Privacy Policy

Last Updated: February 19, 2026

Version: 2026-02-19

Dillingham Capital, LLC ("Company," "we," "us," or "our") operates the Contract Intelligence platform (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By accessing or using the Service, you agree to the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

1. Information We Collect

1.1 Account Information

When you create an account, we collect information that identifies you as an individual or relates to an identifiable individual, including:

• Name
• Email address
• Company name
• Password (stored in encrypted form; we never store or have access to your plaintext password)
• Billing information (processed securely via Stripe; we do not store full payment card numbers)

1.2 Customer Data

You may upload or otherwise provide content to the Service, including:

• Contracts and legal documents
• Business agreements
• Uploaded files (PDF, DOCX, and other supported formats)

You retain all rights in your Customer Data. We process Customer Data solely to provide and improve the Service as described in this Privacy Policy and our Terms of Service.

1.3 Usage Information

We automatically collect certain information when you access or use the Service, including:

• Log data (IP address, browser type, operating system, referring URLs, and access timestamps)
• Usage patterns (features accessed, pages viewed, actions taken within the Service)
• Performance and error data (crash reports, response times, and diagnostic information)

1.4 Cookies and Tracking

We use cookies and similar tracking technologies to operate and administer the Service. These include:

• Authentication cookies — to keep you signed in and verify your identity
• Preference cookies — to remember your settings and display preferences
• Analytics cookies — to understand how the Service is used so we can improve it

You can control cookies through your browser settings. Disabling certain cookies may limit your ability to use some features of the Service.

2. How We Use Information

We use the information we collect for the following purposes:

• (a) Provide the Service — To operate, maintain, and deliver the features and functionality of the Service, including AI-powered contract analysis, clause extraction, risk assessment, and benchmarking.
• (b) Improve the Service — To understand usage patterns and trends so we can enhance the Service, develop new features, and improve the accuracy and quality of our AI analysis.
• (c) Communicate — To send you service-related notifications, updates, security alerts, and support or administrative messages. We may also send you information about new features or services that may be of interest to you.
• (d) Billing — To process payments, manage subscriptions, send invoices, and handle billing-related inquiries.
• (e) Security — To detect, prevent, and address fraud, unauthorized access, and other illegal or harmful activity, and to protect the rights, property, and safety of our users and the public.
• (f) Legal Compliance — To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.

3. AI Processing and Third-Party Providers

3.1 AI Analysis

The Service uses artificial intelligence to analyze your contracts and documents. Our AI analysis is powered by Anthropic (Claude AI). When you upload a document for analysis, portions of the document text are sent to Anthropic's API for processing.

We use Anthropic's zero-retention API, which means that Anthropic does not store or retain your data after processing. Your contract content is not used to train Anthropic's models. For more information on how Anthropic handles data, please review Anthropic's Privacy Policy.

3.2 Other Service Providers

We engage the following third-party service providers to help us operate and deliver the Service:

Each service provider is contractually obligated to use your data only for the purposes of providing their services to us and in accordance with applicable data protection laws.

4. Data Storage and Security

4.1 Storage Location

Your data is stored on secure cloud infrastructure located in the United States. By using the Service, you consent to the storage and processing of your data in the United States.

4.2 Security Measures

We implement industry-standard security measures to protect your data, including:

• AES-256 encryption for data at rest
• TLS 1.2+ encryption for data in transit
• Role-based access controls and least-privilege principles
• Row Level Security (RLS) policies ensuring data isolation at the database level

While we strive to protect your data, no method of electronic transmission or storage is 100% secure. We cannot guarantee absolute security.

4.3 Data Isolation

We maintain strict per-customer data isolation. Your contracts, analysis results, and account data are logically separated from other customers' data. Row Level Security policies ensure that each user can only access their own organization's data.

5. Data Retention

5.1 Active Accounts

We retain your information for as long as your account is active or as needed to provide you with the Service. This includes your Account Information, Customer Data, and Usage Information.

5.2 Terminated Accounts

Upon account termination or cancellation, you will have a 30-day window to export your data. After this 30-day period, we will delete your Customer Data from our active systems. Certain Account Information may be retained as required by law or for legitimate business purposes (such as fraud prevention and record-keeping).

5.3 Backups

Deleted data may persist in encrypted backups for up to 90 days before being permanently removed. Backup data is not actively used and is maintained solely for disaster recovery purposes.

6. Data Sharing

We do not sell your personal information. We will never sell, rent, or trade your personal information or Customer Data to third parties for their marketing purposes.

We may share your information in the following circumstances:

• With Service Providers — We share information with the third-party service providers identified in Section 3, solely for the purposes of operating and delivering the Service.
• For Legal Reasons — We may disclose your information if required to do so by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers — In connection with a merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred as part of the transaction. We will notify you of any such change in ownership or control of your personal information.
• With Your Consent — We may share your information for any other purpose with your explicit consent.

7. Your Rights

7.1 Access and Portability

You have the right to access the personal information we hold about you. You may export your contracts and data at any time through the Service's built-in export functionality.

7.2 Correction

You have the right to request correction of inaccurate or incomplete personal information. You can update most account information directly through your account settings.

7.3 Deletion

You have the right to request deletion of your personal information. To request deletion of your account and associated data, please contact us at support@dillinghamcapital.com. Please note that we may retain certain information as required by law or for legitimate business purposes.

7.4 Opt-Out

You may opt out of receiving marketing communications from us at any time by clicking the "unsubscribe" link in any marketing email or by contacting us directly. Please note that you may still receive transactional or service-related communications (such as security alerts and billing notifications) even after opting out of marketing communications.

7.5 California Residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal information we collect, use, and disclose
• The right to request deletion of your personal information
• The right to opt out of the sale of your personal information (we do not sell personal information)
• The right to non-discrimination for exercising your privacy rights

To exercise your CCPA rights, please contact us at privacy@dillinghamcapital.com.

8. Children's Privacy

The Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly. If you believe we may have collected information from a child under 18, please contact us at privacy@dillinghamcapital.com.

9. International Users

The Service is operated from the United States. If you are accessing the Service from outside the United States, please be aware that your information will be transferred to, stored, and processed in the United States. By using the Service, you consent to the transfer and processing of your information in the United States, where data protection laws may differ from those in your jurisdiction.

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will notify you by updating the "Last Updated" date at the top of this page and, where appropriate, providing additional notice (such as an in-app notification or email). Your continued use of the Service after any changes to this Privacy Policy constitutes your acceptance of the updated policy.

11. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

© 2026 Dillingham Capital, LLC. All rights reserved.