facts, client identities, deal-specific terms and any data that could identify a particular client, transaction or matter is excluded from training data.
• We do train on aggregated and anonymised platform data. This includes structural workflow signals — for example, how often particular contract clause structures appear, the distribution of rule fires and overrides across the platform, and matter-type frequency. These signals contain no personal data and cannot be used to identify any individual, client, matter or counterparty.
• Lawyers control matter-level data. For matter-related data processed on behalf of a Lawyer, training use is governed by the data processing agreement between Correm and the Lawyer, which restricts use to the aggregated, non-personal form described above.

We share personal data with:

• service providers who host and support the Site, Apps and Platform (cloud hosting, payment processing via Stripe, email delivery, analytics);
• Lawyers and Companies — where you are a Lawyer, with Companies who are matched with you (and vice versa);
• professional advisers (lawyers, accountants, auditors, insurers) where reasonably necessary;
• prospective buyers or investors if we sell or restructure our business;
• regulators or law enforcement where required to comply with a legal or regulatory obligation; and
• others where required to protect the rights, property or safety of Correm, our users or third parties.

We do not sell your personal data. We require third parties to respect the security of your personal data and to treat it in accordance with the law and our instructions.

Where permitted by law or where we have your consent, we may send you marketing communications about Correm. You can opt out at any time by emailing kenzo@correm.ai or using the unsubscribe link in any marketing email. We do not share your personal data with third parties for their own marketing.

Your information is stored primarily in the United Kingdom and the European Economic Area (EEA). Where we transfer personal data outside the UK or EEA — for example to a service provider hosted in the United States — we rely on approved transfer mechanisms (such as the EU Standard Contractual Clauses and the UK International Data Transfer Addendum) to ensure adequate safeguards are in place.

Subject to limited exceptions, you have the right to:

• request confirmation of whether we process your personal data and a copy of the personal data we hold;
• have inaccurate personal data rectified or incomplete personal data completed;
• have your personal data erased in certain circumstances;
• restrict or object to our processing of your personal data;
• have your personal data transmitted directly to another organisation where technically feasible (data portability);
• withdraw consent where the processing is based on consent; and
• not be subject to a decision based solely on automated processing that produces legal or similarly significant effects on you, unless we have your consent, it is authorised by law, or it is necessary for the performance of a contract.

To exercise any of these rights, email kenzo@correm.ai. We may ask you to verify your identity before responding.

We have put in place technical and organisational measures designed to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to personal data to those employees, agents and contractors who have a business need to access it. They process personal data only on our instructions and are subject to a duty of confidentiality.

We retain personal data for as long as necessary for the purposes for which it was collected, and to satisfy any legal, regulatory, accounting, tax, reporting and insurance requirements. After the end of our relationship with you, we may retain data in aggregated and anonymised form for analytical and product-improvement purposes, where it can no longer be used to identify you.

If you have a complaint about how we process your personal data, please contact us first at kenzo@correm.ai and we will do our best to resolve it. You also have the right to complain to the UK Information Commissioner's Office (ICO):

Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Helpline: 0303 123 1113. Website: ico.org.uk.

If you are in the EEA, you can contact the relevant data protection regulator in your country of residence.

We may update this policy from time to time. We will notify you of material changes via the Site or by email, and update the "Last updated" date above. Continued use of the Site, Apps or Platform after a change constitutes acceptance of the updated policy.

Crumb Topco Ltd, trading as Correm. For privacy queries, email kenzo@correm.ai.