Effective date and last update: 31/03/2025
1. INTRODUCTION
The General Counsels’ Association (GCA) is committed to protecting your privacy and ensuring the ethical use of technology in our operations. As an association that values ethics, cooperation, and professionalism, we hold ourselves to the highest standards of data protection and transparency.
This comprehensive policy document outlines in a clear, brief style how we collect, process, and protect your personal data when you interact with our website, apply for membership, participate in our projects, or use our AI-powered tools.
2. PRIVACY POLICY
2.1 Data Controller
General Counsels’ Association (GCA)
Email for Data Protection Inquiries: backoffice[at]generalcounselsassociation[dot]com
2.2 Categories of Personal Data We Process
As an invitation-only professional association, we collect and process only the data necessary to fulfill our purposes:
a) Membership Data:
- Professional details (name, job title, company, professional experience)
- Contact information (email, phone number, business address)
- Information provided during the peer review process
- Areas of legal expertise and professional interests
b) Website Usage Data:
- IP address (as recorded in standard server logs)
- Basic device and browser information
- Pages visited and time of access
- Login information for authenticated users accessing “The GCA Private Spot”
c) AI Tools Usage Data:
- Content submitted to our AI Assistants (e.g. First Drafter, Reviewer, C-Level Brainstormer)
- Translation requests
- Usage patterns of AI-powered tools
d) Event Participation Data:
- Registration information for “Meaningful Coffees” and other GCA events
- Participation in projects (e.g. Pi, Sigma, Epsilon, Zeta)
- Contributions to resources and collaborative documents
2.3 Purposes and Legal Basis for Processing
| Purpose | Description | Legal Basis |
|---|---|---|
| Membership Management | Managing the invitation, peer review, and ongoing membership process | Contract Performance & Legitimate Interest |
| Service Provision | Providing access to GCA resources, projects, and AI tools | Contract Performance |
| Communication | Sending updates about GCA activities, projects, and related legal topics | Legitimate Interest & Consent |
| Website Administration | Ensuring website security and optimal performance | Legitimate Interest |
| Improvement of Services | Analyzing usage to enhance our offerings | Legitimate Interest |
| Legal Compliance | Fulfilling legal obligations and establishing legal claims | Legal Obligation |
2.4 Data Retention
We retain personal data only for as long as necessary to fulfill the purposes for which it was collected:
- Membership data: For the duration of membership plus 2 years for legal and historical purposes
- Website usage data: 1 year from collection
- AI tools usage data: 1 year from last usage
- Event participation data: 1 year year from the event
2.5 Data Recipients and Transfers
Your personal data may be accessed by:
- Authorized GCA staff and board members
- Peer reviewers (only for membership application evaluation)
- IT service providers who support our website and AI tools
- Cloud service providers who host our digital infrastructure
We ensure all third-party service providers are bound by appropriate data protection agreements. If data transfers outside the EEA occur, we implement suitable safeguards in accordance with GDPR requirements.
2.6 Your Rights
As a data subject, you have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase your data (where legally permissible)
- Restrict or object to processing
- Data portability
- Withdraw consent at any time
To exercise these rights, contact us at [Insert Email]. You also have the right to lodge a complaint with the Garante per la Protezione dei Dati Personali (www.garanteprivacy.it).
3. COOKIE POLICY
3.1 What Are Cookies
Cookies are small text files placed on your device when you visit our website. They help us provide you with a better browsing experience and allow us to improve our site.
3.2 Cookies We Use
| Cookie Type | Purpose | Duration |
|---|---|---|
| Essential Cookies | Enable core functionality such as security, account authentication, and website preferences | Session to 1 year |
| Analytics Cookies | Help us understand how visitors interact with our website by collecting anonymous information | Up to 2 years |
| Functional Cookies | Recognize you when you return to our website and enable personalized features | Up to 1 year |
3.3 Third-Party Cookies
Our website may use services that set third-party cookies:
- WordPress (website platform)
3.4 Managing Cookies
You can control cookies through your browser settings:
- For Chrome: chrome://settings/cookies
- For Firefox: about:preferences#privacy
- For Safari: Preferences > Privacy
- For Edge: Settings > Site permissions > Cookies
Refusing cookies may impact your experience of our website and limit access to certain features, particularly in “The GCA Private Spot” section.
