1. INTRODUCTION
DealDoctor PLLC ("DealDoctor," "we," "us," or "our") operates the CARMAI™
software platform ("Software"). This Privacy Policy describes how we collect,
use, disclose, and protect information in connection with your use of the
Software, including the CARMAI™ Word Plugin, the CARMAI™ Web application,
CARMAlly™ at carmai.app/carmally and the CARMAlly™ apps for iOS and Android (collectively, the "Services").
By using the Services, you consent to the practices described in this Privacy
Policy. If you do not agree, do not use the Services.
2. PRIVACY-FIRST ARCHITECTURE
CARMAI™ is built on a privacy-first architecture. We designed the Software
to minimize the exposure of your sensitive information:
DOCUMENT ANONYMIZATION
Before any document text is transmitted to AI providers for analysis,
CARMAI™ applies an anonymization layer that:
• Detects and replaces party names, counterparty names, and personally
identifiable information (PII) with anonymized placeholders
• Uses pattern matching to catch misspellings and variations
• Is designed to ensure that text transmitted to Cloud AI Providers has been anonymized
WHAT THIS MEANS FOR YOU:
• Your original document text is processed on Licensor’s analysis server and is not intentionally transmitted to Cloud AI Providers
• AI providers (Anthropic, OpenAI, Google) are designed to receive anonymized text
• DealDoctor servers receive document text, apply anonymization, and route the resulting anonymized text to AI providers for analysis
• Your confidential terms, party names, and deal details are designed not to be
transmitted to third parties in identifiable form, although no anonymization process can guarantee complete removal of all identifiable information in every instance
3. INFORMATION WE COLLECT
3.1 ACCOUNT INFORMATION
When you register for CARMAI™, we collect:
• Your name and email address
• Organization name
• License key
• Role designation (CARMA Champion)
3.2 USAGE DATA
We collect technical data about how you use the Software:
• Feature usage patterns (which modules, tabs, and tools you use)
• Error reports and crash logs
• Performance metrics (analysis times, export counts)
• Session duration and frequency
Usage data does not include:
• The content of your documents
• Your analysis results or findings
• Your business strategies or work product
• Your entity configurations or counterparty information
3.3 ANONYMIZED ANALYSIS TEXT
When you use AI-powered analysis features, we process the anonymized
version of your document text through our AI routing infrastructure.
This anonymized text:
• Has party names and PII replaced with placeholders where detected
• Is used solely to route your request to AI providers
• Is not retained after the analysis response is delivered, except the latest anonymized copy of each analyzed
document, which is kept in your tenant database (database-tier Subscriptions) so follow-up questions can use it
(Note: CARMAlly™ conversations are stored separately; see Section 3.5)
• Is not intended to be used to train any AI models
3.4 ENTITY SETUP AND CONFIGURATION DATA
Your entity profiles, risk configurations, jurisdiction selections,
and regulatory mappings are stored in your organization's own database (database-tier Subscriptions).
This data:
• Is stored in your organization's own database, separate from other customers' databases
• Is encrypted at rest and in transit
• Is accessible only to authorized users within your organization
• Is designed not to be shared with other tenants or third parties
3.5 CARMAlly™ AI ASSISTANT CONVERSATIONS
CARMAlly™ is the AI assistant in CARMAI™: at carmai.app/carmally, in the CARMAlly™ apps for iOS and
Android, in the CARMAI™ web application and in the Word Plugin. CARMAlly™ answers are written by
Anthropic (Claude). No other AI provider is used for CARMAlly™.
WHAT IS SENT TO ANTHROPIC:
• Your question, after names, email addresses and other identifying details are removed where detected
• At carmai.app/carmally and in the iOS and Android apps: up to your six most recent messages in the same
conversation, each shortened and anonymized the same way, so CARMAlly™ can follow the conversation
• In the web application, when you ask about a document you selected: up to the first 60,000 characters of
that document's anonymized copy
CUSTOMERS WITH A DATABASE-TIER SUBSCRIPTION (PROFESSIONALS, TEAM, ENTERPRISE):
Conversations are stored in your organization's tenant database. This data:
• Is kept until it is deleted; there is no automatic deletion
• Can be deleted by you, conversation by conversation, in the web application and the Word Plugin; an
administrator can clear all of the organization's conversations
• Is not viewable by administrators or other users, and is not included in data exports
• Is not intended to be shared with other customers or used to train AI models
SOLO CUSTOMERS:
Conversations are not stored on DealDoctor servers or retained on your device after the session ends.
