Privacy Policy

Last Updated: January 31, 2026

This Privacy Policy describes how Lex, Inc. ("Lex," "we," "us," or "our") collects, uses, and shares your personal information when you use our AI-powered workspace at https://thoughtful.app ("Thoughtful Platform"). This Privacy Policy does not apply to any third-party websites, services, application program interfaces ("APIs") and software development kits ("SDKs"), even if they are accessible through the Thoughtful Platform.

1. PERSONAL INFORMATION WE COLLECT

2. HOW WE USE YOUR PERSONAL INFORMATION

3. HOW WE SHARE YOUR PERSONAL INFORMATION

4. YOUR PRIVACY CHOICES AND RIGHTS

5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

6. HOW LONG WE KEEP PERSONAL INFORMATION

7. SUPPLEMENTAL NOTICE FOR USERS IN CERTAIN REGIONS

8. CHILDREN

9. THIRD-PARTY WEBSITES OR APPLICATIONS

10. CHANGES TO THIS PRIVACY POLICY

11. CONTACT US

1. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, the Thoughtful Platform, and the requirements of applicable law.

A. Personal Information You Provide to Us Directly

We collect personal information that you provide to us.

Account Information. We collect personal information, such as your name, email address, and a profile picture when you create a Thoughtful account.
Payment Information. We may collect personal information when you purchase a subscription to the Thoughtful Platform. We use third-party payment processors to process payments, such as Stripe. We do not directly collect or store any payment card information, but we may receive information associated with your payment card information (e.g., your billing details).
User-Generated Content. We collect personal information when you submit content through the Thoughtful Platform, such as comments, Chat messages, uploaded documents, audio and voice recordings (when you use speech-to-text features), and other content or information that you generate, transmit or otherwise make available on the Thoughtful Platform, as well as associated metadata. For clarity, we may collect your conversations with the AI assistant including both your inputs and the AI assistant's outputs.
Communication Information. We may collect personal information, such as your name and an email address, when you request information about us or the Thoughtful Platform, request support, submit a feature request, report a bug, or otherwise communicate with us.
Interactive Features. We and others who use the Thoughtful Platform may collect personal information that you submit or make available through our interactive features (e.g., commenting functionalities or Chat). Any information you provide using the public sharing features of the Thoughtful Platform will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy protections referenced here.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Thoughtful Platform.

Usage Information. When you use the Thoughtful Platform, we collect certain information automatically, including your Internet protocol (IP) address, user settings, cookie identifiers, mobile carrier, other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider (ISP). We may also collect personal information about your use of the Thoughtful Platform, such as the links you click within the Thoughtful Platform, the types of content you interact with, the frequency and duration of your activities, and other similar information.
Crash Reports. If you provide crash reports, we may collect personal information related to such crash reports, including detailed diagnostic information about your device and the activities that led to the crash.
Cookie Policy (and Other Technologies). We and third parties that provide content or other functionality on the Thoughtful Platform may use cookies, pixel tags, and other technologies ("Technologies") to automatically collect information when you use the Thoughtful Platform.
- Cookies. Cookies are small text files placed on device browsers. Cookies store preferences and enable and enhance your experience.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Thoughtful Platform that collects information about engagement on the Thoughtful Platform. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page. We may also include web beacons in emails to understand if a recipient opened, acted on, or forwarded them.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to the Thoughtful Platform, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality.
Performance-Related. We may use Technologies to assess the performance of the Thoughtful Platform, including as part of our analytic practices to help us understand how individuals use the Thoughtful Platform (see Analytics below).
Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using the Thoughtful Platform. This may include identifying you when you sign into the Thoughtful Platform or keeping track of your specified preferences, interests, or past items viewed. See "Your Privacy Choices and Rights" below to understand your choices regarding these Technologies.
Analytics. We may use Technologies and other third-party tools to process analytics information on the Thoughtful Platform. These Technologies allow us to better understand how the Thoughtful Platform is used and to continually improve and personalize the Thoughtful Platform. Some of our analytics providers include:
- PostHog. For more information about how PostHog uses your personal information, please visit PostHog's Privacy Policy.

