Privacy policy
Last updated: 10 October 2026
This policy explains what personal data LEXSUB handles, why, for how long, and what rights you have. It covers the website at lex-submission.com and the LEXSUB app at vault.lex-submission.com.
In short. The website sets no cookies and runs no analytics. The Talk to Sales form emails your details to our sales inbox: we don't store them in the app's database or add you to a mailing list. App data, its backups and its encryption keys are stored in France, in Scaleway's Paris region. We don't sell personal data.
Who we are
LEXSUB is run by FRENCHMOB SAS, a simplified joint-stock company (société par actions simplifiée), 9 Rue Ambroise Thomas, 75009 Paris, France, registered with the RCS of Paris under number 838 590 982.
- Privacy contact: privacy@lex-submission.com
Our two roles
We handle personal data in two different capacities.
As controller. We decide why and how we use the data of:
- people who visit our website;
- people who contact us through the Talk to Sales form;
- people who hold a LEXSUB account.
As processor. Our clients are law firms. When a firm enters its lawyers, deals, referees and other records into LEXSUB, the firm is the controller of that data. We process it only on the firm's instructions, under a data processing agreement (DPA) that is part of our contract with the firm, so the firm sees it before signing. Clients can email us for a copy.
The website
lex-submission.com sets no cookies. It runs no scripts and no analytics, and it loads nothing from any third party, including fonts. We don't know who you are when you read it.
lex-submission.com is hosted on Scaleway Object Storage, in its Paris region (see "Who receives your data"). Scaleway offers us no request logs for the site, so we keep none. Traffic to lex-submission.com passes through Cloudflare, which delivers the site and protects it from attacks. To do that, Cloudflare processes technical data about each request, such as your IP address, the page requested and the time. We have no access to those logs.
The Talk to Sales form
LEXSUB has no public sign-up. If you want an account, you fill in the Talk to Sales form, which is part of the app.
What we collect
Five fields are required:
- your name;
- your work email;
- your phone number;
- your law firm's name;
- the country your firm is based in.
You can also answer three optional questions about your firm's directories: which directories you're about to submit to, whether you've already submitted to all of them, and which ones you've submitted to before.
What happens to it
When you send the form:
- We check that each field is filled in correctly.
- We email your details, in plain text, to a single LEXSUB sales inbox. The email also records the date and time you sent it. If we reply, the reply goes to the work email you gave.
- We don't store your details in the app's database, and we don't add you to any mailing list.
The email is sent through Scaleway Transactional Email, our email provider, and reaches our inbox through Cloudflare's email routing (see "Who receives your data"). The same sales inbox also receives the requests firm owners send us to delete their firm.
To protect the form from abuse, we use your IP address to limit how many requests can come from one address. We keep it in memory only, never in the database, and our server logs don't record it (see "How long we keep it").
Why, and on what legal basis
We use these details to answer your enquiry and discuss setting up an account for your firm. Our legal basis is our legitimate interest in responding to people who ask to hear from us (GDPR Article 6(1)(f)).
Your LEXSUB account
Accounts are by invitation only. Our team sets up each new client firm and invites its first user. That user can then invite colleagues.
What we collect
- Identity and sign-in: your name, your email address and your password. We store the password only as a one-way hash.
- Two-factor sign-in: the secret that links your authenticator app, stored encrypted, and your recovery codes, stored as one-way hashes.
- Preferences: your time zone (detected by your browser when you sign up, and editable in Settings) and whether you want deadline reminders.
- Access: the firms you can access, your role in each, and who invited you. We keep a log of changes to a firm's access: who invited, changed or removed whom, and when.
- Activity: when your account was created and when you last used the app.
- One-time codes: short-lived codes and links we email to verify your address, reset your password or confirm sensitive actions.
- Server logs: for each request, the time and the page address, without its query string. They don't record your IP address.
- Firm setup: when our team sets up a new client, we record the contact person's name, email and phone number, and the firm's name, office address and country. We also record the firm's email domains (shared access is limited to addresses at those domains), whether its access is live or waiting for payment, and the date of its last payment.
Emails we send you
We email you only about your account and your firm's work in LEXSUB:
- verification codes and password reset links;
- invitations to join a firm;
- security codes for sensitive actions, such as deleting a firm;
- submission deadline reminders.
You can turn deadline reminders off in Settings, or with the one-click link in any reminder. We don't send marketing emails.
Why, and on what legal basis
| Purpose | Legal basis |
|---|---|
| Provide the app and your account | Performance of our contract with your firm (Art. 6(1)(b)). If your firm invited you, our legitimate interest, and your firm's, in giving you access to the service (Art. 6(1)(f)). |
| Keep the service secure: sign-in, two-factor checks, abuse limits, access logs | Legitimate interest in protecting the service and our clients' data (Art. 6(1)(f)) |
| Send deadline reminders | Legitimate interest in helping you meet the deadlines the service tracks (Art. 6(1)(f)). You can opt out at any time. |
| Find and fix errors | Legitimate interest in running a reliable service (Art. 6(1)(f)) |
| Keep a record of who had access to a firm, including after a member deletes their account | Legitimate interest in being accountable to the firm for who had access to its data (Art. 6(1)(f)) |
| Invoicing and accounting | Legal obligation (Art. 6(1)(c)). We issue invoices with Sage, which holds the billing details shown on each invoice. |
Firm data we process for our clients
This section covers data that firms enter into LEXSUB. For this data, your firm is the controller and we are its processor.