ALL CUSTOMERS:
• For each question we record usage (your user identifier, the AI model, token counts, cost, response time
and status), not the content of the question or the answer
• An answer to a question asked without earlier messages may be kept in server memory and reused for up to
24 hours when the same question is asked again, by you or by anyone else; it stays in memory only until it is
removed or the server restarts, and it is never written to disk or to any database
• If you use "Report this response" in the apps, the question, the answer, your reason and your email
address are stored and emailed to DealDoctor support so the report can be reviewed
3.6 COOKIES AND SESSION MANAGEMENT
The Software uses a strictly necessary session cookie (carmai_sid)
to maintain your authenticated session. This cookie:
• Is set upon successful login and expires after 24 hours
• Is configured with HttpOnly and Secure attributes to prevent
access by third-party scripts and ensure encrypted transmission
• Is classified as strictly necessary for operation and does not
require separate consent under applicable cookie regulations
The Software does not use advertising cookies, tracking cookies,
analytics cookies, or any third-party cookies.
3.7 CARMAGREE™ ELECTRONIC SIGNATURE DATA
When you use CARMAgree™, the Software's electronic signature service,
Licensor stores signed documents and related data (including signer names,
email addresses, signing actions, and timestamps) on its servers for the
duration of the active Subscription.
CARMAgree™ signed documents and related data are stored in your organization's own database,
separate from the databases of other customers. CARMAgree™ is not available on the Solo plan.
Upon cancellation or termination, you have sixty (60) days to export
CARMAgree™ data through the Software. After that period, CARMAgree™
data is permanently deleted.
Electronic signatures captured via CARMAgree™ are intended to comply
with the U.S. Electronic Signatures in Global and National Commerce
Act (15 U.S.C. § 7001 et seq.) and the Uniform Electronic Transactions
Act as adopted by each applicable State. See Section 6.d of the EULA
for details.
4. HOW WE USE YOUR INFORMATION
We use the information we collect to:
• Provide, maintain, and improve the Services
• Process your AI analysis requests (using anonymized text only)
• Authenticate your license and manage your account
• Send transactional communications (account setup, password resets,
critical security notices)
• Monitor and improve Software performance and reliability
• Comply with legal obligations
We do not currently use your information to:
• Train AI models (ours or any third party's)
• Sell or rent your data to third parties
• Build profiles for advertising purposes
• Share your data with other CARMAI™ customers
• Contact you for marketing purposes without your consent
5. AI PROVIDER DATA HANDLING
CARMAI™ routes anonymized analysis requests through cloud AI providers.
Our current providers and their data handling:
ANTHROPIC (Claude): Anthropic processes CARMAlly™ and CARMAI™ AI requests. Anonymized text is processed per
Anthropic's API terms. Anthropic represents that it does not use API inputs to train models under its current API terms.
OPENAI (GPT) AND GOOGLE (Gemini): Used for document analysis only as a fallback, when Anthropic is unavailable and a
key for them is configured, including a key you add in the Word Plugin (BYOK). The text is then processed under
that provider's API terms; each represents that it does not use API inputs to train models under its current API terms.
BRING YOUR OWN KEY (BYOK): A key you add is used through DealDoctor's server, under your own agreement with
that provider. CARMAlly™ does not use BYOK keys.
IMPORTANT: Even with these safeguards, we cannot guarantee the behavior
of third-party AI providers. We select providers with strong privacy
commitments, but their terms may change. We will notify you of any
material changes to our AI provider relationships.