C. Personal Information Collected from Other Sources

Third Parties. We may collect personal information from third parties. For example, you may direct a third-party application to share personal information about you with us.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide the Thoughtful Platform, for administrative purposes, and to market the Thoughtful Platform, as described below.

A. Provide The Thoughtful Platform

We use personal information to fulfill our contract with you and provide the Thoughtful Platform, such as:

Managing your information and accounts;
Providing access to certain areas, functionalities, and features of the Thoughtful Platform;
Answering support requests;
Communicating with you about your account, activities on the Thoughtful Platform, and policy changes; and
Processing your financial information and other payment methods for products or services purchased.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and taking appropriate actions against malicious actors;
Measuring interest and engagement with the Thoughtful Platform;
Creating de-identified and/or aggregated information;
Carrying out analytics;
Improving, upgrading, or enhancing the Thoughtful Platform;
Developing new products and services;
Ensuring internal quality control and safety;
Debugging to identify and repair errors on the Thoughtful Platform;
Auditing relating to interactions, transactions, and other compliance activities;
Sharing personal information with third parties as needed to provide the Thoughtful Platform;
Enforcing our agreements and policies; and
Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to provide you with marketing. If you have any questions about our marketing practices, you may contact us using the information provided below.

D. With Your Consent

We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

E. Other Purposes

We also use your personal information for other purposes as requested by you or as permitted by applicable law.

F. Creating De-Identified and/or Aggregated Information

We may use personal information to create de-identified and/or aggregated information, such as demographic information, information about how you use the Thoughtful Platform, information about the device from which you access the Thoughtful Platform, or other analyses we create. If we create or receive de-identified information, we will not attempt to reidentify such information, unless permitted by or required to comply with applicable laws. De-identified and/or aggregated information is not personal information, and we may use, disclose, and retain such information as permitted by applicable laws including, but not limited to, for research, analysis, analytics, and any other legally permissible purposes.

3. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with third parties for a variety of business purposes, including to provide the Thoughtful Platform, to protect us or others, or in the event of a corporate transaction, as described below.

A. Sharing to Provide the Thoughtful Platform

The categories of third parties with whom we may share personal information are described below.

Other Users of the Thoughtful Platform. When you use the Thoughtful Platform to collaborate or interact with others, we will share certain information with your collaborators. For example, you can create content, which may contain information about you, and grant permission to others to see, share, edit, copy and download that content based on settings you or your administrator (if applicable) select. In addition, some of the collaboration features of the Thoughtful Platform display some or all of your profile information to other Thoughtful Platform users when you share or interact with specific content. For example, when you comment, we display your profile picture and name next to your comments so that other users with access to the comment know who made it. Please note that we are not responsible for privacy practices of users who receive information about you through the Thoughtful Platform.
The Public. You or others with shared access to your content can make content publicly available. In such cases, any information about you included in such content is also publicly available.
Integrated Third-Party Services You Share or Interact With. Certain features and functionalities of the Thoughtful Platform may link to or allow you to interface, interact, share information with, direct us to share information with, access and/or use third-party websites, applications, services, products, and technology (collectively, "Integrated Third-Party Services", and each an "Integrated Third-Party Service"). For example, when you send a chat message, in order to generate a response, we share your message with one of our AI providers. The information you share will be subject to the Integrated Third-Party Services' privacy policies. Our AI providers include:
- Anthropic - Powers our primary AI assistant functionalities, subject to Anthropic's Privacy Policy
- OpenAI - Powers speech-to-text transcription and alternative AI models, subject to OpenAI's Privacy Policy
- Google - Powers alternative AI models (Gemini), subject to Google's Privacy Policy
Service Providers. We may share your personal information with our third-party Service Providers. By "Service Providers" we mean companies, agents, contractors, vendors, or others engaged to perform functions on our behalf such as IT support, hosting, payment processing, data storage, customer service, and related services. Service providers include, but are not limited to, analytics services provided by PostHog; account registration and authentication provided by WorkOS; payment processing provided by Stripe, subject to Stripe's Privacy Policy; cloud hosting provided by Vercel and AWS.
Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested.
Corporate Affiliates. We may share your personal information with our corporate affiliates.

