Privacy Policy

1. Introduction

atorni AI is the Philippine AI Legal Assistant intended for legal professionals: lawyers, paralegals, law clerks, and law students. It is not directed to, or marketed to, the general public. It is operated by Karl Gabriel M. Anciro (the “operator,” “we,” “us”), a sole proprietor based at 2F Unit 3, 34 Matias St., Brgy. Paltok, Quezon City, Philippines 1105. This Privacy Policy explains what personal information we collect, how we use it, and the choices you have, in line with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, the “DPA”) and its Implementing Rules and Regulations.

This policy applies to:

• the public marketing site at atorni.ph;
• the chat application, where you create an account and authenticated users interact with the AI assistant; and
• the administration interface used internally to manage accounts.

This Privacy Policy forms part of, and should be read together with, our Terms of Use. By using any part of atorni AI, you confirm that you have read and understood this policy.

2. Information we collect

We collect only what we need to operate atorni AI.

Account information. When you create a chat account, we collect your full name, email address, and a password. Passwords are hashed before storage, so we never see or store your plain-text password. You may optionally upload a profile photo and set a display name, which are stored with your account and shown to you inside the app; you can replace or remove them at any time from your profile page. Authorized operator personnel may review photos and display names, and remove or reset any that violate the Terms of Use.

Notification settings and push subscriptions. atorni AI shows notices inside the app: plan reminders, changes to your plan, and announcements from the operator. On your profile page you choose whether reminders and announcements also reach you by email and, for each device you use, as push notifications. Turning push on asks your browser to create a push subscription with its push service (Google, Apple, or Mozilla, depending on the browser), and we store that subscription so we can deliver the notice to that device. A notice carries only its title and text, never chat content. You can turn either setting off at any time, and every reminder or announcement email carries a link that turns email notifications off. Emails about signing in, payments, invoices, and account security are sent regardless.

Professional details. When you create an account, we also collect your date of birth, your current role as a legal professional (for example, lawyer, paralegal, law clerk, or law student), the organization or firm you belong to (optional), your total years of experience as a legal professional, and your location (city). We use these details to verify that you are eligible for the service (atorni AI is limited to legal professionals aged eighteen (18) and over) and to review registrations. Your date of birth is used solely to verify your age and eligibility. If you previously requested access via the waitlist, we collected the same details at that stage.

Chat content. When you use the chat assistant, we store the messages you send, the AI’s responses, and the source citations returned by retrieval.

Feedback and screenshots. When you send feedback through the in-app feedback dialog, we store your message and any screenshots you choose to attach. The operator reviews them to fix problems and improve the service, and may write a reply that you can read in the application. A screenshot captures whatever was on your screen at the time, so please attach only images you are comfortable sharing, and remember an image may contain other people’s personal information.

Documents you upload. On paid tiers you can upload your own files (for example PDFs, Word documents, and images) for the assistant to read and use when answering your questions. We store these files, the text taken from them, and any folders you organize them into. Uploaded files are private to your account. Documents an authorized member uploads to an organization’s shared repository are visible to the members of that organization whose administrator has granted access, and remain within that organization. Please upload only material you are authorized to share, and remember a document may contain other people’s personal information.

Billing and payment data. When you subscribe to a paid plan, payments are processed by PayMongo. You pay by scanning a QR Ph code with your e-wallet or banking app or, where available, by card; any card details are entered with and tokenized by PayMongo, and we never see or store your full card number. We keep only a payment token or reference, the card brand and last digits (for card payments), your subscription and billing history, and the invoices and payment acknowledgments we are required to issue.

Billing information you provide for invoicing. To issue your official BIR Service Invoice and deliver your physical copy, you may provide a billed-to name or organisation, a billing address, an optional Taxpayer Identification Number (TIN), a mailing address, and a mobile number. The mailing address and mobile number are used only to courier your physical invoice when you have asked for one (the mobile number is shared with the courier for delivery coordination), and we communicate with you about deliveries by email. All of these billing details are stored encrypted.

