DraftEngine™ Privacy Policy
Effective Date: May 12, 2026
Last Updated: May 12, 2026
This privacy statement ("Statement"), read in conjunction with the Terms of Service, applies to the Gemini Legal Support, Inc. product DraftEngine™ which operates this website (the "Company" "we," or "us" and the "Website"). The security and privacy of information is very important to us. This site is a general audience site that is neither designed nor intended to collect personal information from children and/or minors. Further, no information from any user of the services provided by DraftEngine™ (“Service”) will be sold to third parties. By using our website and Service, and by agreeing to this Statement, you understand and acknowledge we might collect and use some of your Personal Data as described in this Statement. This Privacy Policy forms part of our Terms and Conditions and/or License Agreement. It is important to note this statement applies to the Personal Data which might be collected and processed in the website and Service as part of our daily business conduct. Any inquiry or complaint regarding the data collected and managed by the Company’s customers while using Company’s products should be addressed to the relevant customer which is the data controller with respect to such data.
Who We Are And How You Can Contact Us
Gemini Legal Services, Inc.
250 Technology Way, Rocklin, CA 95765
Phone: 877.739.7481
Client Support Email: clientsupport@gemini.legal
Security Email: security@gemini.legal
While you are visiting our website and using the Service we might collect some information about your use in our website and Service for our purposes, as set forth by this Privacy Statement. Questions, comments, requests, and complaints regarding this Statement and the information we hold are welcome and should be addressed to us by using the contact details above. All requests will be dealt with promptly and efficiently.
Information we may collect from you:
"Personal Data", or personal information, means any information about an individual from which that person can be identified.
We collect Personal Data from you voluntarily when you provide such Personal Data to us, or via our Services and website with which you voluntarily interact. We may also obtain such Personal Data about you as may be provided to us in the course of our legitimate business activities. You do not have to provide us with your information, but in some cases, if you do not, it may mean that you will not be able to use our Service. For example, we may be unable to complete a requested "contact form" inquiry, unless you provide us with your contact details.
When you use our website and choose voluntarily to provide us with your information, we might collect and process the following information:
Identity Data - including full name, username, or any similar identifier, title, date of birth and gender, and any other information provided by you upon your sole discretion.
Contact Data - including email address and telephone numbers.
Usage Data - includes information about how you use our website and Service.
Technical Data - includes internet protocol (IP) address, the device you are using, browser type and version, screen resolution, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website and Service.
Marketing and Communications Data - includes your preferences in receiving marketing from us and our third parties, as well as your communication preferences.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but does not reveal your identity.
Our Two Roles: When We Act as a "Business" vs. a "Service Provider"
DraftEngine is a B2B platform used by law firms and legal professionals ("Customers") to discover, complete, and manage California court forms. We handle Personal Information in two (2) distinct capacities, and your rights depend on which one applies.
When we act as a "Business" (or "Controller"). When you visit our website, request a demo, sign up for an account, or contact our support team, we determine why and how your Personal Information is processed. In those interactions, we are the "Business" under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), and the "Controller" under comparable laws (see below for additional information regarding the CCPA).
When we act as a "Service Provider" (or "Processor"). When our Customers use DraftEngine to manage their legal matters, they upload, integrate, or generate information about themselves, their personnel, their clients, opposing parties, witnesses, and other individuals involved in legal matters ("Customer Data"). For Customer Data, our Customer is the "Business" under the CCPA and the "Controller" under comparable laws. We act solely as their "Service Provider" or "Processor," and our handling of Customer Data is governed by our written agreement with the Customer, including our Data Processing Addendum ("DPA").
The restrictions above apply to Customer Data - the substantive content of legal matters, forms, and individuals' information. They do not apply to aggregated, de-identified usage and telemetry data about how the DraftEngine service is used (such as which features are accessed, how long workflows take, or which form templates are most common). We use that operational data to improve the service, including through machine learning models that analyze user behavior patterns.
If you are an individual whose information appears in Customer Data - then, you are a client of a law firm using DraftEngine, or your information appears on a court form prepared through our platform. Please direct any privacy requests (access, deletion, correction, etc.) to the law firm or Customer that controls that data. We are contractually permitted to process Customer Data only on our Customer's instructions, and responding directly to you could interfere with the attorney-client relationship between you and our Customer. We will support our Customers in responding to such requests as required by applicable law and our DPA.
