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Privacy and data protection

Last updated 8 September 2026. This policy describes what the platform actually does today. It is reviewed by independent counsel, and it is updated here whenever the platform changes — not afterwards.

Two kinds of reader arrive on this page. A buyer wants to know what happens to the passport scan and the title deed they are about to upload. A partner law firm wants to know, before it puts a client file on someone else's infrastructure, who controls that file, who can read it, where it is held, what the software does to it and what happens on the day the relationship ends. This policy is written to answer both, in that order, without sending anyone to a separate document.

It covers the Suradeed website and the Suradeed platform — the client portal, the partner portal and the administration surface — and the processing carried out under the General Data Protection Regulation (EU) 2016/679 and, for the work performed in Thailand, the Personal Data Protection Act B.E. 2562.

The short version#

1Who is responsible for your data#

The controller is AI Mentors, a French société par actions simplifiée registered at the R.C.S. Bordeaux under SIREN 937 752 921, whose registered office is Bâtiment A1, 4 rue Robert Caumont, 33300 Bordeaux, France, trading as Suradeed. It is the entity named at the head of your quote and on your invoice, and in the legal notice on this site. Because the controller is established in France, the GDPR applies to this processing directly, and the French supervisory authority — the CNIL — supervises it.

The partner law firm engaged on your dossier is a separate controller for the legal work it performs and signs. It is not our processor: it owes you its own professional duties under Thai law, it is answerable to its own professional body, and it decides what its file must contain. We describe in section 6 what it receives and on what terms.

There is one point of contact for everything in this policy — contact@suradeed.com — and it is the address your dossier correspondence already comes from, so you can verify who is replying to you.

2What we collect, and why#

Everything below is collected because the service cannot be delivered without it. We do not build profiles, we do not advertise to you, and we do not sell data.

When you ask for a price

  • your name, email address, country and preferred language;
  • what you tell us about the property: a label, the property type, the ownership route, the title grade, the region, an address or area, an optional listing link and an optional indicative purchase price.

Those property answers are the ones the published price grid is applied to. You are asked to confirm they are accurate because the fixed price depends on them.

When you pay

  • the payment session identifier, the amount, the currency and whether the payment was live or a test;
  • the version and digest of the disclosure you acknowledged before paying.

We never see or store your card number. The payment page is operated by Stripe and card details are entered there, not here.

While the verification runs

  • the documents you upload, and the result of the malware scan run on each one;
  • the data read out of those documents so the report can be built — title and parcel identifiers, registered rights and encumbrances, permits, areas, names appearing on the deed;
  • messages exchanged about the dossier;
  • an audit trail of the actions taken on the dossier, kept so that who did what, and when, can be established later.

A verification file will normally contain identity documents and, through the title deed, the names of third parties — the seller, a co-owner, a nominee, a lender. Those people are data subjects too, and this policy applies to them. Where the deed reveals nationality, that is a special category of data under the GDPR; we hold it because the verification is precisely a check on whether a foreign national may hold that right, and we hold it on the basis set out in section 3.

Because you have an account

  • sign-in sessions, including the IP address and browser reported at sign-in, kept so a session can be recognised and revoked;
  • for staff and partner accounts, the second-factor enrolment and the devices you have marked as trusted.

If you are a law firm applying to the partner programme

  • the firm's name, province, website and licence details;
  • the name, role and work email address of the person applying;
  • what you tell us about capacity and areas of practice.

When you choose the public Chanote reader

When this optional reader is enabled, you select a PDF, PNG or JPEG and explicitly agree to send its normalized page images to Google Cloud Vision API or Google Gemini, as named on the page before you consent, for document reading. Selection and PDF preparation happen in your browser; choosing a file does not itself send it to Google. The service shows text and proposed fields for you to check, without opening a dossier. We keep limited pseudonymous abuse-prevention metadata, described in section 8.

When you simply read the site

  • Cloudflare's network logs, kept to keep the site available and to stop abuse;
  • the measurement described in section 12 — the part that sets nothing in your browser runs always; Meta's advertising measurement runs only if you accept the consent banner, and your choice itself is kept in one cookie so you are not asked again.

3Why we are allowed to process it#

  • Performance of your contract, for everything needed to scope, price, route, carry out and deliver the verification, and to give you access to your dossier.
  • Our legitimate interest in keeping the platform secure and available: the malware scan on uploads, the audit trail, rate limiting, and error monitoring. Also our legitimate interest in reaching law firms about the partner programme, and in answering a business enquiry you send us.
  • A legal obligation, for invoicing, accounting records and any anti-money- laundering or tax duty that applies to the transaction.
  • The establishment or defence of legal claims, for the retained file — and this is also the ground on which the file may contain nationality and other special-category data, under Article 9(2)(f) GDPR, alongside the substantial public interest in verifying title.
  • Consent, for the optional public Chanote reading and its image transfer to the disclosed Google reader, and where you give it — a marketing email, an optional field you choose to complete, or the Meta advertising measurement described in section 12. You can withdraw it at any time and it costs you nothing.