Enterprise organization data. When an organization subscribes to the Enterprise plan, its administrator provides the company’s legal name, registered address, contact details, and Taxpayer Identification Number (TIN). The TIN is sensitive personal information under the DPA; see the paragraph below.

Sign-in session. When you sign in, we create a session so you can stay signed in across visits. The session credentials are kept by your browser.

Technical information. Our servers record standard request data (IP address, user-agent string, and timestamps) in application logs. When you sign in, or a sign-in attempt on your account fails, we also record the time, the IP address, the browser and device type, and which atorni AI app you signed in to, in a sign-in log tied to your account. Our administrators use that log to investigate suspicious access and to answer support requests. It is kept for one year and is deleted with your account. The IP address of waitlist submissions is held briefly to rate-limit abuse. When you accept the Terms of Use, at registration and again whenever you accept an updated version, we keep a record of that acceptance (the version accepted, the timestamp, and the IP address it was made from) as evidence of your assent under the E-Commerce Act (Republic Act No. 8792).

With two narrow exceptions, we do not knowingly collect sensitive personal information as defined under the DPA (e.g., government IDs, health, religion, ethnic origin), and we do not ask you to provide any in your chats. The first exception is your date of birth. Because age is classified as sensitive personal information under the DPA, we collect it only with your specific consent when you create an account, and use it solely to verify your age and eligibility. The second exception is a Taxpayer Identification Number (TIN), a government-issued identifier, which is collected only when you (or an Enterprise organization’s administrator) choose to provide it in your billing information, with your prior explicit consent, solely so that official invoices can be issued in compliance with Philippine tax law. It is always optional and stored encrypted. Please refrain from sharing sensitive information in chat content; treat chats as content visible to operators of the third-party AI providers listed below. To reduce what is shared, you can turn on Mask, which replaces names and similar personal details with neutral placeholders before your message is sent (see Section 5).

3. How we use your information

We use the information above to:

• provide the AI chat service, including retrieving relevant cases and statutes and generating an answer;
• read and search the documents you upload so the assistant can use them when answering your questions;
• authenticate you and keep your session active;
• rate-limit abuse and protect the service, using usage metadata such as message counts, timestamps, and account activity, not the content of your conversations;
• review registrations (and any earlier access requests) and assess professional eligibility (including verifying that users are legal professionals aged eighteen (18) and over), and contact you about the outcome and major service updates;
• issue invoices and payment acknowledgments, and deliver your physical BIR Service Invoice when you have asked for one (including coordinating the delivery with you by email and providing your contact number to the courier);
• respond to feedback and support requests;
• comply with our legal obligations.

We do not sell your personal information. We do not share it with advertisers or use it to build advertising profiles.

4. Legal basis for processing

Under DPA Sections 12 and 13, we rely on the following bases:

• Consent: when you create an account (or, previously, requested access via the waitlist), covering the details you provide at that stage, and explicit prior consent for the sensitive personal information described above (your date of birth at registration, and an Enterprise organization’s TIN).
• Performance of a contract: when we process your data to deliver the chat service you have asked for, and to bill, invoice, and manage your paid subscription.
• Legal obligation: when we issue and retain invoices and billing records required by Philippine tax law.
• Legitimate interest: for security, abuse prevention, server logging, and product improvement, provided your rights and freedoms are not overridden by these interests.

5. Third parties and cross-border transfers

atorni AI uses a small number of third-party processors. Where these processors are located outside the Philippines, the DPA’s rules on cross-border transfer apply, and we have selected providers with comparable data protection commitments.

