Privacy Policy — ERa analytics

Version: 2.3
Effective date: 05/03/2026
Last updated: 10/26/2026
Platform: ERa analytics
Domain: https://era-analytics.app
Controller: Artifizio Technology LLC — Wyoming, USA
Controller contact: soporte@era-analytics.app
Lee esta Política en español

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1. Identity of the Controller

The controller of the personal data collected through the Platform is Artifizio Technology LLC, a Limited Liability Company organized on August 17, 2026 under the laws of the State of Wyoming, United States of America, registered with the Wyoming Secretary of State under registration number 2026-002058211, with its address at 30 N Gould St, Ste R, Sheridan, WY 82801, United States of America (hereinafter, "ERa", "we" or "the Platform"). Artifizio Technology LLC operates the Platform under the trade name "ERa analytics".

• Address: 30 N Gould St, Ste R, Sheridan, WY 82801, United States of America
• Contact email: soporte@era-analytics.app
• Website: https://era-analytics.app
• Data Protection Officer (DPO): enquiries concerning the processing of personal data may be sent to the email address above, with the subject "Privacy" or "Personal Data".

2. Applicable Legal Framework

This Policy is governed by:

• Constitution of the Bolivarian Republic of Venezuela, in particular Articles 28 (right of access to personal data) and 60 (right to honour, personal privacy, own image, confidentiality and reputation).
• Special Law against Computer Crimes (Ley Especial contra los Delitos Informáticos, Official Gazette No. 37,313 of October 30, 2001).
• Decree-Law on Data Messages and Electronic Signatures (Decreto-Ley sobre Mensajes de Datos y Firmas Electrónicas, Official Gazette No. 37,148).
• Code of Professional Ethics of the Venezuelan Lawyer (Código de Ética Profesional del Abogado Venezolano), in particular Article 25 on professional secrecy.
• Organic Law for the Protection of Children and Adolescents (LOPNNA), regarding the processing of data relating to minors in court proceedings.
• On a supplementary basis and as an accepted international standard, the principles of the European Union General Data Protection Regulation (GDPR / EU 2016/679) and the California Consumer Privacy Act (CCPA / CPRA), insofar as applicable to users in those jurisdictions.

3. Definitions

• Personal data: any information that identifies or makes it possible to identify a natural person.
• Processing: any operation performed on personal data (collection, storage, use, transmission, erasure).
• Data subject: the natural person to whom the personal data belong.
• Controller: whoever determines the purposes and means of the processing (with regard to the user's account data, ERa).
• Processor: whoever processes data on behalf of the controller (the sub-processors listed in § 7).
• Platform: the ERa analytics web application, accessible at https://era-analytics.app, and all its associated services, including its Android and iOS applications. Both display that same web application within the device and add two things to it: installation as an application and receipt of push notifications. Apart from the device identifier that such notifications require (§ 5.8), they collect no other data from the phone —no contacts, no location, no camera, no advertising identifiers—, and everything described in this Policy applies to them equally.
• User: the person who creates an account and uses the Platform, typically a practising legal professional. The Platform does not verify that status nor require it to access any of its features.
• Client user: the person who accesses the Client Portal with a client-type account, created at a User's invitation, whose access is limited to the information on the cases that User shares with them (§ 5.7).
• User's client: the natural or legal person recorded by the user on the Platform as their client, party to proceedings, shareholder, legal representative or contact.

4. Dual Role: the Lawyer User as Controller

The Platform operates under a dual-role model for the processing of personal data that is important to understand:

• With regard to the user's account data (name, email, password, preferences, team settings): ERa is the controller.
• With regard to the data of clients, parties to proceedings and other third parties that the user uploads to the Platform: the lawyer user is the controller of those data vis-à-vis their data subjects, and ERa acts as processor on the user's behalf. This means that:
  • The user must have the appropriate legal basis (professional mandate, consent, legitimate interest of the litigation, legal obligation) to add third-party data to the Platform.
  • The user is responsible towards their clients and towards the parties to proceedings for informing them of the processing the user carries out, including the use of ERa as a management tool.
  • ERa undertakes to process those data exclusively in accordance with the user's instructions, for the purposes described in this Policy and with the security measures set out in § 12.

The same applies to the Client Portal: the lawyer user decides whom to invite, which cases to share with them and when to revoke that access, and remains the controller vis-à-vis that person. ERa merely operates the portal.