What it includes
Depending on what a firm enters, it can include:
- lawyers: names, contact details, job titles, departments, biographies and ranking information;
- deals: client names, matter descriptions, values, dates and the other firms involved;
- referees: names, job titles, employers, contact details and postal addresses;
- team moves: the names and roles of lawyers who joined or left;
- the firm's contacts and practice information.
How we handle it
- We use it only to provide LEXSUB to the firm: to store it, show it to the firm's authorised users, and build the submission files they ask for.
- We don't sell it, share it with the directories, or use it for any other purpose.
- Each firm's data is kept separate from every other firm's. Every request checks that the user has access to the firm concerned, and the database itself, independently, returns only the rows of the firms the request may see. Only users the firm has invited can see it.
- The content of a firm's deals, referees, practice descriptions, ODA text answers and team moves is also encrypted with a key unique to that firm, held in a separate key service. For deals, that means client names, matter descriptions and values, the other firms advising, completion dates or status, jurisdictions, sectors and summaries; for referees, every detail. It doesn't cover lawyers, interview contacts, ODA figures and choices, department names, other dates, or user accounts, which are protected as described in "How we protect your data".
- When a user imports a previous submission file, we read it and save only the entries the user confirms. We don't keep the file.
- Our server logs record page addresses without their query string, and database errors without the values involved. Page addresses identify records by number, never by name.
If your details are in a firm's records
If you are a lawyer, a client contact or a referee whose details a firm has entered in LEXSUB, please contact that firm to exercise your rights. If you contact us, we will pass your request to the firm and help it respond.
Who receives your data
Within LEXSUB, personal data is accessed only when needed to operate, support or secure the service. Our staff pages show a firm's metadata and counts only, never its content, and offer no way to view the app as one of the firm's users. Opening them requires two-factor sign-in, and every staff action on a firm, such as cutting its access or deleting it, is recorded in an audit trail the app can only add to.
Only the legal owner of LEXSUB, Guillaume Marolleau, has access to production systems. Production data is never copied outside Scaleway. Any access to a firm's data outside the app, for a support request or an incident, is logged.
We use these service providers (subprocessors). Each acts only on our instructions, under a contract that includes data protection terms.
Scaleway SAS
- What it does: hosts the app, its database, its backups and its encryption keys, the website lex-submission.com and our inboxes. Sends our emails and keeps the app's logs.
- Data it handles: all app data, the app's logs, and the emails we send and receive, such as Talk to Sales enquiries, firm deletion requests, support requests (which can include firm data) and our replies.
- Location: France (Scaleway's Paris region). Scaleway is a French company.
Cloudflare
- What it does: routes the email sent to our lex-submission.com addresses to our inboxes. Delivers lex-submission.com and protects it from attacks.
- Data it handles: the emails sent to us, such as Talk to Sales enquiries, firm deletion requests and support requests (which can include firm data), and technical data about each visit to the website.
- Location: Cloudflare is a US-based company (see "Where your data is stored").
Sage
- What it does: issues our invoices.
- Data it handles: the billing details shown on each invoice.
- Location: European Union.
We don't sell personal data. We don't share it with advertisers or with the legal directories. We disclose it to authorities only when the law requires us to.
Where your data is stored
App data, its backups and encryption keys, the app's logs, our inboxes and the website are stored in France, in Scaleway's Paris region (fr-par). Scaleway is a French cloud provider. Its SecNumCloud offer is undergoing qualification by ANSSI, the French national cybersecurity agency.
The LEXSUB app runs entirely in Scaleway's data centres. Scaleway presents itself as the sovereign cloud: a reliable, innovative cloud chosen by government ministries, public administrations and institutions, research institutes and universities. Scaleway is certified ISO/IEC 27001:2022, and HDS-certified for hosting and securing health data. Its 10 data centres are in Europe, four of them in France. Scaleway states that its services comply with the GDPR and are beyond the reach of extraterritorial laws, so that its clients keep full sovereignty over their data. It provides the public sector with a secure, sustainable cloud.
Only one of our providers may handle personal data outside the European Economic Area: Cloudflare, a US-based company, which routes the email sent to our lex-submission.com addresses and delivers the website. That transfer relies on Cloudflare's certification under the EU-US Data Privacy Framework and, as a fallback, on the European Commission's Standard Contractual Clauses, which are part of Cloudflare's data processing terms.