OpenRouter (United States). When you send a chat message, it is forwarded to OpenRouter, which routes it to the AI model you have selected for that conversation. A Deep Research answer involves several such requests, and one of them goes to an additional model we select to check the citations in the draft; every one of those requests carries the same routing instructions described in this section. Depending on the model, that request is served by the model developer or by the cloud platform hosting it, which currently includes Amazon Web Services, Microsoft Azure, Google Cloud, and a number of specialist inference providers. This is a cross-border transfer of your message content, which may include text from documents you have chosen to use in that conversation.

Your content is never used to train AI models. Every request atorni AI sends carries a routing instruction that permits only providers that do not use your message content to train their models. A request that cannot be served on those terms is refused rather than sent. Providers may retain content briefly under their own security and abuse-prevention policies, after which it is deleted in accordance with those policies; they may not train on it in any case. OpenRouter itself does not retain your prompts, and we do not enable its optional prompt-logging feature. You can also turn on Mask to replace names and similar personal details with neutral placeholders before your message is sent, as a best-effort safeguard.

PayMongo (Philippines). Paid-plan payments are processed by PayMongo. Payment details, whether you pay via QR Ph or by card, are entered with and handled by PayMongo under its own privacy policy and PCI-DSS obligations; we receive and keep only a payment token or reference and, for card payments, the card’s brand and last digits. This processing stays within the Philippines.

Resend (United States). Transactional emails, such as access-request confirmations, welcome emails, payment acknowledgments, renewal reminders, and announcements, are delivered through Resend. Your email address and the message content are transferred to Resend’s servers for delivery. Reminder and announcement emails stop when you turn email notifications off on your profile page or use the link inside those emails.

Browser push services. If you turn on push notifications for a device, the notice for that device is delivered through the push service your browser uses (Google, Apple, or Mozilla, depending on the browser). The message is encrypted for that device before it leaves our servers, and the push service sees the device’s subscription endpoint, not your account.

Microsoft Azure. We host the application and store your data on Microsoft Azure. Your account data, chat history, and waitlist record reside on Microsoft-managed servers.

Local search model. Before sending your question to the AI, we convert it into a numerical form so we can match it against our library of cases and statutes. This step runs locally on our servers using an open-source model, so your messages are not sent to any outside party for this step.

Source materials we cite from. The legal materials surfaced as citations in chat are taken from the following public sources:

• elibrary.judiciary.gov.ph: the Supreme Court E-Library (decisions, statutes, rules, and other official issuances);
• lawphil.net: the LawPhil Project (jurisprudence and statutes);
• oca.judiciary.gov.ph: Office of the Court Administrator circulars and memoranda;
• bir.gov.ph: Bureau of Internal Revenue revenue issuances;
• sec.gov.ph: Securities and Exchange Commission memorandum circulars and SEC-OGC opinions;
• doj.gov.ph: Department of Justice department and memorandum circulars;
• dole.gov.ph: Department of Labor and Employment issuances (department orders, labor advisories, and related circulars);
• nlrc.dole.gov.ph: National Labor Relations Commission issuances (en banc resolutions and rules of procedure).

No personal data is sent to those sources at runtime.

6. Data retention

We keep your information only as long as needed:

• Account data: kept for as long as your account is active, including the professional details and date of birth you provide at registration. You may request deletion at any time using the contact details below.
• Chat history: retained so you can continue past conversations. Deletable on request. This is retention by atorni AI only, stored encrypted under a key unique to your account. AI providers never train on your message content and retain it, if at all, only briefly under their own security policies, as described in Section 5.
• Offline copy of recent chats: kept in your browser on the device you use, for at most fourteen (14) days, and deleted when you sign out. See Section 9.
• Uploaded documents: kept until you delete them or close your account. When you delete a document, the stored file and everything taken from it are removed.
• Access requests (waitlist): the details you submit with your request (including your date of birth) are kept while your request is under review and a reasonable period after, or until you ask to be removed.
• Billing and tax records: invoices, payment acknowledgments, and related billing records are retained for the period required by Philippine tax law (Bureau of Internal Revenue record-keeping rules), even after account deletion.
• Sign-in log: one (1) year, then deleted, or earlier if you delete your account.
• Server logs: typically rotated within 30 to 90 days.

