Privacy Policy

Last updated: 21 October 2026

This policy explains how we process personal data when you use the Justivo mobile app (iOS and Android), the website justivo.app and the e-mails we send. Justivo is an artificial-intelligence (AI) legal information service.

1. Controller and contact

The controller is Xprofit OÜ, private limited company, registry code 14662029, VAT no. EE102244366, Pae tn 21, 11415 Tallinn, Harju maakond, Estonia ("we", "us"). For every privacy question or request write to info@justivo.app. We have not appointed a data protection officer; the address above reaches the person responsible for data protection.

2. Personal data we process

• Account: e-mail address, name, app language, one-time login codes (stored only as a hash, valid 15 minutes), session tokens with the IP address and device operating system, time of last activity, internal client number, referral code.
• Profile (optional — used to fill in your documents): person type, first and last name, phone, address, city, postal code, country, personal identification code, date of birth, company name and registry code.
• Case content: your messages and answers to intake questions, the AI's replies, analyses and generated documents, files and photos you upload and the text extracted from them, the photos' own metadata (when it was taken and, if your camera recorded it, where; the device) — kept with the case, used to describe the photo and deleted with the case, and voice input (sent for transcription; we do not store the recording). Case content often includes information about other people, e.g. the opposing party.
• Case memory: short summaries of your earlier cases with a numerical representation (embedding), used to give the AI context in your new cases.
• Find-a-lawyer requests: jurisdiction, topic, city, the search results shown to you and the case brief.
• Documents you send from the app: the recipient's e-mail address, the document and your name as the sender.
• Purchases: plan, subscription status and periods, transaction identifiers of Apple, Google Play or Stripe, amounts, dates, billing name and e-mail. We never receive your card number.
• Devices and notifications: push-notification token, device platform, notification preferences.
• Support: tickets and messages you send us.
• Technical and security data: e-mail and IP address of login attempts (audit log), server and error logs, records of AI processing (section 5), e-mail delivery logs.
• App analytics and crash reports: only if you switch analytics on (consent prompt or Profile; off by default): a pseudonymous user ID, app events (e.g. login, case started, document viewed, purchase started), plan and app language (Google Firebase Analytics). Crash reports (Google Firebase Crashlytics): device and crash information, linked to your user ID only if you have switched analytics on.
• Website: IP address and technical request data; your e-mail address if you join the beta list.

Sensitive data

Legal questions can reveal special categories of personal data (for example health, ethnic origin, religious beliefs, trade union membership, sex life or sexual orientation) or information about criminal offences. Please share only what is needed for your question, and avoid personal identification codes, health records or other people's details where they are not necessary. We process such data only to answer your request and prepare your documents, on the basis of your explicit consent (GDPR Art. 9(2)(a)), which you give by accepting the notice in the app before first use and by entering the information. In the same notice you confirm that you are at least 18 years old. We record the version of the notice you accepted and the time of acceptance as proof of your consent. You can withdraw consent at any time by deleting your account; withdrawal does not affect processing carried out before it.

3. Purposes and legal bases

Where we rely on legitimate interests you may object at any time (section 9).

4. Do you have to provide data?

There is no legal obligation to provide data. An e-mail address is needed to create an account, and the service cannot answer without the facts of your case. Profile data is optional and only needed to fill in documents. Paid plans require a purchase through Apple, Google Play or Stripe.

