This page is New Axis Solutions P.C.'s firm-default Article 30 GDPR register for the platform itself. Workspace owners remain the controllers for their clients' personal data and should maintain their own per-firm register; this document covers the processing that New Axis Solutions carries out as processor on their behalf, plus the processing where New Axis Solutions is itself the controller (account, billing, support).
1. Controller / processor
| Processor | New Axis Solutions P.C. (operator of the Nomoaxis platform) — registered seat [to be completed on incorporation], ΓΕΜΗ [to be completed on incorporation], ΑΦΜ [to be completed on incorporation] — contact@nomoaxis.com |
| Controller (client/matter data) | The subscribing law firm (workspace owner) |
| Controller (account/billing) | New Axis Solutions P.C. |
2. Categories of data subjects
- Workspace users (lawyers, paralegals, admin staff of the subscribing firm).
- Clients of the firm (εντολείς), including individuals and legal entities.
- Opposing parties and other persons named in matters or documents.
- Witnesses, experts and counterparties referenced in case files.
3. Categories of personal data
- Identification: name, ΑΦΜ (VAT id), ΑΜΚΑ (social security number), ΑΔΤ (national id number), date of birth.
- Contact: email, phone, postal address.
- Financial: invoices, payments, hourly rates, bank reference numbers on receipts.
- Case-related: matter description, court info, deadlines, decisions, conflict-check fingerprints.
- Communications & documents: uploaded files, notes, message logs. Document bodies and names are encrypted client-side; New Axis Solutions cannot read them. Login emails, member names, workspace names, audit-log structural fields, upload/intake recipient addresses and conflict-check keyed HMAC fingerprints remain readable server-side, and document text is sent to Anthropic in plaintext when AI features are used.
- Special categories may incidentally appear inside encrypted documents (e.g. health data in a personal-injury matter). New Axis Solutions does not deliberately collect special-category data.
- AI interaction data: user-typed prompts and document text (all AI features); and, for the Nomoaxis AI assistant panel only, role-filtered context summaries drawn from matter records (matter titles, practice area, status, opposing party names, deadline titles and due dates), client records (client names, email addresses, phone numbers, notes previews), and team member records (names and roles); plus model responses generated by Nomoaxis AI, the document AI assistant, and the support chat.
4. Purposes of processing
- Provide the legal-practice-management service (matters, time, billing, documents, deadlines).
- Authenticate users, enforce MFA, detect abuse.
- Bill subscribers and process payments.
- Provide AI-assisted drafting, summarisation, and matter Q&A (Nomoaxis AI panel, document AI assistant) plus the opt-in support chat.
- Comply with legal obligations (tax law, professional retention, audit log integrity).
5. Legal bases
| Service delivery | Art. 6(1)(b) — contract (subscription agreement) |
| Billing, tax records | Art. 6(1)(c) — legal obligation (Κώδικας Φορολογικής Διαδικασίας Ν. 5104/2024 άρθρο 13; EU VAT Directive 2006/112/EC) |
| Security logging / audit chain | Art. 6(1)(c) and 6(1)(f) — legal obligation + legitimate interest |
| AI features (Nomoaxis AI, document assistant) | Art. 6(1)(b) — performance of contract + Art. 6(1)(f) — legitimate interest in providing assistive tooling |
| AI features (opt-in support chat) | Art. 6(1)(a) — explicit per-workspace opt-in |
| Service improvement (aggregate) | Art. 6(1)(f) — legitimate interest |
6. Recipients and sub-processors
| Lovable Cloud (hosting) | EU/US · SCCs · runs the application |
| Anthropic PBC | USA · SCCs · AI language model inference (drafting assistant, inline editing, cross-document analysis, case chronology, optical transcription, Nomoaxis AI panel). Receives prompts, matter/client context and document excerpts in plaintext, including documents the assistant retrieves autonomously within the open matter, plus page images and model-composed web search strings. DPA signed; API logs up to 7 days; no training on Customer Data |
| Lovable AI Gateway | US / Global · SCCs · AI inference for in-app support chat only; ephemeral; no training on Customer Data |
| Supabase, provisioned through Lovable Cloud (database, storage, auth) | EU · primary datastore · operated on Lovable Cloud infrastructure |
| Brave Software Inc. (engaged by Anthropic) | USA · SCCs via Anthropic · web search strings for legal research |
| open.er-api.com | US · public foreign-exchange rate feed · no personal data sent |
| Resend (transactional email) | EU · SCCs · sends auth / billing / notification emails |
| Stripe (payments) | EU/US · SCCs + adequacy · processes subscription payments |
| Sentry (error monitoring) | EU ingestion (ingest.de.sentry.io) · SCCs for any onward US transfer · client-side error events only; PII stripped, no IP, no session replay, no performance tracing |
7. International transfers
Primary storage is in the EU. Where a sub-processor hosts data in a third country, the transfer is covered by Standard Contractual Clauses (Module 2 or 3 as applicable) and supplementary technical measures (TLS in transit, encryption at rest, client-side encryption for document bodies).
8. Retention
| Billing records (invoices, payments) | 5 years from issuance — Κώδικας Φορολογικής Διαδικασίας Ν. 5104/2024 άρθρο 13 |
| Matter files (closed matters) | 5 years from closure (default), longer for matter types with statutory retention under Ν. 4194/2013 (Code of Lawyers) and adjacent professional rules; AML records 5 years per Ν. 4557/2018 άρθρο 30 |
| Audit log | Indefinite while the workspace is active; append-only, hash-chained. Where the workspace owner sets an audit retention period in Settings, actor identity (actor id, IP address, person-identifying metadata) is automatically anonymised past that period and the hash chain is re-sealed; the action record itself is kept |
| Authentication logs | 12 months |
| Backups | 30 days rolling |
| AI usage records (per-call token and cost telemetry) | 90 days, then deleted by a nightly automated job. Monthly budget and billing figures live in separate monthly summary rows and are unaffected |
| Accounts with no remaining workspace | Deleted 30 days after the last workspace membership ends, by a nightly automated job (account, profile, device keys, sessions, notification preferences, recovery codes, legal acceptance records) |
| AI conversation history | Stored per user; retained until the user clears it from the AI panel or the workspace is deleted |
| Erased client tombstones (Art. 17) | PII redacted on erasure (GDPR Art. 17 satisfied); the tombstone row itself is retained indefinitely as operational data under Art. 17(3)(b)+(e), to preserve referential integrity for billing, time entries, and audit records — it is not hard-deleted |
9. Security measures
- End-to-end XChaCha20-Poly1305 encryption for document content; per-user wrapped private keys.
- TLS 1.2+ in transit; encryption at rest at the storage layer.
- Row-Level Security on every tenant table; workspace_id is the tenancy key.
- Append-only, hash-chained audit log with daily integrity verification.
- MFA-capable authentication; per-workspace step-up MFA policy.
- CSV exports sanitised against formula injection.
- Rate-limiting on report and AI endpoints to prevent abuse.
- Role- and assignment-based gating for AI context assembly: matter/client context is only sent to the model when the viewer is owner/partner or assigned; revenue figures are redacted for Associate and Paralegal roles; per-seat monthly token quotas enforced server-side.
10. Data subject rights
Access (Art. 15), rectification (16), erasure with retention carve-outs (17), restriction (18), portability (20) and objection (21) requests are handled by the workspace owner for client data, and by New Axis Solutions for account data. See the Privacy Policy at /privacy for the procedure.
This register is a firm-default and will become per-workspace customisable in a future release. Workspace owners are responsible for maintaining their own controller-side Article 30 register.