B. Sharing to Protect Us or Others

We may access, preserve, and disclose any information we store if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others' rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity.

C. Sharing in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be sold or transferred as part of such a transaction.

4. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email Communications. If you receive a marketing email from us, you may opt-out by using the unsubscribe link at the bottom of such email or by contacting us. You will continue to receive service-related and other non-marketing emails related to the Thoughtful Platform.
"Do Not Track." Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Thoughtful Platform may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications.

Your Privacy Rights. Depending on what laws apply to your personal information, you may have the right to:

Request Access to and Portability of Your Personal Information, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company in a structured, commonly used, and machine readable format (also known as the "right of data portability");
Request Correction of your personal information where it is inaccurate, incomplete, or outdated. In some cases, we may provide self-service tools that enable you to update your personal information;
Request Deletion of your personal information (also known as the "right to be forgotten");
Request Restriction of or Object to our processing of your personal information; and
Withdraw your Consent to our processing of your personal information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

Please contact us using the information below if you would like to exercise any of these rights. We will process your request in accordance with applicable laws.

If your personal information is subject to the applicable data protection laws of the European Economic Area, Switzerland, or the United Kingdom, and you believe our processing of your personal information violates applicable law, you have the right to lodge a complaint with the competent supervisory authority.

5. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

Your personal information is stored and processed in the United States. We are currently undergoing a SOC 2 Type II audit to validate our security controls and practices. We may transfer, process, and store all personal information we collect anywhere in the world. Some countries may have data protection laws that are different from the laws where you live.

If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us as set forth below. Data Processing Agreements are available for enterprise customers upon request at legal@thoughtful.app.

6. HOW LONG WE KEEP PERSONAL INFORMATION

We keep the personal information we collect for as long as you use the Thoughtful Platform, or as necessary to fulfill the purpose(s) for which we collected it. There are also other reasons why we may keep personal information. They may include, but are not limited to, providing the Thoughtful Platform, resolving disputes, establishing legal defenses, conducting audits, pursuing legitimate business purposes, enforcing our agreements, and complying with applicable laws.

To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.

7. SUPPLEMENTAL NOTICE FOR USERS IN CERTAIN REGIONS

A. Supplemental Notice for Nevada Users

If you are a resident of Nevada, you have the right to opt-out of the sale of certain personal information to third parties who intend to license or sell that personal information. You can exercise this right by contacting us at hello@thoughtful.app with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth in Contact Us below.

B. Supplemental Notice for European and UK Users

This Supplemental Notice only applies to our processing of personal information that is subject to the EU or UK GDPR.

Our processing of your personal information may be supported by one or more of the following legal bases:

Performance of a Contract: Lex may need to process your personal information to perform our contract with you, namely the Terms of Service, and for the purposes described in Section 2(A) of this Privacy Policy.
Legitimate Interest: Lex may process your personal information to further our legitimate interests, which include the purposes in Section 2(B) of this Privacy Policy, but only where our interests are not overridden by your interests or fundamental rights and freedoms.
Consent: In some cases, Lex may also rely on your consent to process your personal information.
Compliance with our Legal Obligations: Lex may process your personal information to comply with our legal obligations.

8. CHILDREN

The Thoughtful Platform is not directed to children under 13 years of age (or other age as required by local law outside of the United States). We do not knowingly collect personal information from children. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Thoughtful Platform from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

9. THIRD-PARTY WEBSITES OR APPLICATIONS

The Thoughtful Platform may contain links to other websites or applications and other websites or applications may reference or link to the Thoughtful Platform. We do not control these third-party services. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

10. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in our sole discretion. If we do, we will let you know by posting the updated Privacy Policy on the Thoughtful Platform, and we may also send other communications. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Thoughtful Platform after the new Privacy Policy takes effect.

11. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at hello@thoughtful.app.