5. AI processing and AI transparency

• You interact with an AI system, not a lawyer. Replies, analyses and documents are generated by AI. They are marked as AI-generated both visibly (notice in the chat, note in PDF documents) and in machine-readable form (metadata on each AI message, PDF metadata, headers of the e-mails you send to recipients; the e-mail itself goes out in your name), in line with Art. 50 of the EU AI Act (Regulation (EU) 2024/1689).
• OpenAI is our only AI provider. It processes your messages, uploaded files and photos, voice input, the profile data used in your documents, case summaries and web-search queries.
• Backup models. If an OpenAI model is unavailable or fails, the request is handled by another, simpler OpenAI model. We do not pass your data to other AI providers.
• Use for training. Under OpenAI's API terms, data sent through the API is not used to train OpenAI's models by default and may be retained by OpenAI for up to 30 days for abuse monitoring.
• Records of AI processing. We keep a record of each AI request and response (including the full text) so that answers can be traced, errors investigated, complaints handled and the quality of our answers checked and improved. The records are kept with the case they belong to and are deleted when you delete the case or the account.
• Knowledge base. When a case is completed, an anonymised summary of it (the legal issue, the legal assessment and the recommended approach) is stored with its legal area and country in our internal legal knowledge base and may be shown to the AI as reference material when it analyses similar cases of other users. Before storing, we remove your profile data, the names of the parties, e-mail addresses, phone numbers, ID codes, addresses, bank account numbers and dates; the entry's title is only the legal area and country. Cases concerning criminal matters or offences are never included. Purpose: improving answers using anonymised summaries of completed cases; legal basis: legitimate interests (GDPR Art. 6(1)(f)). You can object at any time by writing to info@justivo.app; we then delete the entries made from your cases. They are also deleted with your account.
• Operator review. Cases the system flags as complex or uncertain may be reviewed by our operator to improve answer quality.
• Partner lawyers. If you choose to hand your case to one of our partner lawyers in the app, we share that case (the conversation, uploaded files, the analysis, documents and the lawyer brief) with the lawyer you chose — or, if you choose “any partner lawyer”, with our partner lawyers until one of them takes it. We share it only after you confirm your consent in the app. The lawyer processes it to give you legal help as an independent controller under their own professional duties. Legal basis: your consent and steps taken at your request before a contract (GDPR Art. 6(1)(a)–(b) and Art. 9(2)(a)). You can withdraw the request in the case.
• Your feedback and reminders. Your ratings of answers (👍/👎 and the reason), your answer to “did the analysis help?” and the deadline reminders about your case are kept with the case and deleted with it.
• No automated decisions. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (GDPR Art. 22). The AI provides information; you decide what to do with it. Usage limits of your plan are applied automatically according to the plan you chose.
• Limitations. AI output can be wrong, incomplete or out of date. Check important information and have documents reviewed by a lawyer before relying on them (see the Terms of Service).

6. Recipients

We do not sell personal data and do not use it for advertising. We share it only with:

7. Transfers outside the EU/EEA

Transfers to the USA rely on the EU–US Data Privacy Framework where the recipient is certified, otherwise on the European Commission's Standard Contractual Clauses. We do not transfer data to countries without such safeguards, such as China.

8. How long we keep data

• Account, profile, cases, messages, uploads (including their copies in our file storage), documents, case memory, find-a-lawyer requests and support tickets: as long as your account exists; deleted when you delete the account. Inactive cases are archived after 30 days but not deleted.
• Login codes: 15 minutes.
• Records of AI processing: kept with the case, until the case or the account is deleted; records of deleted cases are deleted automatically.
• E-mail delivery logs: 12 months; the logs of e-mails to your address are also deleted when you delete the account.
• Security logs (login events, sessions, audit log): IP addresses are removed after 12 months; the event records themselves (without your name and e-mail once the account is deleted) are kept for security. A minimal record of an account deletion (internal ID, date, outcome) is kept as proof of the erasure.
• Server and error logs: 90 days, then deleted automatically.
• Billing and accounting records: 7 years from the end of the financial year (Estonian Accounting Act); kept after account deletion. Where such records exist, a deactivated account entry without your name, e-mail or profile data remains as their reference.
• Backups: until they are overwritten in the regular backup cycle.
• Beta list: until you ask to be removed.
• Firebase analytics data: according to the retention setting of our Firebase project.
• Apple, Google and Stripe keep their own records under their policies.

9. Your rights

Under the GDPR you have the right to:

• access your data and receive a copy — Profile → Export Data downloads your main account and case data as JSON; for a complete copy of everything we hold, e-mail us;
• rectify your data (Profile → Edit Profile);
• erase your data (Profile → Delete Account, see what is deleted);
• restrict processing;
• data portability (JSON export);
• object to processing based on legitimate interests, including to reminder e-mails at any time;
• withdraw consent at any time, without affecting earlier processing;
• lodge a complaint with a supervisory authority — in Estonia the Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, www.aki.ee, info@aki.ee — or with the authority of your EU country of residence or work.