How long we keep it
| Data | How long |
|---|---|
| Talk to Sales enquiries (sales inbox) | Up to 3 years after our last contact with you, unless you become a client |
| Support requests and firm deletion requests (our inboxes) | Up to 3 years after the request is closed |
| Contact details of a client firm | For the length of our contract with the firm, then up to 3 years |
| Records of the emails we send, held by Scaleway Transactional Email: recipient, sender, subject and delivery status, not the content | As long as Scaleway keeps them in the service's activity history, which covers the current and previous calendar year |
| Your account | Until it is deleted (see "Deleting your account" below) |
| Your email address in a firm's access history | For as long as that firm exists, including after you delete your account |
| Firm data | Until the firm deletes it. When our contract with the firm ends, until the end of the period that contract sets for a final export |
| Our staff audit trail: which staff member acted on a firm, what they did, when, and the firm's name | For as long as LEXSUB runs. It can't be edited, and it stays after the firm is deleted |
| Database backups | 7 days. Taken daily and kept in Scaleway's Paris region only, then deleted |
| Server logs, including error details | 7 days |
| IP addresses used to limit abuse | In memory only, cleared after about 10 minutes without activity, or when the app restarts |
| Invoicing records | 10 years, as French commercial law requires |
Deleting your account. A member can delete their account at any time in Settings. Deletion is immediate and permanent: it removes your account and your access to every firm from the live database. The firms' data stays, and the changes you made show as made by "a colleague". A firm's owner can't delete their account: they first transfer ownership, delete the firm in Settings, or ask us to delete the firm, which we do by hand after confirming the request with them. Your account leaves our backups when they expire, after 7 days.
Deleting a firm. Deletion from the live database is immediate and permanent, for every member of the firm. The firm's key is destroyed after a 7-day safety window, which makes the firm's encrypted content unreadable in the database and in its backups. The rest is removed from backups when they expire after 7 days.
How we protect your data
Where and how it's stored
- Hosting: in France, in Scaleway's Paris region, backups included.
- In transit: connections to the app use HTTPS. The app reaches its database over a private network, through an encrypted connection that checks the database's certificate.
- At rest: the database disk is encrypted by our host. Your firm's deal, referee and practice content is also encrypted with a key unique to your firm, in the database and in its backups.
- Keys: each firm's key is held in a separate key service (Scaleway Key Manager), which the database's credentials can't reach.
Who can open it
- Separation: each firm's data is kept separate from every other firm's. Every request checks that the user has access to the firm concerned, and the database itself, independently, returns only the rows of the firms the request may see.
- Sign-in: two-factor sign-in is available to every user. We recommend turning it on.
- Passwords: stored only as one-way hashes. The secret behind your authenticator app is stored encrypted.
- Staff: LEXSUB staff have no in-app way to view your firm's content. Staff pages require two-factor sign-in, and every staff action on a firm is logged. Only the legal owner of LEXSUB has access to production systems, and production data is never copied outside Scaleway.
- Logging and limits: we log changes to who can access a firm, and we limit repeated attempts to sign in or send forms.
No system is perfectly secure. If a breach puts your data at risk, we will notify the CNIL and, where required, the people affected. As a processor, we will tell the firm concerned without undue delay. To report a security issue, see our security policy.
Cookies
The website (lex-submission.com) sets no cookies.
The app (vault.lex-submission.com) sets only cookies that are strictly necessary for it to work and to keep it secure. Under French law, these don't need your consent, so the app shows no cookie banner. It sets no analytics, advertising or tracking cookies.
| Cookie | Purpose | Lifetime |
|---|---|---|
ls_csrf | Protects forms, including Talk to Sales, against cross-site request forgery | 24 hours |
ls_session | Keeps you signed in | 24 hours |
ls_pending_2fa | Remembers that you've entered your password while you enter your two-factor code | 5 minutes |
ls_after_verify | Returns you to your invitation after you verify your email address | 24 hours |
ls_firm_delete | Tracks the confirmation steps when a firm owner deletes a firm | 10 minutes |
ls_admin_wipe | Staff only: tracks the confirmation steps when our staff delete a firm | 10 minutes |
Your rights
Under the GDPR and the French Data Protection Act, you have the right to:
- access your personal data and get a copy;
- correct it;
- have it deleted;
- restrict how we use it;
- object to our use of it, where we rely on legitimate interest;
- receive it in a portable format, where we process it under a contract;
- give instructions on what happens to your data after your death.
To exercise any of these rights, email privacy@lex-submission.com. We will reply within one month. We may ask you to confirm your identity first.
If your request concerns data a firm has entered in LEXSUB, see "If your details are in a firm's records".
If you think we haven't handled your data properly, you can complain to the CNIL, the French data protection authority: www.cnil.fr, or 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07.
Changes to this policy
If we change this policy, we will update the date at the top. If a change affects account holders significantly, we will tell them by email before it applies.
Contact
For any question about this policy or your data, email privacy@lex-submission.com.