For the personal data of third parties who appear in a title deed, our ground is the same legitimate interest that the verification itself serves: a buyer cannot be told whether a right is safe without reading who holds it. We collect no more of it than the deed already states.

4What the software does with documents, including artificial intelligence#

This section exists because it is the first question a law firm asks, and it deserves a straight answer.

Documents are read by machine before a person reads them. When you upload a title deed, a permit or a company extract, the platform sends the pages to a model that reads them and returns structured fields — title number, parcel, area, registered rights, encumbrances, dates. The same pipeline produces a draft translation of report blocks between Thai, English and French. The providers are named in section 5.

Four things are true about it, and they are the four that matter:

  • No decision is made by the model. The extraction is a first draft of the data entry. Every field is shown to the lawyer handling the dossier, who corrects it against the document. The legal conclusion and the signature are the firm's, always.
  • The providers process on our instructions only. Each is engaged under a data processing agreement that forbids using the content of a document to train or improve a model, and forbids any other use of it.
  • Nothing is fed back into a shared model. Your documents do not become part of anything another customer can reach.
  • You can decline it. If you or your law firm would rather no document be read by machine, write to contact@suradeed.com when the dossier opens and the dossier is handled with manual data entry instead. It is slower; it changes nothing else.

Documents are also scanned for malware on upload and quarantined until they pass. That scan is structural and signature-based; it reads the file to decide whether it is safe, and reads nothing into a report.

The public Chanote reader is a separate optional service. It sends only the submitted normalized page images to the Google reader named on the page after your explicit agreement and a security check. Its text and proposed fields are transient unless you explicitly submit the separate contribution form after analysis. No dossier is opened by this reading. You can clear the result in the page. Uncertain proposals are labelled; missing or unsupported values stay empty. These are reading proposals, not verified facts, and a partner lawyer performs the legal verification. This reading performs no Land Office search and provides neither title verification nor legal advice. Stopping a request prevents further processing where possible but cannot retract an image already transmitted. Google's processing arrangements must be reviewed before this service is activated; this description is not a guarantee of a particular provider retention period.

5Who else sees it#

The partner law firm engaged on your dossier sees the dossier and its documents. That is the point of the service, and section 6 describes the terms.

Our processors, who act only on our instructions and under a data processing agreement:

  • Cloudflare, Inc. (United States) — hosting, database, document storage, network protection and PDF rendering;
  • Stripe — payment processing. Stripe is an independent controller for its own fraud and regulatory duties;
  • Resend — transactional email, including your sign-in links;
  • Anthropic PBC (United States) — the document reading and translation described in section 4;
  • Cloudflare Workers AI — the same, for report translation;
  • Sentry — error monitoring, configured so that personal data is not sent with an error: request bodies, headers and cookies are stripped before an event leaves the platform;
  • Google Analytics — analytics of the public marketing pages only, in consent mode with every purpose denied. It never loads on the client, partner or administration surfaces, so nothing you type, upload or store can reach it.

Google Cloud Vision API or Google Gemini, according to the reader disclosed on the page, receives the page images you explicitly submit to the optional public Chanote reader. This is a separate purpose from Google Analytics; refusing marketing cookies does not authorize or prevent a reading. Cloudflare Turnstile supplies its security check. Neither service receives dossier documents through this public reader.

Meta Platforms Ireland Limited receives the advertising measurement described in section 12 — only after you accept the consent banner, and never from the signed-in surfaces. Identifiers used for matching are hashed before they leave the platform. For its own advertising services Meta acts as an independent controller under its own notice.

We may also disclose data to a public authority where the law requires it, and to our professional advisers — counsel, accountants, insurers — under their own duties of confidentiality. If the business were ever sold or restructured, a buyer would receive the data under the same undertakings; you would be told before that happened.

We do not sell your data. Nothing is shared for advertising without your consent, and what is shared when you give it is exactly what section 12 describes. No processor is permitted to use your data for its own purposes.

6Partner law firms: the terms your file travels under#

A firm considering the platform is entitled to know the answers before it registers, so they are stated here rather than on request.

