Lex · privacy.

This policy explains how ALMA handles your personal data when you use Lex by ALMA ("Lex"). It starts with a summary; the details follow.

0. At a glance

• Who is responsible: ALMA (Albuquerque de Matos, Unipessoal, Lda) provides Lex and is the controller of your data.
• What we process: your account details, what you write in Lex (questions, topics, notes and annotations) and some technical data the service needs to work and stay secure.
• Artificial intelligence: Lex's answers are generated by artificial intelligence (AI) from the official sources Lex finds. To do this, your question and the sources found are processed by AI models hosted on Cloudflare's network. Cloudflare does not use this data to train models, and neither does ALMA. Lex does not send your questions to other AI providers.
• Who receives data: the recipients listed in section 8, including the people you choose to share with.
• Purchases: paid plans and credit packs can only be bought on the App Store. Apple handles the payment; ALMA does not receive your card details.
• Age: Lex can be used from the age of 16; at 16 or 17, with the agreement of your parents or legal guardian.
• No advertising: we show no ads, we don't track you across other sites and we don't sell personal data.
• Your rights: you can access, correct and delete your data, object to its processing and complain to the CNPD (the Portuguese data protection authority). You can delete your account in Lex's Settings.

1. Who is responsible

The controller of your data in Lex is:

Albuquerque de Matos, Unipessoal, Lda (ALMA)
NIPC (tax and company number) 516746596
Address: Rua Canto da Maya 1, 8.º, 1070-372 Lisboa, Portugal
Email: legal@alma.dev

ALMA has not appointed a data protection officer. For any privacy matter, write to legal@alma.dev.

What this policy covers. Lex at lex.alma.dev, its server at api.lex.alma.dev and the Lex app for iPhone, iPad and Mac (identifier dev.alma.lex), once it is available. It does not cover Lex installed by a law firm or another organisation in its own Hub: there, that organisation's privacy notice applies and, for the data that reaches ALMA, the Hub privacy policy. It also does not cover the alma.dev website, which has its own general privacy policy.

2. What we process

• Account: name, email address, password (stored only as a cryptographic hash, never in readable form), whether you confirmed your email and, if you add one, a profile photo.
• Signed-in devices: IP address, type of device and of browser or app, approximate location derived from the IP address (city and country), how you signed in and when it was last active.
• Passkeys: if you create one, we store its public key, an identifier, which password manager holds it and when it was created and last used. The private key never leaves your device or your password manager.
• Notifications: if you allow them, the device's notification token, the device name and model, and the system and app versions.
• Preferences: for example language, theme, notifications and research options.
• What you create in Lex: topics (the title is generated from the first question), conversations, questions, answers and cited sources, notes, annotations and the passages you highlighted, the news you follow and have read, and what you share with other people or receive from them.
• AI usage: for each answer you ask for, the date, the model that wrote it, the amount of text processed and the cost in credits, to count the usage included in your account or your plan and the credits you bought, and to show you how much you can still use.
• App Store purchases: the plan you have and, for each purchase, the data Apple sends us: the product bought, the dates, the price and the transaction and subscription identifiers (section 12).
• Document requests: the official link of a document you ask us to add to Lex, kept with your account's identifier so we can show you the requests you made.
• Error reports: when something fails in the app, it sends ALMA a report with the error and where it happened, the page address with sensitive parts removed, your account's identifier and email, the app version and technical details of the device (browser or app version, system, screen size, language, connection type, approximate memory and number of processor cores). When a request to Lex's server fails, the server keeps a log of the error with your account's identifier, the request address and technical details of the error, and may send a similar report to ALMA's error reporting system, with your account's email.
• Communications with us: what you write to us, for example to ask for support or to exercise your rights, and our replies.
• Acceptances: the version of the Terms of Use you accepted, the version of this policy you were shown, and when.

Required data. To create an account we need your name, email and a password; without them the account cannot be created. To answer, Lex needs your question. Everything else is optional: notifications, passkeys, sharing and purchases only exist if you use them.

3. Why and on what basis

The legal bases are those of Article 6(1) of the General Data Protection Regulation (GDPR). Retention periods are in section 10.

Sections 5 and 6 explain how we handle data about other people: those you mention in what you write, and those named in the official sources.