Write to info@justivo.app, preferably from your account's e-mail address so we can verify your identity. We answer within one month.

10. Age limit

Justivo is intended for adults. You must be at least 18 years old to use it. We do not knowingly process data of children; if we learn that a child has created an account we delete it.

11. Website, cookies and e-mail

• Cookies: justivo.app sets only one strictly necessary session cookie (_justivo_key) used for security (protection of forms against forgery). We use no analytics, advertising or tracking cookies on the website, so no consent banner is shown.
• Fonts: the website's fonts are hosted on our own server; the website loads nothing from Google Fonts or other third-party services, so your IP address is not sent to them.
• Beta list: if you enter your e-mail address in the beta form we store it to send you news about Justivo. You can unsubscribe at any time by writing to us.
• No e-mail tracking: our e-mails contain no tracking pixels or tracked links; we do not know whether you opened an e-mail.
• The app contains no advertising. Analytics and crash reporting are described in sections 2 and 3.

12. Security

We use encrypted connections (TLS), password-less login with short-lived one-time codes stored only as hashes, ownership checks on uploaded files and documents, logging of logins and AI processing, and redaction of login codes from e-mail logs. No system is completely secure; if a personal data breach is likely to result in a high risk to you, we will inform you.

Data protection documentation

We maintain a record of processing activities (GDPR Art. 30) and a data protection impact assessment (Art. 35) for the AI service, together with our legitimate-interest assessments and a data breach procedure. They are available to the supervisory authority on request.

13. Changes

We will inform you in the app or by e-mail before material changes to this policy take effect.

14. What changed on 29–30 September 2026

• 30 September: added handing your case to a partner lawyer at your request and with your consent, and keeping your ratings of answers, survey answers and deadline reminders.
• Corrected our company details (registry code 14662029, address, VAT number).
• AI processing is now done by OpenAI only: Moonshot AI (Kimi) and DeepSeek are no longer used, and the transfer of data to China and the consent to it under GDPR Art. 49 have ended; if an OpenAI model fails, a simpler OpenAI model is used.
• Named our hosting provider: OVH SAS, France (EU).
• Added Firebase Analytics/Crashlytics, Telegram, Migadu, the knowledge base and case memory; corrected retention periods and the legal basis for reminder e-mails.
• Added a section on sensitive data; the minimum age is now 18.
• Stated exact retention periods: AI-processing records until the case or the account is deleted, IP addresses in security logs and e-mail delivery logs 12 months. Support tickets, e-mail logs and the copies of your uploads are now deleted with your account; a Stripe subscription is cancelled when you delete the account.
• Push notifications no longer contain the text of an AI or support reply; the open-tracking pixel was removed from our e-mails. Operator notifications in Telegram no longer contain your name, e-mail or message text.
• The website now uses self-hosted fonts and no longer contacts Google Fonts.
• We now record the version and time of your acceptance of the in-app notice (consent to processing sensitive data, confirmation of age 18+); the record is included in your data export.
• Knowledge base: summaries of completed cases are now anonymised before they are reused (profile data, names, contact details, ID codes, addresses, bank accounts and dates removed; neutral title), criminal and offence matters are excluded, and you can object at info@justivo.app.
• Server and error logs are now deleted after 90 days.
• App analytics is now based on your consent (off by default, can be switched on or off in Profile); crash reports are linked to your user ID only with that consent. Added a note on our data protection documentation (records of processing, impact assessment).

15. What changed on 19 October 2026

• E-mails (login codes, service e-mails and documents you send) are now sent by Amazon SES (Amazon Web Services, Sweden, EU); Migadu receives incoming mail and remains a fallback. We receive delivery information (delivered, bounced, complaint) so that we stop mailing addresses that do not accept mail and can tell you when a document did not arrive.
• A document you send to a recipient goes out in your name (“your name via Justivo”) without a note of ours in the text; the marking that it was drafted with the help of AI stays in the e-mail’s machine-readable headers.