4. AI POLICY
4.1 Our AI Services
The GCA provides members with access to AI-powered tools:
- First Drafter: Assists in drafting initial legal documents
- Reviewer: Provides analysis and suggestions for existing documents
- C-Level Brainstormer: Generates ideas and perspectives for executive-level discussions
- Translator: Facilitates multilingual communication (not AI-based)
4.2 Data Processing in AI Tools
When using our AI tools, please be aware that:
- Content submitted to our AI tools is processed to generate the requested output
- We implement technical safeguards to protect confidential information
- We use industry-leading AI technologies with appropriate data protection measures
- Human oversight might be implemented for quality assurance purposes and for compliance review
4.3 Ethical AI Use Principles
Our AI usage adheres to the following ethical principles:
- Transparency: We clearly disclose AI use in our services
- Accountability: Human oversight ensures the quality and appropriateness of AI outputs
- Data Minimization: We process only necessary data for the intended purpose
- Accuracy: We strive for accurate AI outputs while acknowledging limitations
- Legal Compliance: Our AI usage complies with relevant laws and professional standards in accordance with the terms and conditions set forth by the service providers, as specifically detailed in the webpage hosting each tool
4.4 Member Responsibilities
When using GCA AI tools, members should:
- Use AI and translation tools for generic use, not inputting data containing personal, corporate or other sensitive data, ss specifically instructed in the webpage of each tool,
- Review AI-generated content before using it professionally
- Report any concerns about AI outputs to backoffice[at]generalcounselsassociation[dot]com
- Use AI tools as assistive resources rather than replacements for professional judgment
4.5 Limitations and Disclaimers
- AI-generated content may contain errors or inaccuracies
- GCA AI tools are designed to assist, not replace, professional legal analysis
- The GCA is not responsible for decisions made based on AI-generated content
5. LEGAL TERMS
5.1 Membership Terms
- GCA membership is by invitation only, based on peer review
- Membership approval is at the sole discretion of the GCA
- Members must adhere to the GCA’s ethic code
- The GCA reserves the right to terminate membership for violation of these values
5.2 Intellectual Property
- Content created through collaborative GCA projects remains the intellectual property of the GCA
- Members retain intellectual property rights to their individual contributions, while granting the GCA a non-exclusive license to use such contributions for association purposes
- The GCA website, logo, and branding materials are protected by copyright law
5.3 Confidentiality
- Members agree to maintain the confidentiality of information shared within the GCA
- Discussions during “Meaningful Coffees” and project collaborations are considered confidential; members are strictly prohibited from sharing or discussing competitively sensitive information including, but not limited to, pricing strategies, market allocation plans, non-public business strategies, bidding intentions, or any other information that could have anti-competitive effects or violate antitrust regulations; all members must ensure full compliance with competition law during all GCA activities
- The GCA implements appropriate measures to protect confidential information shared on its platforms
5.4 Limitations and Disclaimers for AI Tools
4.5.1 Nature and Limitations of AI Technology
- The AI tools provided by GCA utilize machine learning technology which, despite ongoing advancements, has inherent limitations in understanding legal nuance, legal hyerarchy and succession la laws and regulations, jurisdictional distinctions, and evolving jurisprudence.
- AI-generated content may contain errors, omissions, inaccuracies, or outdated legal references, and may not account for recent legislative changes or case law developments.
- The quality of output depends significantly on the quality and specificity of input provided by the user.
- AI systems may exhibit unintended biases or limitations based on their training data.
5.4.2 Professional Responsibility
- Members expressly acknowledge that AI-generated content constitutes preliminary assistance only and does not constitute legal advice or a substitute for professional legal judgment.
- All AI-generated content must be thoroughly reviewed, verified, and validated by qualified legal professionals before any professional or client use.
- Members remain solely responsible for their professional duties, ethical obligations, and the accuracy of any documents or advice ultimately provided in their professional capacity.
- Use of GCA AI tools does not alter members’ obligations under applicable codes of professional conduct and legal practice regulations.
5.4.3 Liability Disclaimer
- The GCA provides AI tools on an “as-is” and “as-available” basis without warranties of any kind, either express or implied.
- The GCA expressly disclaims all liability for any direct, indirect, incidental, special, exemplary, or consequential damages arising from the use of AI-generated content.
- Members agree to indemnify and hold harmless the GCA against any claims, damages, or liabilities arising from their use of AI-generated content in professional practice.
- The GCA does not guarantee the continuous availability or error-free operation of AI tools and reserves the right to modify or discontinue these services at any time.
5.4.4 Confidentiality and Data Security
- While the GCA implements reasonable security measures for AI systems, members should exercise caution when inputting sensitive or confidential information.
- Members should anonymize or pseudonymize client-specific information when using AI tools to avoid potential confidentiality breaches.
- The GCA cannot guarantee absolute confidentiality of information processed through third-party AI systems and recommends appropriate discretion.
5.5 Governing Law and Jurisdiction
These terms are governed by Italian law. Any disputes shall be subject to the exclusive jurisdiction of the courts of Milan.
5.6 Changes to Terms
The GCA reserves the right to modify these terms. Members will be notified of significant changes through their registered email address.