We do not use your data for other purposes. We do not use what you write in Lex to train AI models or for advertising. Before we process data for a new purpose, we tell you (section 17).

4. Your questions and AI

Lex's answers are generated by artificial intelligence. When you ask a question, Lex searches its collection of official sources for the relevant passages, and an AI model writes the answer from them. No person writes or reviews the answers. Each answer shows which model wrote it.

Which models. Lex's answers are written by AI models hosted on Cloudflare's network, on the Workers AI service, in ALMA's Cloudflare account where Lex is hosted. They also plan each search and rank the passages found. Lex does not send your questions to other AI providers, such as Anthropic (Claude) or OpenAI. If that changes, we will update this policy and tell you first (section 17), and we will only send your questions to another provider with your permission.

What is sent. To write each answer, the model receives your question, the passages from the sources found and the earlier messages of the same topic.

What happens to that data.

• Cloudflare (Workers AI): under Cloudflare's terms, it does not use this data to train models and does not keep it after answering, except in features that keep logs, such as AI Gateway. Processing happens on Cloudflare's network, in data centres in the European Union and in other countries.
• ALMA: keeps your questions and answers in your topics, in your account, until you delete them or your account. It does not use them to train models.

Quote checking. The quotes in each answer are compared automatically with the stored text of the sources, and those that are not found are flagged. The interpretation is not checked. Always check the sources before using an answer.

No automated decisions. Lex does not take decisions about you based solely on automated processing that produce legal effects concerning you or similarly significantly affect you. If we have to suspend an account, the decision is taken or reviewed by a person.

5. Information about other people you type in

In your questions, notes and annotations you may write information about other people, for example clients, parties to a case or witnesses. This section explains how we handle that information, and it is also meant to inform those people.

A request. Don't include names, tax numbers, contact details or anything else that identifies clients or other people. Describe the facts anonymously: Lex doesn't need to know who the people are to find the relevant provisions and decisions. If you are bound by professional secrecy, it is for you to decide what information you may enter.

• What data: whatever the user writes. It may include, even indirectly, special categories of data (for example about health, racial or ethnic origin, religious or political beliefs, trade union membership or sex life) or data about criminal offences and convictions. We ask users not to include them when they identify someone.
• What for: only to answer the question, keep the topic in the account of the person who wrote it and, if that person decides to, share it with whoever they choose.
• Legal basis: the user's legitimate interest in doing their research and ALMA's in providing the service they asked for (GDPR Article 6(1)(f)).
• Source: the user who wrote it.
• Who receives it and where: the recipients and on the terms of sections 4, 8 and 9.
• How long: as long as the topic or note exists in the account of the person who wrote it, or in a share or a shared space (sections 7 and 10).

Why we don't inform each person directly. We don't know who the people mentioned are or how to contact them, and we could only find out by reading the content of accounts, which we don't do (section 14). So we publish this information and apply these safeguards: we ask users not to identify people; we use this information for no other purpose and not to train models; ALMA's staff don't read it except in the cases in section 14; and it is deleted with the topic or the account, except in shares and shared spaces (section 10).

If you are a person mentioned. You can exercise your rights (section 15) by writing to legal@alma.dev. To help us find the information, tell us what you know, for example the email of the user who may have written it. Without that, we may not be able to locate it.

6. People named in the official sources

Lex's collection holds official texts that have already been published (Portuguese and European Union legislation, decisions of courts and other public bodies, legislative initiatives of the Portuguese Parliament) and references to academic works published in open-access repositories. These texts can name people, for example public office holders, authors, legal representatives, judges or parties to a case.

• What for: making these texts searchable, citable and up to date in Lex.
• What data: what the texts contain as published, normally names and roles (for example of judges, legal representatives, authors or public office holders) and, in decisions, the facts of the case as the source published them, which may include health data or data on criminal offences where the source did not anonymise them.
• Legal basis: the legitimate interest of ALMA and of users in accessing and searching official texts that have already been published (GDPR Article 6(1)(f)), balanced against the rights of the people named.
• Source: the official sources shown on each document, with their link.
• Who receives it: Lex users, Cloudflare, where the collection is hosted (sections 8 and 9), and organisations that install Lex in their own Hub, which receive a copy of the collection and are responsible for it.
• Care taken: we reproduce court decisions as the official sources publish them, normally already anonymised by those sources, and we add no personal data to the texts.
• How long: as long as the official text is part of the collection.