This model is analogous to that of any professional legal management software: the lawyer retains the status of responsible professional towards their client, and the Platform acts as technical infrastructure serving professional practice.

5. Categories of Personal Data We Process

5.1. User account data

• Name, email address and username.
• Cryptographic hash of the password (the plain-text password is never stored; its management is delegated to Supabase Auth).
• Email verification status, date of acceptance of the terms and conditions, notification preferences.
• Professional role, advance notice days, language and internal technical identifiers.
• Inpreabogado number, when the user declares it. It is an optional, self-reported field: it is not checked against the INPREABOGADO register or any other source, and does not condition access to any feature. It is used to sign the reports the user sends to their client and to identify the user in the Client Portal.
• If the user signs in with an external identity provider (Google or Apple), the basic identification data that provider supplies: name, email address and, where applicable, profile picture. In the case of Apple, the email may be a private relay address generated by the provider itself, and the Platform works with it without knowing the real address.
• Apple revocation credential: when the user signs in with "Sign in with Apple", the Platform stores, encrypted, the refresh credential (refresh token) that Apple supplies only once. It gives no access to any user data or to the Platform: its sole purpose is to be able to ask Apple to revoke the link when the user deletes their account, as Apple requires. It is destroyed in that same act.

5.2. Case data

• Case file number, type of proceeding and procedural status.
• Identification of the claimant and the defendant or of the parties (full name, identity card number, RIF tax ID where applicable).
• Assigned court, jurisdiction and judicial district.
• Procedural milestones, dates, time limits, court decisions and associated notes.

5.3. Client portfolio

• For natural persons: name, identity card number, telephone, email, address.
• For legal persons: corporate name, RIF tax ID, share capital, commercial registry data, shareholders and legal representatives (name, identity card number and percentage of ownership).
• Documents uploaded by the user: contracts, powers of attorney, commercial registrations, RIF, identification documents and other documents relevant to professional practice.
• Proposals for professional services (description, fees, expenses).

5.4. Digitized case files

• Images and PDF files of case file documents uploaded by the user.
• Text extracted through OCR and structured analysis generated by artificial intelligence (summary, facts, arguments, premises).

5.5. Firm administration data

• Income and collections the user records, with their description, date, currency and the case or client to which they are linked.
• Reimbursable expenses and operating expenses of the firm, with their supporting document when the user uploads it.
• Profitability indicators the Platform derives from the above, and the reference exchange rate applied to show equivalents.
• Status of proposals for professional services and of their payments.

These data are the user's own internal management record. The Platform does not process the collections the user records in this module, nor does it connect to banks, payment gateways or collection systems to obtain them: it does not receive, hold or intermediate funds, and therefore does not process card or bank account data. Currency equivalents are merely indicative (§ 15 bis of the Terms).

5.6. Team and collaboration data

• Identity of the team members (director, collaborators), permissions granted, status of invitations.
• Traceability of collaborative actions: who marked a milestone, who edited a court business day, who shared a case or a client.

5.7. Client Portal data

• Client user account data: name, email address, password hash and invitation status.
• Link between that account and the cases their lawyer shares with them, and access timestamps.

The client-type account arises from a user's express invitation, and its scope is decided and revoked by that user, who remains the controller vis-à-vis their client on the terms of § 4.

5.8. Device data for push notifications

• Device notification identifier: an opaque string supplied by the operating system (the APNs token on iOS and its equivalent on Android) that serves exclusively to direct a notification to that installation of the application. It does not reveal the phone number, location, model or any other data about the device.
• The device platform (iOS or Android) and the dates of registration and last activity of the token.
• The user's preference as to whether they wish to receive push notifications and how many days in advance.

The identifier designates the installation, not the person: if another account signs in on the same phone, the identifier is reassigned to it instead of being duplicated, precisely so that a notification never reaches the wrong user. It is deleted on sign-out, when notifications are deactivated, when the account is deleted or when the notification service itself declares it expired.