6. DATA STORAGE AND SECURITY
6.1 INFRASTRUCTURE
• Hosted on commercial cloud infrastructure with industry-standard physical and network security
• Encryption of data at rest and in transit using industry-standard protocols
• A dedicated database per tenant for your documents, settings, CARMAlly™ conversations and AI usage records
(database-tier Subscriptions); account records, CARMAlly™ reports and Solo usage records are kept in
DealDoctor's platform database
• Regular automated backups
6.2 ACCESS CONTROLS
• Access controls within your organization
• Workflow enforcement for document approvals
• Audit logging of user actions
• DealDoctor restricts employee access to your data and requires your prior written consent before any such access, except as necessary for emergency security response
6.3 DATA RETENTION
• Account data: Retained while your account is active, plus 60 days
after termination for data export
• Anonymized analysis text: Not retained after response delivery, except as described in Section 3.3
• Usage records (user identifier, AI model, token counts, cost, timing; no content): Kept until your account is deleted on request (Section 7.2)
• Audit logs: Kept until your account is deleted on request; an administrator can clear the activity log
• CARMAlly™ conversations (customers with a database-tier Subscription): Kept until you or an administrator delete them, or your account is deleted on request. There is no automatic deletion.
• Audit trail (customers with a database-tier Subscription): Kept until your account is deleted on request; an administrator can clear the activity log.
• CARMAgree™ signed documents and related data: Retained for the active Subscription period plus a sixty (60) day post-termination grace window, after which permanently deleted. CARMAgree™ data is stored in your organization's own database (see Section 3.7).
• Session cookies: Expire after 24 hours
7. YOUR RIGHTS AND CHOICES
7.1 DATA EXPORT (PORTABILITY)
Database-tier customers may export their organization's data at any time using the built-in data
export feature, as a ZIP file (records as JSON, documents in their original format) or a CSV file. This
supports your rights under GDPR Article 20 and similar data portability regulations. For a complete copy of
the data we hold for your organization, including anything the export does not cover, contact
privacy@dealdoctor.pro. CARMAlly™ conversations are not included in the export; an open conversation can be printed or
saved from the Word Plugin.
7.2 DATA DELETION AND RETENTION CONTROLS
Customers with a database-tier Subscription have the following data management controls:
• Each user may delete their own CARMAlly™ conversations, one at a time, in the web application and the Word Plugin
• Administrators may clear all of the organization's CARMAlly™ conversations (double confirmation required)
• Administrators may clear the activity log (double confirmation required)
There is no automatic retention period. CARMAlly™ conversations are not included in the data export (Section 7.1).
ACCOUNT DELETION
You may request deletion of your account and all associated data by
contacting us at privacy@dealdoctor.pro. Upon verified request, we
will delete your tenant database and all associated records within 30
days, subject to legal retention requirements.
7.3 ACCESS AND CORRECTION
You may access and correct your account information at any time through
the Entity Setup interface. For data that cannot be corrected through
the interface, contact us at privacy@dealdoctor.pro.
7.4 OPT-OUT
• You may opt out of non-essential communications at any time
8. CHILDREN'S PRIVACY
The Services are not directed to individuals under the age of 18. We do
not knowingly collect personal information from children. If we learn
that we have collected personal information from a child under 18, we
will take steps to delete such information promptly.
9. INTERNATIONAL DATA TRANSFERS
Our servers are located in the United States. If you access the Services
from outside the United States, your information may be transferred to,
stored, and processed in the United States. By using the Services, you
consent to such transfers. We implement appropriate safeguards for
international data transfers, including standard contractual clauses
where required.
10. CHANGES TO THIS POLICY
We may update this Privacy Policy from time to time. We will notify you
of material changes by:
• Displaying a notice within the Software
• Sending an email to your registered address
• Posting the updated policy on our website
Your continued use of the Services after such notification constitutes
your acceptance of the updated Privacy Policy.
If you have questions or concerns about this Privacy Policy or our data practices, contact us at:
| Company: | DealDoctor PLLC |
| Privacy Inquiries: | privacy@dealdoctor.pro |
| Legal Inquiries: | legal@dealdoctor.pro |
| General Support: | support@dealdoctor.pro |