Your rights. If you are named in a text in Lex, you can object to this processing or ask us to delete or hide your data by writing to legal@alma.dev with the document's link. If the request is upheld, we remove or hide that data in the collection ALMA maintains and we tell the organisations that received a copy.

7. Sharing with others

You can send topics and annotations to another person with a Lex account by entering their full email address. Lex doesn't show or search other users: it only finds the account with that exact address. Likewise, anyone who knows your account's full email address and types it in Lex learns that you have a Lex account and sees your name and your profile photo, if you added one.

The recipient of a share sees your name and what you sent, and can import a copy into their own account. The imported copy then belongs to that person and stays with them, even if you later delete the original or your account. Until the share is imported or declined, you can take it back. So that the recipient can import it, we keep a copy of what you sent until the share is declined or taken back; otherwise, until 180 days have passed since it was sent, even after it is imported. After those 180 days the share is deleted in the next automatic clean-up and can no longer be imported.

You can also save topics and annotations as a file (.lex) on your device and send it to anyone you like. That file is outside Lex: what happens to it depends on you and on whoever receives it.

If you use a space shared with other people, that space's members see what you keep in it, according to the role you give them. If you delete your account, what you kept in that space stays in it; if the space is yours, it passes to another member.

Before sharing, make sure you may share the information the topic contains, especially data about clients or other people.

8. Who receives data

This table shows who receives Lex data. The recipients marked as processors handle data on ALMA's behalf and on our instructions; they are all of Lex's processors.

Where the law requires it, we may have to disclose data to public authorities or courts.

If we change this list, we update this policy and, if the change is significant, tell you in advance (section 17).

9. Transfers outside the EEA

Some recipients are in the United States or process data in other countries outside the European Economic Area (EEA). Lex's data does not stay only in the European Union: Cloudflare and the Workers AI models may process it in data centres outside the European Union.

• Cloudflare, Inc. (United States): participates in the EU-US Data Privacy Framework, recognised by Commission Implementing Decision (EU) 2023/1795. Cloudflare's data processing agreement provides the European Commission's standard contractual clauses as a fallback.
• Apple (United States), for notifications and App Store purchases: the safeguards Apple itself describes in its privacy policy.
• Browser push services and our email provider: those providers' safeguards, about which you can ask us.

You can ask for a copy of the applicable safeguards by writing to legal@alma.dev.

10. How long

When you delete your account, we delete the account and what you created in your personal Lex space. All that remains is:

• backups, for up to 30 days;
• copies other people imported from what you sent them;
• shares you sent that were not declined or taken back, which the recipient can still import up to 180 days after they were sent, and the copy kept for that, even if already imported, until then;
• what you kept in spaces shared with other people, which stays in those spaces;
• error reports sent to ALMA, until they are 90 days old, and the entries in the server's error log with your account's identifier, until they are deleted as described above;
• the document requests you made, with your account's identifier;
• the records of App Store purchases, as described above;
• records the law requires us to keep.

11. Notifications and email

Notifications. You only get them if you allow them on your device or in your browser. In the app for iPhone, iPad and Mac they are delivered by the Apple Push Notification service (APNs), which receives the device's token and the notification content. In a browser they pass, encrypted, through the push service of the browser's maker. Notifications tell you what happened, for example a legislative update you follow or a share you received, and may include the name of the person who shared and the title of what they shared. Tokens are deleted when you sign out on that device or delete your account. You can turn notifications off in Lex's Settings or in your device's settings.

Email. Service emails (confirming your address, resetting your password and, when needed, notices about your account or changes to these texts) are sent from no-reply@lex.alma.dev through Cloudflare's email sending service. We send no marketing.

12. App Store purchases

Lex's paid plans and credit packs are sold only on the App Store, in the Lex app for iPhone, iPad and Mac. We do not sell plans or credits on the web or in any other way, and we do not process the details of your means of payment.