5.9. Technical data, activity logs and observability

• IP address, user agent and timestamps, recorded temporarily for rate limiting and abuse prevention.
• Session tokens (JWT) and refresh tokens, kept in the user's browser or device; in the web application, the refresh token is kept in a first-party HttpOnly cookie (§ 11).
• Visual theme and language preferences kept in the browser's local storage.
• Operational records (logs) and invocation traces: for each technical request the Platform receives (whether initiated by the user or by internal scheduled tasks), ERa records through its Hosting Provider (Cloudflare Inc., in the Workers Observability tool) metadata such as the HTTP method, the resource path, the status code, the response duration, the internal identifiers of sub-calls to the database, to the artificial intelligence models and to the email provider, and the messages the application itself issues for diagnostic purposes (warnings, errors, progress markers of scheduled tasks).
• Sampling and minimization policy: in order to minimize the amount of data retained, the complete set of logs and traces is persisted only for a 10% sample of invocations; the remaining 90% is not stored beyond the request's own cycle. Before passing any data to the observability system, the Platform applies automatic filters that redact email addresses embedded in messages, omit complete request bodies and omit tokens, passwords, OCR content and data of the user's clients.
• Express purpose of the records: diagnosing errors, identifying anomalous behaviour, monitoring the technical health of the service, optimizing performance and continuously improving the Platform. These records are NOT marketed, NOT assigned to third parties for advertising purposes, NOT used for individual user profiling, and NOT made available to analytics or advertising services other than Cloudflare as technical hosting provider.

5.10. Communication data

• Messages sent by email from the Platform (deadline notifications, client summaries, account verification, password recovery).
• Delivery and bounce markers (NDR) processed by the Platform to avoid retries to non-existent mailboxes.

5.11. Subscription and credit consumption data

• Plan purchased (Pro, Max or Ultra), subscription status, start and end dates of each period, whether it renews automatically and, where applicable, the grace period for a pending charge.
• The identifiers the store supplies to verify the purchase: at Apple, the original transaction identifier and the transaction signed by Apple; at Google Play, the purchase token and the order number. With them ERa queries the store about the status of the subscription. When the subscription is purchased on the website, those supplied by Stripe: the customer's, the subscription's, each invoice's and the purchased price's.
• A random account identifier (account token) that the application gives the store at the time of purchase, so that the purchase and the store's subsequent notices are associated with the correct account. It neither contains nor reveals any user data.
• The credit consumption of each period and of the free trial, calculated from the computing cost of each artificial intelligence operation.
• An irreversible fingerprint of the email address (a code calculated from the email with a secret key, from which the address cannot be recovered) and the free-trial credits consumed with it. It serves to prevent the trial from being repeated by deleting the account and registering again (§ 9).
• ERa neither receives nor stores card data or other means of payment: the charge is made by Apple or Google on their own platforms or, when the User purchases on the website, by Stripe on its own payment page, in accordance with their respective terms.

5 bis. Personal Data Contained in Public Documents

This section governs processing that is different from the rest of the Policy: it does not refer to the data the User entrusts to us, but to third parties' personal data that already appear in public documents and that the Platform displays through its case law search engine.

5 bis.1. What data these are. The court decisions published by the Supreme Tribunal of Justice and the judicial circuits, as well as the acts published in the Official Gazette, by their very nature contain data identifying persons. Specifically, the Platform may display:

• Names of parties (natural and legal persons) as they appear in the decision.
• Names of legal representatives and, where the text records it, their Inpreabogado number.
• Names of judges, justices and reporting judges, in their capacity as public officials acting in the exercise of their functions.
• Names of officials appointed or removed, where so recorded in the Official Gazette.
• Aggregate statistical indicators built from those mentions (number of cases, results obtained, bodies before which they acted).

5 bis.2. Origin and legal basis. These data are not collected from the data subject or from private sources: they come exclusively from documents already published by the Public Power in exercise of the principle of publicity of state acts and court decisions. The legal basis for the processing is the legitimate interest in facilitating legal research and structured access to information that the law requires to be published, together with the fact that the information is lawfully in the public domain by decision of the issuing body itself.

5 bis.3. Limits we impose on ourselves. With respect to these data, ERa undertakes:

• Not to enrich them with data from sources other than the original public document.
• Not to cross-reference them with private databases, credit registers, social networks or contact information.
• Not to build profiles for commercial, advertising, market segmentation, credit, employment, insurance or solvency assessment purposes.
• Not to sell, assign or license them to third parties, either as a database or as a service.
• Not to disseminate them massively: they are displayed only in response to an individual, authenticated query by a User, never openly, proactively or in a way indexable by public search engines.
• Not to issue value judgements about the persons mentioned. The indicators are verifiable counts over the subset of decisions incorporated, not ratings.

