Product Privacy Notice

This privacy policy sets out how Grounded AI Limited uses and protects your personal data.

1. Important information and who we are

Privacy policy

This privacy policy gives you information about how Grounded AI Limited (company number 14164566) (referred to as “Grounded AI”, "we", "us" or "our" in this privacy policy), having its registered office at Unit 3, Fen End Astwick Road, Stotfold, Hitchin, Bedfordshire, England, SG5 4BA collects and uses your personal data through your use of our services.

Our services are not intended for children and we do not knowingly collect data relating to children.

Responsibilities

Grounded AI acts as controller for the limited aspect of covering the processing of account-holder data for account management, authentication, billing, service communications, user feedback, build identity-based risk models for detecting coordinated citation manipulation (on subscription by client) and system monitoring and maintenance.

When using our services under the veracity mark, you provide us with files containing personal data for which you act as a data controller, Grounded AI will act as a data processor. In these cases, Grounded AI will process these personal data only and exclusively to the extent necessary to provide you with the service and the data processing agreement present in this link https://groundedai.company/dpa will apply.

If you upload files containing other people’s personal data, you are responsible for ensuring you have a lawful basis to do so and for informing those individuals as required by law.

If you have any questions regarding this privacy policy, please contact us by email at: human@groundedai.company

2. The types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Account Data: Name, email address, job title and OAuth profile information. Passwords are not held by Grounded AI, as authentication credentials are managed by Auth0.

• Contact Data includes billing address, and telephone numbers.

• Financial Data: limited payment details, such as card type, last four digits and expiry date. Stripe processes full card details, and Grounded AI does not see or store them.

• Transaction Data: details of payments made and the subscriptions or services purchased.

• Content that includes personal information which is sent or received using an online feature of Grounded AI Services and Software, such as documents, metadata about your content, user generated requests such as search terms, prompts, inquiries, feedback, and other information you may disclose when you access or use our Services and Software as well as any information the Services and Software returns in response to such requests including Veracity reports and other outputs.

• Technical Data includes your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, error and performance log data, device ID and other technology on the devices you use to access our services.

• Profile Data includes your interests, preferences, feedback and survey responses

• Usage Data includes information about how you interact with and use our website, products and services.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

The information we collect depends on how you use our products and how you manage your privacy settings.

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you:

• use our services and upload documents

• subscribe to our service;

• Contact, Financial and Transaction Data from our payment provider, Stripe, when you make a payment to us.

• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

• Technical Data is collected from the following parties:

• analytics providers;

• Contact, Financial and Transaction Data is collected by providers of technical and payment services through Stripe.

4. How we use your personal data

Legal Basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

• Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

• Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

• Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

1. We process your personal data for several purposes, including providing our services, administering and protecting our business and website, creating and authenticating accounts, improving our products and services, conducting market research, and managing cookies and similar technologies. To provide our services, we may process your identity, contact and transaction data where necessary for our legitimate interests in carrying on our business and providing you with a relevant and well-functioning service, in accordance with Article 6(1)(b) of the UK GDPR and EU GDPR, where applicable. We retain this data only for as long as is strictly necessary to fulfil the purpose for which it was collected.

• To administer and protect our business and website, including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting, we may process your account, contact and technical data. This processing is necessary for our legitimate interests in operating our business, providing administrative and IT services, maintaining network security, preventing fraud and facilitating any business reorganisation or group restructuring. We may also process this data where necessary to comply with a legal obligation. We retain data only for as long as necessary to operate, secure, and improve our services and meet applicable legal obligations. Error logs, performance data, and other technical information are generally retained for up to 30 days. When a subscription ends, associated account data and content are securely deleted from active systems and backups, typically within 30 days, unless we are legally required to retain it or you instruct us otherwise. Any retained data is securely deleted when no longer needed.

2. We may process technical and usage data to analyse how our website and services are used, improve our products and services, enhance customer relationships and experiences, and measure the effectiveness of our communications and marketing. This processing is based on our legitimate interests in understanding our customers, maintaining and updating our website, developing our business and informing our marketing strategy. We retain such data only for as long as is strictly necessary for these purposes.

3. Where you voluntarily subscribe to our market research activities, we may use technical and usage data to understand how customers use our products and services and to support their ongoing improvement and development. This processing is based on our legitimate interests in studying customer behaviour and improving our offerings. We retain the relevant data only for as long as is strictly necessary for these purposes.

4. We may also use cookies and similar technologies to collect technical and usage data. Where required by applicable law, we will obtain your consent before using non-essential cookies or similar technologies. Strictly necessary cookies may be used without consent where permitted by law. The data collected through cookies and similar technologies will be retained only for as long as is necessary for the relevant purpose, subject to the applicable retention periods.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask us to stop sending you marketing communications at any time by following the unsubscribe link in any marketing email, by contacting the membership team (for member communications) or by contacting us at human@groundedai.company.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see our cookie policy https://groundedai.company/cookies .

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the table in paragraph 4.

• Service providers who act on our instructions, to support the delivery, security and operation of our services. These include cloud hosting and infrastructure providers, authentication and identity management providers, payment processing providers, and system monitoring, performance and error-tracking providers.
• Independent third-party services to verify references and identify source material. These organisations operate independently and process submitted queries under their own terms and privacy policies, rather than acting on our instructions.
• Professional advisers, including lawyers, bankers, auditors and insurers.
• HM Revenue & Customs, regulators and other authorities where we are required to do so by law.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and we do not share any document content or manuscript text with third-party AI or large language model providers.

6. International transfers

We may store your personal data in secure, multitenant-isolated cloud infrastructure located in the European Union, the United States of America or Australia, depending on the applicable regional hosting arrangements.

This means that it may be processed on our behalf by service providers that carry out certain functions for us, and could be stored outside the UK.

Whenever we transfer your personal data out of the UK (or, where the EU GDPR applies, out of the European Economic Area) to service providers, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is in place:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.

• We may use specific contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us through the details given at paragraph 10.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Customer data is held in multitenant-isolated cloud storage and databases, and all document processing takes place within our private, access-controlled environment.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

Details of retention periods for different aspects of your personal data are set out in paragraph 4.

Where no specific period is stated, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see paragraph 9 below for further information.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. We will send your copy electronically unless you ask us to provide it in another way.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You can also contact us at any time to change your subscription preferences.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4).
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data, for example for our analytics cookies (see paragraph 4). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
• if you want us to establish the data's accuracy;
• where our use of the data is unlawful but you do not want us to erase it;
• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us through the contact details given at paragraph 10.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact our DPO or us in the following ways:

• Email address: privacy@groundedai.company

• Postal address: Unit 3 Fen End, Astwick Road, Stotfold, SG5 4BA

11. Data Protection Officer (DPO)

Grounded AI has appointed a Data Protection Officer, who may be contacted for any matter related to the processing of personal data and the exercise of rights:

• Name: Joseph Shockman

• Email: privacy@groundedai.company

12. Complaints

You have the right to make a complaint to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). If you are located in the European Economic Area, you may also complain to the data protection supervisory authority in your country of residence. However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. You can contact us about a complaint using the details in paragraph 10 or by using our complaints form here: https://groundedai.company/complaint.

13. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. If we make changes, we will add a notice to our website to tell you. This version was last updated on 2026-11-10. Historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

14. Third-party links

This website may include links to third-party websites, plug-ins and applications, including our social media pages on LinkedIn. 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.