How Your Personal Data Is Collected
We use different methods to collect data from and about you. This includes:
Direct Interactions - you may give us your identity, contact and other Personal Data by filling in forms (e.g. "Contact Us") or by corresponding with us by phone, email, or otherwise.
Automated Technologies or Interactions - as you interact with our website, we may automatically collect Personal Data (please refer to the description below, under "Cookies Usage").
Third Parties or Publicly Available Sources - we may receive Personal Data about you from various third parties and public sources (e.g.: advertising and social networks, analytics providers, search information providers).
Cookies Usage
Like many other websites, our website and Service uses cookies for proper work, and to improve your experience while you navigate through the website and utilize the Service. Some of those cookies are necessary and stored on your browser as they are essential for the working of basic functionalities. Additionally, we also use third-party cookies that help us analyze and understand how you use this website and Service.
We may use various types of cookies, such as:
Essential Cookies – which are necessary for the site to work properly.
Functional Cookies – designated to save your settings on the site, your language preference, or other view preferences.
Session Cookies – used to support the functionality of the website; such Cookies are stored only temporarily during a browsing session and are deleted from your device when you close the browser.
Targeting Cookies - these cookies are used to collect information from you to help us to improve our products and Service as well as serve you with targeted advertisements that we believe will be relevant to you (e.g. Google’s cookies, Facebook’s pixels, Linkedin, etc.).
Social Networks Cookies - social plug-in cookies (e.g. Facebook and/or LinkedIn pixels etc.) enabling sharing of information with your social networks accounts to be smooth and seamless.
Analytics Cookies - give us aggregated information that enables us to improve the way our website works, e.g. Google analytics.
Third-Party Services Used By Us – for example, an external service supporting our career and recruiting options through the website, or an external service that allows us to screen short videos on our website (e.g. Vimeo or Youtube).
Please note the data collected by use of cookies may be linked to and combined with any other data, including Personal Data.
The Purposes of the Processing
We might use your data in order to:
Enable you to use our website and Service in the most effective way, including the personalization of your experience by presenting content tailored to your interests; to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory body;
Assess or evaluate the effectiveness of our services, as well as any technical and organizational measures designated for the protection of your Personal Data;
Improve and secure our services and systems; or
Protect our rights and legitimate interests, as well as defend against any lawsuit, legal claim or complaint; to conduct any other activities that are required to provide our services.
The Legal Basis for the Processing of Your Personal Data
We will only process and use your Personal Data when we have your permission or when the law allows us to, i.e. when we have a lawful basis for such usage. Such lawful and legal basis examples can be any of the following:
Processing actions which are related to your reservations and/or requests, to carry out our obligations arising from any contracts entered between you and us. For example, contacting you per "Contact" form filled by you;
Our use of your information is necessary to meet responsibilities we have to our regulators, tax officials, law enforcement, or otherwise meet our legal responsibilities; or
Our use of your information is in our legitimate interest as a commercial organization. For example, to operate and improve our services and to keep people informed about our products and services. In these cases, we will look after your information at all times in a way that is proportionate and respects your privacy rights, making sure our legitimate interest is not overridden by your interests or fundamental rights and freedoms.
In general, and as detailed above, we do not solely rely on consent as a legal basis for processing your Personal Data. Yet, in any case, in which you have provided your consent to our processing of your information, you can withdraw this consent at any time by contacting us through the contact details provided above.
Data recipients
We may disclose your Personal Data to third parties in a variety of circumstances in the ordinary course of operating our business, such as:
Disclosure of Personal Data to persons authorized to process personal data, in our organization, or third-party service providers, qualified as data processors, providing us with services supporting our website, Service, and ordinary course of business, e.g. system, storage and computing services, as well as marketing efforts, in accordance with applicable law; or
When we have a legal obligation to do so, or when we are allowed to do so under our legitimate interests.
In any such communication we will take steps to make sure such transfer is carefully managed to protect your privacy rights, such as:
Transfers within our group and affiliates will be subject to an agreement/policies and procedures made to ensure that your data receives an adequate and consistent level of protection as required by applicable law; or
Transfers to any subcontractor or processor will be subject to contractual terms ensuring the security and protection of any Personal Data under any such sub-processor, in accordance with applicable law provisions.