5 bis.3 bis. How the Corpus is structured. The conversion of public documents into searchable data (identifying the chamber, the date, the reporting judge, the parties, the operative part or the articles of a rule) is carried out with third-party language models, which as of the date of this Policy are those of Google LLC, Anthropic PBC and DeepSeek. Those providers receive only the text of documents already published by the Public Power, which includes the third-party data described in § 5 bis.1. Under no circumstances is User Content transmitted to them: no cases, no case files, no client portfolio data. That processing takes place outside Venezuela, mainly in the United States and, in the case of DeepSeek, in the People's Republic of China.

5 bis.4. Scope of the indicators. The percentages and counts the Platform shows are calculated over the subset of decisions actually incorporated and analysed, which is partial and under construction. Consequently, they do not reflect the complete track record of any person, nor do they allow any conclusion about their competence, diligence or integrity. The User undertakes not to present them as such.

5 bis.4 bis. How the indicators are built. The profiles of lawyers, parties, judges and justices aggregate what the published decisions in which that person appears say: how many there are, in which subject matters and chambers, on which dates and, where the decision makes it possible to determine, the outcome for the side they represented or the criterion they applied. Those data are extracted automatically, with language models (§ 5 bis.3 bis), and the quality of the extraction is measured periodically against reviewed samples, with verification of the citations. The variables that carry weight are the subject matter, the type of decision and its outcome; no data other than the decisions themselves are used. Their limits: the Corpus is partial (§ 5 bis.4), automatic extraction may be wrong in a specific case, and the same name may correspond to different persons. The indicators do not produce automated decisions about anyone: they are research material that the User must check against the original decisions, to which each profile links.

5 bis.5. User obligations. The User who consults this information undertakes to use it solely for legal research purposes within the scope of their professional practice. It is prohibited to use it to harass, discredit, discriminate against or pressure any person, to build lists or databases of third parties, or for any purpose unrelated to the study of law and the preparation of professional actions. The User is personally liable towards third parties for the use they make of the information obtained.

5 bis.6. Rights of the persons mentioned. Any person whose data appear in a document displayed by the Platform may write to soporte@era-analytics.app to request access, rectification of transcription errors or the removal of their mention from our display. We will handle the request on the terms of § 13 of this Policy, but within a maximum of fifteen (15) business days without extension, and with two necessary clarifications:

• Removal takes effect on our display, not on the original document: the latter will remain public on the portal of the body that issued it, over which ERa has no authority whatsoever.
• Rectification of the content of a court decision may only be requested from the body that issued it, through the appropriate procedural means. ERa can only correct errors introduced in the digitization or structuring process.

5 bis.7. Retention. Public-source documents are kept for as long as the Platform provides the search service, as they reflect information permanently published by their issuer. A removal granted under § 5 bis.6 is final with respect to our display.

6. Purposes and Legal Basis of the Processing

We process personal data for the following purposes, on the legal bases indicated:

ERa does not carry out automated profiling with legal effects on data subjects, does not sell, rent or assign personal data or operational records to third parties for commercial or advertising purposes, and does not use User Content or its Users' data to train its own or third-party artificial intelligence models. Data and records are used exclusively to provide the contracted service and for the technical purposes described in this Policy. The public documents of the Corpus are transmitted to the providers in § 5 bis.3 bis for the sole purpose of structuring them; what each provider does with them is governed by its own terms (§ 7 and § 8). In particular, DeepSeek's terms allow it to use the content it receives, after de-identification, to develop and improve its services: that is why DeepSeek is only sent documents that the Public Power has already published.

7. Processors (Sub-processors)

To operate the Platform, ERa relies on carefully selected technology providers, all of them subject to contractual confidentiality and security obligations. The current list of sub-processors is as follows:

ERa keeps this list up to date and will notify users of any substantial change in the sub-processors.

8. International Transfers

The sub-processors in § 7 are established outside Venezuela. Personal data may be transferred to, stored and processed in other jurisdictions, namely:

• United States of America (and Singapore, for part of the database infrastructure): all User Content and the user's account data are processed here.
• People's Republic of China: only the public documents of the Corpus that are sent to DeepSeek for structuring (§ 5 bis.3 bis). No Users' data or User Content is transferred to China.