• Apple is the seller: it takes the payment, handles VAT and issues the invoice, under its own terms and privacy policy. ALMA does not receive your card details or any other payment details.
• What ALMA receives: for each purchase, Apple sends us the data we need to give you access: the product bought, the dates, the price and the transaction and subscription identifiers. It also tells us about renewals, cancellations and refunds. To link the purchase to your account, the app sends Apple, with the purchase, a code derived from your account's identifier, which does not include your name or email.
• At lex.alma.dev: a subscription bought on the App Store also applies to the same Lex account at lex.alma.dev.
• Cancelling: an App Store subscription is cancelled in your Apple account's settings. Deleting your Lex account does not cancel it.

How long we keep this data is in section 10.

13. Cookies and device storage

The cookies and device storage listed in the table below are those strictly necessary to provide the service you ask for. Lex uses no advertising or analytics cookies, and no third-party tools that track your browsing. Error reports also read some data from the device, as explained at the end of this section.

Passkeys are kept by your password manager (for example iCloud Passwords), not by Lex.

Error reports. When something fails, the app reads some technical details from the device for the error report (section 2): browser or app version, system, screen size, language, connection type, approximate memory and number of processor cores. We use them only to find and fix the fault.

14. Security and staff access

We use encrypted connections (HTTPS), store passwords only as cryptographic hashes and end sessions left unused. No system is infallible: if there is a personal data breach, we notify the CNPD as the law requires and, where the breach is likely to result in a high risk to your rights, we tell you.

Staff access to your content. ALMA's staff do not read your topics, questions, notes or annotations, except: at your request (for example, to fix a problem you report); where needed for the security of the service or to investigate abuse; or where the law requires it.

15. Your rights

• Access: know what data we process about you and get a copy.
• Rectification: correct inaccurate or incomplete data.
• Erasure: ask us to delete your data, in the cases the law provides for. You can delete your account in Settings (see the support page).
• Restriction: ask us to pause processing in certain cases, for example while we check whether the data is accurate.
• Portability: receive the data you gave us in a structured, commonly used and machine-readable format, and pass it to another controller. You can also save your topics and annotations as a .lex file.
• Objection: see the box below.
• Withdrawing consent: where processing is based on consent, at any time, without affecting processing already done.

How to exercise them. Write to legal@alma.dev, preferably from your account's email. We reply within one month, which may be extended by two further months if the request is complex or there are many requests; in that case we tell you why within the first month. It is free, unless the request is manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse it, explaining why. We only ask for information to confirm your identity if we have reasonable doubts about it. When we correct or delete data at your request, we tell anyone who received it from us, unless this is impossible or involves disproportionate effort.

Complaints. You can lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD), Av. D. Carlos I, 134, 1.º, 1200-651 Lisboa, Portugal, geral@cnpd.pt, www.cnpd.pt, or with the supervisory authority of the Member State where you live, where you work or where the alleged infringement took place. You can also go to court. We would appreciate the chance to sort it out first, but you don't have to contact us before complaining.

16. Minimum age

Lex can be used from the age of 16. We do not knowingly create accounts for people under 16.

If you are 16 or 17, you can create an account and use Lex with the agreement of your parents or legal guardian. They are also responsible for any purchase. Purchases are only made on the App Store (section 12), where Apple's family settings, such as Ask to Buy, apply.

Why your parents' agreement. We process your account's data to provide the service you asked for, on the basis of the contract (section 3), not on the basis of your consent. So the age of 13 that Portuguese law sets for consent to digital services (Article 16 of Law 58/2019) is not the one that counts here. What counts is the capacity to enter into the contract: under the Portuguese Civil Code (Articles 122 to 127), people who are not yet adults do not, as a rule, have it on their own.

If you know that someone under 16 has created an account, tell us at legal@alma.dev and we will delete it. The parents or legal guardian of someone aged 16 or 17 can exercise the rights in section 15 on that person's behalf by writing to the same address.

17. Changes

This is version 1 of this policy, dated 31 October 2026. If we change it, we publish the new version with its date and keep earlier versions available (links below). Before we start processing data for a new purpose, we tell you. If the change is significant (for example a new recipient or a new transfer outside the EEA), we tell you by email or with a notice in Lex, reasonably in advance of the date it takes effect.

Versions: version 1, 31 October 2026 (current).

18. Contact

Privacy and legal matters: legal@alma.dev
Support: support@alma.dev
Albuquerque de Matos, Unipessoal, Lda, Rua Canto da Maya 1, 8.º, 1070-372 Lisboa, Portugal

See also the Lex Terms of Use, the support page and ALMA's legal information.