Any requests for information we receive from law enforcement or regulators will be carefully validated before the disclosure of any Personal Data. Further, by agreeing with this Statement, the aforementioned Terms of Service, and with your continued use of our Service, you agree to allow us to enter your Personal Data into our marketing database for future marketing communications. You may, however, opt-out of these communications at any time.
Purpose of this mapping
The following tables map DraftEngine's data collection practices against the personal information categories enumerated in California Consumer Privacy Act §1798.140(v), as amended by CPRA and the 2026 California Privacy Protection Agency regulations. It satisfies the disclosure requirements of §1798.130(a)(5) and serves as the substantive content for the privacy policy section titled "Categories of Personal Information We Collect," as well as the body of the Notice at Collection.
Scope
This mapping covers only personal information for which DraftEngine acts as a Business (Controller) — information collected directly from website visitors, demo requesters, account administrators, and Authorized Users.
Main Category Disclosure Table
It does not cover Customer Data — the client information, party details, and matter contents that Customer law firms upload to the Service. For Customer Data, the law firm is the Business/Controller and DraftEngine is the Service Provider/Processor. That data is governed by the Data Processing Addendum (DPA), and data subjects whose information appears in Customer Data should direct their inquiries to the law firm.
Note: DraftEngine does not sell personal information for monetary or other valuable consideration, and does not "share" personal information for purposes of cross-context behavioral advertising as those terms are defined in CCPA §1798.140. The Sold/Shared column reflects this affirmative position for each category.
Sensitive Personal Information (CPRA addition, §1798.140(ae))
The 2026 regulations require SPI to be disclosed separately with its own Right to Limit Use treatment. Because DraftEngine uses SPI only for purposes permitted under §1798.121(a) and only as necessary to deliver the Service, the right to limit use of SPI is honored by default and no "Limit the Use of My Sensitive Personal Information" link is displayed. The privacy policy should affirmatively state this — silence on SPI is what triggered the Sephora enforcement action.
How We Secure Your Information
We are committed to protecting the security of your Personal Data. We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access and use. However, the collection, transmission, and storage of information can never be guaranteed to be completely secure. Yet, we take steps to ensure that appropriate security safeguards are in place to protect your information, and we will continue to revise our policies and implement additional security features.
Storage of Personal Data
We will only store your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We have defined data retention periods for any data item in our systems, ensuring the minimization of retention periods. In some circumstances we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may save and use this information indefinitely without further notice to you.
Data Subjects' Rights Under the CCPA
Under the California Consumer Privacy Act (“CCPA”), California residents have rights that might include:
Right to Access Your Personal Data - you can ask us to confirm whether or not we have and use your Personal Data, and if so, you can ask for a copy of your data;
Right to Correct Your Personal Data - you can ask us to correct any of your Personal Data which is incorrect, after verifying the accuracy of the data first;
Right to Erase Your Personal Data - you can ask us to erase your Personal Data if you think we no longer need to use it for the purpose we collected it from you. You can also ask for such erasure in any case in which the process of your data was based on your consent, or where we have used it unlawfully or where we are subject to a legal obligation to erase your Personal Data. Any request for such erasure will be subject to our obligations under the law (e.g. our obligation to keep some records for tax or customs purposes);
Right to Restrict Our Use in Your Personal Data - you can ask us to restrict our use of your Personal Data in certain circumstances; and
Right to Object to How we Use Your Personal Data - you can object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest in using the information.
You can always require us to refrain from using your data for direct marketing purposes. You have the right to lodge a complaint at any time before the relevant supervisory authority for data protection issues. However, we will appreciate the chance to deal with your concerns before you approach the authorities, so please feel free to contact us in the first instance. We may not always be able to do what you have asked.
Special Notification for California Residents
We do not sell or share your personal information for the intentions and purposes of the CCPA. We can use your personal data for our purposes, but only as described above or after the de-identification or anonymization of such data, including aggregate data which can no longer be associated with you.
Links to Other Sites
Our website and Service may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Changes to This Privacy Statement
We reserve the right to change this statement from time to time at our sole discretion. If we make any changes, we will post those changes here so you can see what information we gather, how we might use that information and in what circumstances we may disclose it. By continuing to use our site or Service or otherwise provide data after we post any such changes, you accept and agree to this statement as modified.