The Constitutional Chamber of the Supreme Tribunal of Justice established, with binding effect, that international transfers of data shall not proceed to the territory of States whose legislation does not guarantee a minimum of personal data protection, having regard to the nature of the data, the applicable legal system and the consent of the person concerned (judgment No. 1318 of August 4, 2011). In accordance with that criterion, ERa's transfers rely on:

• The nature of the data: only documents already published by the Public Power are sent to the People's Republic of China, never Users' data or User Content. That country has a general personal information protection law, which governs DeepSeek's processing. There is no signed data processing agreement with DeepSeek.
• Each provider's terms of service and, where the provider offers them, its data processing agreements and confidentiality commitments.
• The providers' information security certifications (ISO 27001, SOC 2) and, where applicable, adequacy frameworks such as the EU-U.S. Data Privacy Framework.
• Minimization: each provider is sent only what is necessary for its function, in accordance with the table in § 7.
• The user's informed consent, given upon accepting this Policy and the Terms and Conditions.

The user acknowledges that certain artificial intelligence services (the Gemini models on Vertex AI) necessarily require the case file documents to be sent to third-party servers for processing, and that using the mobile applications with push notifications involves transmitting the device identifier to its manufacturer's notification service. Activating both features is voluntary and the user may refrain from using them.

9. Retention Periods

• Account and case data: for the entire life of the account. Once deletion is requested, the data are erased from the active databases within a maximum of ninety (90) days, unless retention is required by law or necessary to resolve disputes or claims.
• Uploaded documents and files: the same period as for case data. The user may delete individual documents at any time from the Platform.
• Rate-limiting records (rate_limits): one (1) hour for API actions; twenty-four (24) hours for authentication actions.
• Email bounce markers (email_suppressed): indefinite, for the sole purpose of avoiding retries to non-existent mailboxes and protecting the sender's reputation.
• Authentication tokens: the technical lifetime of the access token (1 hour) and of the refresh token (configurable by Supabase Auth). In the web application, the cookie that keeps the refresh token expires after thirty (30) days at the latest.
• Device identifiers for push notifications: for as long as the application remains installed with the session open and notifications activated. They are deleted on sign-out, when notifications are deactivated, when the account is deleted or when the manufacturer's notification service declares the identifier expired.
• Apple revocation credential: for as long as the "Sign in with Apple" link exists. It is used and destroyed in the very act of deleting the account.
• Subscription and credit consumption data (§ 5.11): for the entire life of the account; they are deleted with it, except for the irreversible email fingerprint and the trial credits consumed with it, which are kept after deletion for the sole purpose of preventing the free trial from being repeated. Neither the email nor any other account data can be recovered from that fingerprint. The store (Apple or Google) keeps its own purchase records in accordance with its terms, over which ERa has no control. Stripe does the same with subscriptions purchased on the website.
• Firm administration records: for the entire life of the account, with the same deletion period as case data. The user may delete each record at any time from the Platform.
• Technical logs and traces in Cloudflare Workers Observability: the complete set is persisted for a 10% sample of invocations; the remaining 90% is not stored beyond the request cycle. Effective retention at Cloudflare is that provided for in the Platform's plan with the Provider (as of the date of this Policy, up to 7 days). ERa does not keep additional copies of those records outside Cloudflare.
• Backups: Supabase's operational backups may keep deleted data for a maximum of thirty (30) days for service continuity reasons. After that period they are overwritten.

10. Sensitive Data, Minors and Professional Secrecy

10.1. Data of minors (LOPNNA)

The Platform supports divorce and separation proceedings involving minors under the LOPNNA regime. The lawyer user undertakes not to include direct identifying data of children or adolescents in fields that are not strictly necessary for managing the case, and to respect the publicity prohibitions established in the special legislation. Where references to minors must be included, the user should use reserved identifiers (initials, sequence number) instead of full names whenever possible.

10.2. Criminal proceedings data

Data relating to criminal proceedings (complaints, private prosecutions, precautionary measures, decisions of criminal courts) are processed only on the instructions of the lawyer user, in the context of professional practice and under the duty of confidentiality inherent in the adversarial criminal process (Arts. 16, 286 and 313 of the Organic Code of Criminal Procedure, COPP).