When a paid subscription is cancelled, your data remains exportable for sixty (60) days as described in the Refund & Cancellation Policy; after that window, deletion follows this section.

When you ask us to delete your data, we remove it from our active records promptly. Copies may persist in backups for a short period before being overwritten on schedule.

7. Security

We implement reasonable organizational, physical, and technical safeguards as required by DPA Section 20:

• passwords hashed using industry-standard algorithms;
• sign-in sessions cryptographically protected so they cannot be forged;
• industry-standard encryption (HTTPS) for traffic between your device and our servers;
• encryption of stored chat content and uploaded documents, so they are not held in plain, readable form;
• role-based access controls separating regular accounts from administrator accounts;
• chat content encrypted under a key unique to each account, with administrative tooling that provides no access to conversation content: the operator does not view your conversations, and content is accessed only where required by law;
• automatic account lockout after repeated failed sign-in attempts.

If we become aware of a breach affecting your personal data, we will notify you and the National Privacy Commission as required by law.

8. Your rights under the Data Privacy Act

As a data subject, you have the rights listed in DPA Section 16, including:

• Right to be informed of how your personal data is being processed.
• Right to access the personal data we hold about you.
• Right to correct inaccurate or outdated information.
• Right to object to processing, including processing for direct marketing.
• Right to erasure or blocking of your data when there is a valid reason.
• Right to damages if you have been harmed by inaccurate or unlawful processing.
• Right to data portability: receive your data in a structured, commonly used format.
• Right to file a complaint with the National Privacy Commission at privacy.gov.ph if you believe your rights have been violated.

To exercise any of these rights, contact us at the address below. We will respond within a reasonable time, typically within thirty (30) days.

9. Cookies and tracking

The marketing site is static and does not set cookies or use third-party analytics.

The chat and admin applications use your browser’s built-in storage to keep you signed in. This is strictly necessary for the service to work. The chat application also keeps a copy of your recent chats in that storage so you can read them while your device is offline: the chats you open, plus your ten most recent, are saved on your device and refreshed whenever you use the application online. This copy stays on your device, is deleted when you sign out or when your session ends, and is kept for at most fourteen (14) days. None of this storage is used for tracking, profiling, or advertising. Clearing your browser’s site data removes the copy and signs you out.

If we add analytics or any other tracking in the future, we will update this policy and, where consent is required, request it explicitly.

10. Minors’ privacy

atorni AI is intended for legal professionals (lawyers, paralegals, law clerks, and law students) and is not directed to the general public. Consistent with our Terms of Use, the service is available only to persons at least eighteen (18) years of age. We do not knowingly collect personal data from anyone under eighteen (18), and the DPA’s heightened-protection rules for the personal data of minors apply where relevant. If you believe a minor has provided us personal information, please contact us so we can delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time. The “Effective date” at the top will reflect when the latest version took effect. Material changes will be communicated through the chat application and, where applicable, by email to users and access requesters.

12. Disclaimer

atorni (atorni AI) is an artificial intelligence tool. It is not a law firm, does not provide legal advice, and is not a substitute for consultation with a licensed lawyer. atorni AI provides legal information, not legal advice. The AI’s responses may contain errors, omissions, or outdated information, and they do not create a lawyer-client relationship. Always verify outputs against primary sources before relying on them for any legal decision, filing, or transaction. See the Terms of Use for the full terms that govern your use of the service.

13. Contact

For any question about this policy, or to exercise any of the rights described above:

• Email: privacy@atorni.ph
• Operator and designated Data Protection Officer: Karl Gabriel M. Anciro
• Address: 2F Unit 3, 34 Matias St., Brgy. Paltok, Quezon City, Philippines 1105

To file a complaint with the supervising regulator:

• National Privacy Commission: privacy.gov.ph