10.3. Professional secrecy

ERa acknowledges that the information uploaded by the lawyer user may be protected by the professional secrecy of the Code of Professional Ethics of the Venezuelan Lawyer. Accordingly:

• Access to the data is restricted to the user and, where applicable, to the team members to whom the user has expressly granted permissions.
• ERa's technical staff do not access user content except where there is an explicit and consented operational need (for example, technical support requested by the user).
• The artificial intelligence tools process the data transiently. Case files are processed on Vertex AI, whose terms of service establish that Google does not use the content submitted to train or improve its models.
• The search engine assistant operates on the Corpus of public documents and does not receive case files, cases or portfolio data of the user, except what the user writes in their question; the user is therefore advised not to include identifying data of their clients in it.

11. Cookies and Local Storage

ERa does not use tracking, advertising or analytics cookies, nor any third-party trackers. What the Platform stores in the browser or on the device serves exclusively technical purposes:

• Session: the authentication tokens, to keep the session open until it expires. In the web application, the access token is kept in the tab's sessionStorage, and the refresh token in a single first-party cookie, era_rt: HttpOnly (no code on the page can read it), Secure, SameSite=Strict, restricted to the Platform's authentication routes and lasting thirty (30) days at most. On the mobile applications, both tokens are kept in the application's storage.
• Preferences: light or dark theme, preferred judicial district and other display options (localStorage).
• Local copy for search: the lists of saved and recent documents and a copy of their text (localStorage and IndexedDB), tied to the account, so they can be read when the network fails.

Cloudflare, as hosting provider, may set strictly necessary security cookies (bot control) that do not track the user individually. Signing out deletes the tokens, the era_rt cookie and the local copy for search; clearing the site data from the browser has the same effect and also resets the preferences. The details of each item, its duration and how to delete it are set out in the Cookie Policy.

12. Security Measures

ERa applies reasonable technical and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration or improper disclosure. Among others:

• Encryption in transit: all communications with the Platform take place over TLS 1.3.
• Encryption at rest: the PostgreSQL database at Supabase and the file storage are encrypted on disk.
• Strong authentication: signed JWT tokens, automatic refresh and, optionally, OAuth with external providers.
• Isolation by user and by team: row-level security (RLS) policies in the database that prevent cross-access between users and between unrelated teams.
• File validation: verification of the MIME type and magic bytes before accepting an uploaded file.
• Rate limiting: limits per IP and per user to prevent abuse.
• Encryption of third-party credentials: the revocation credential Apple supplies is stored encrypted and is neither readable from the application nor recoverable through its interface.
• Prompt sanitization: defensive filtering of the texts sent to artificial intelligence models.
• Security headers: a restrictive content security policy (CSP), with no uncontrolled inline scripts or eval.
• Continuous auditing: periodic security reviews and detailed logging of collaborative actions (shared court business days, milestones marked by team members).
• Sanitization of records before persistence: before emitting any technical record to Workers Observability, the Platform applies automatic filters that redact email addresses (keeping only the first three characters of the local part and the domain), omit complete request bodies and exclude tokens, passwords, OCR content and identifying data of the user's clients.

Despite these measures, no computer system is absolutely impenetrable. The user acknowledges that there is a residual risk and undertakes to contribute to the security of the service by using strong passwords and taking care of their credentials.

13. Data Subject Rights

The data subject may exercise the following rights at any time:

• Access: to obtain confirmation of whether we process their data and, if so, a copy of them.
• Rectification: to request the correction of inaccurate or incomplete data.
• Cancellation / Erasure: to request the deletion of the data when they are no longer necessary or consent has been withdrawn.
• Objection: to object to the processing on grounds relating to the data subject's particular situation.
• Restriction: to request the suspension of the processing while a dispute about accuracy or lawfulness is resolved.
• Portability: to receive the data in a structured, commonly used format (JSON, CSV) and, where technically possible, to transmit them to another controller.
• Withdrawal of consent: where the processing is based on consent, to withdraw it at any time, without affecting the lawfulness of prior processing.
• Non-discrimination: not to be subjected to detrimental treatment merely for having exercised their rights.

To exercise any of these rights, the data subject must send a request to soporte@era-analytics.app with the subject "Data Subject Rights", providing valid identification and a specific description of the right being exercised. We will handle the request within a maximum of fifteen (15) business days, which may be extended, with justification, by a further fifteen (15).

Where the request concerns data of a client of the lawyer user, we will forward the request to the user responsible for those data and cooperate with them to handle it.

14. Account Deletion

The user may delete their account at any time from the "My Profile" section of the Platform, or request it by email following the instructions on this page if they have lost access. Deletion entails:

• Deletion of the cases, milestones, case files, portfolio clients, proposals and documents associated with the account, except those shared with teams where other users retain joint responsibility.
• Cancellation of pending invitations and withdrawal from the teams to which the user belongs.
• Deletion of the stored files, including digitized case files and portfolio documents.
• Deletion of the firm administration records (income, expenses and proposals) associated with the account.
• Deletion of the device identifiers registered for push notifications, with the consequent immediate cessation of those notifications.
• Where the account was created with "Sign in with Apple", revocation of the link with Apple and destruction of the credential kept for that purpose.
• Sending of an email confirming the closure of the account.

Some data may be kept for a limited period due to legal, accounting or evidentiary requirements, duly justified and documented internally.

15. Notification of Security Incidents

If a security incident is detected that may compromise personal data, ERa will:

• Investigate the scope of the incident and apply the appropriate containment measures.
• Notify the affected users without undue delay and, as far as reasonably possible, within seventy-two (72) hours of becoming aware of it, indicating the nature of the incident, the categories of data involved and the measures adopted.
• Cooperate with the competent authorities where required by applicable law.

16. Artificial Intelligence

When the user activates features based on artificial intelligence (segmentation of case files, OCR, generation of client summaries, case analysis, and data extraction and drafting in "My documents"), the corresponding texts and files are transmitted to the AI provider exclusively for the purpose of obtaining the requested result. That processing is carried out with Gemini models on Vertex AI, in a Google Cloud project owned by Artifizio Technology LLC.

• The data sent are processed transiently and, under the Vertex AI terms of service, are not used to train or improve the provider's models.
• A long case file is processed split by pages, in successive calls; each call transmits only the portion that corresponds to it.
• ERa applies an additional layer of prompt sanitization to mitigate the risk of instruction injection.
• The user is free not to use the AI features and to delete case files already analysed at any time.
• AI results are for guidance only and non-binding; the user is solely responsible for validating the legal relevance of any output.

AI-powered search engine. The search section includes an assistant that answers natural-language questions about the corpus of public sources. When it is used, the question the User writes and the fragments of public documents the assistant needs to consult are transmitted to the model provider —Google LLC or Anthropic PBC, depending on which one ERa has selected at that time— to prepare the answer. No User Content is transmitted —cases, case files, client data or calendar— unless the User writes it in the question, so the User is advised not to include identifying data of their clients in it.

The artificial intelligence features consume credits from the User's free trial or plan, according to the computing cost of each operation (Terms and Conditions, § 4). For that purpose, the User's internal identifier, the period and the accumulated consumption are recorded; the content of the questions is not kept associated with the User's identity beyond what is necessary to produce the answer.

The assistant's answers are automatic elaborations subject to error and do not constitute legal advice. Their use is also governed by § 9 bis of the Terms and Conditions.

17. Complaints and Supervisory Authority

If a data subject considers that the processing carried out by ERa breaches the applicable rules or that their rights have not been satisfactorily addressed, they may lodge a complaint:

• With the controller, at soporte@era-analytics.app.
• With the data protection supervisory authority of the territory where the data subject resides, where one exists. In the European Union, the National Data Protection Authorities. In jurisdictions where there is no specific authority, before the courts with jurisdiction over the matter.

18. Changes to the Policy

ERa may update this Policy to reflect legal, technical or operational changes. Substantial amendments will be notified to users with reasonable advance notice through the registered email address or through a notice on the Platform itself. The date of the last update will always appear at the beginning of the document. Continued use of the Platform after the changes take effect constitutes acceptance of the updated version.

19. Contact

For any enquiry, request or complaint relating to this Policy or to the processing of personal data, the official channel is:

• Email: soporte@era-analytics.app
• Suggested subject: "Privacy" or "Personal Data"
• Indicative response time: 15 business days

20. Language

This Policy is published in Spanish and in English. The English version is a translation provided for the user's convenience; in the event of any discrepancy, conflict or doubt of interpretation between the two, the Spanish version shall prevail.

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This Privacy Policy is interpreted and applied in accordance with the Terms and Conditions of Use. In the event of conflict, special provisions shall prevail over general ones and, on a supplementary basis, the applicable Venezuelan legislation.