  • The firm keeps its file. The firm is a separate controller, not our processor. Nothing in the platform gives Suradeed authorship of, or rights over, the firm's legal work or its professional file.
  • Access is by dossier, decided by role. A partner account sees the dossiers routed to that firm and nothing else. It cannot browse other firms' work, other clients, or the platform's client base.
  • Every action is recorded. Views, downloads, edits, status changes and messages are written to an audit trail the firm can be shown. If a question is ever raised about who saw a document, the answer is in the record rather than in anyone's recollection.
  • Confidentiality is contractual, not implied. The partner agreement binds Suradeed to the confidentiality of the firm's files, and binds the firm to the confidentiality of the client's, with the professional secrecy duties under Thai law preserved in full and unaffected by anything in the platform.
  • Exit is provided for. On termination, the firm can export the dossiers it handled, with their documents and their audit trail, in a readable format. Suradeed retains what it must under section 8 and nothing more.
  • Your own staff data. Names, work email addresses, roles and sign-in records of the firm's users are processed to operate the accounts and for no other purpose. They are not used for marketing to the firm's people individually.
  • Sub-processor changes are notified. If we add or replace a processor that touches dossier content, registered partner firms are told before it takes effect.

A firm that needs a signed data processing agreement, a security questionnaire completed, or a copy of the audit trail specification should write to contact@suradeed.com. These are ordinary requests and they are answered.

7Where it goes, and the basis for sending it there#

The platform runs on Cloudflare's global network, and the providers named in section 5 are established in the United States or serve it from there.

The partner law firm is in Thailand, so a dossier concerning an EU resident is read there. Thailand has not been the subject of an adequacy decision by the European Commission. That transfer happens at your request and is necessary to perform the contract you asked for: a Thai property can only be verified by a lawyer licensed in Thailand, and no arrangement between us and that lawyer could change it. It rests on Article 49(1)(b) GDPR, and it is additionally covered by the confidentiality undertakings in the partner agreement described in section 6.

For our processors, transfers outside the EEA are covered by the safeguards in each data processing agreement — the European Commission's standard contractual clauses, or, where the provider is certified, the EU–US Data Privacy Framework. The same safeguards cover the consented advertising measurement of section 12: data sent to Meta may be processed in the United States under the EU–US Data Privacy Framework, to which Meta Platforms, Inc. is certified, alongside the standard contractual clauses in Meta's transfer terms.

In the other direction: where the Thai Personal Data Protection Act applies to the firm's processing, the firm gives its own notice under that Act, and the rights it confers are exercised with the firm. Where both laws apply to the same file, we apply the stricter of the two rather than the more convenient.

8How long we keep it#

  • Public Chanote reader: images, recognized text, proposals and your corrections are not retained after the request/browser session unless you explicitly opt into the separate contribution described below. Admission metadata — hashed network/session/job identifiers, page counts, timestamps and lease state — expires after 48 hours and is deleted in bounded scheduled cleanup. A delayed cleanup can extend physical retention beyond that expiry. These are pseudonymous identifiers, not anonymous data. Short request-throttle counters expire with their ten-minute window and use the existing cleanup process. No document content or document hash is stored in these records. This public service does not fall under the ten-year dossier retention period.
  • The verification file and its documents: ten years from delivery. That is a deliberate commercial promise, stated on your receipt — a certificate is worth little if the file behind it has been deleted by the time anyone questions it. The period matches the horizon over which a title dispute realistically surfaces.
  • Invoices and accounting records: ten years, which French commercial law requires.
  • Quote requests that never become a dossier: twenty-four months, then deleted or anonymised.
  • Partner applications that do not lead to a partnership: twenty-four months.
  • Sign-in sessions and their IP records: thirteen months.
  • The dossier audit trail: for the life of the file, because its whole purpose is to be readable later.
  • Chanote email submission: 30 days without marketing permission; with a separate marketing opt-in, up to three years from collection. When you explicitly request a PDF reading, we send a generic verification code before attaching documents. The code expires after ten minutes and five attempts. The provisional PDF includes passive copies of the pages used for your reading. A temporary PDF and delivery state are retained for no longer than the one-hour reading receipt to allow identical retries, then queued for deletion by the fifteen-minute sweep. This transactional purpose is independent of marketing and optional OCR contribution. Withdrawal prevents pending sends; email already accepted by the provider cannot be recalled.
  • Optional Chanote OCR contribution: original files (including pages not read), prepared page images, reading data and the generated provisional reading summary are retained privately for twelve months. They are linked to the submitted email while that email is retained. Permission is separate from reading and marketing. Platform administrators alone may review them for internal/offline OCR evaluation; this does not authorize additional AI processors, model training, public examples or marketing use of documents. Original uploads must pass document safety checks before access. Expiry and withdrawal close access immediately; scheduled, retryable cleanup removes associated files. A failed storage attempt can leave inaccessible partial objects until cleanup succeeds.
  • Withdrawal receipt: keep the private receipt supplied after submission. Submit it through the Chanote withdrawal form to withdraw that submission’s permissions and remove its email and files; contact us if you lose it. No receipt is placed in a URL. A minimal replay-prevention tombstone may remain until the original one-hour admission receipt expires.
  • Backups: forty days, on a rolling schedule. A record erased from the live platform disappears from the backups as they expire.

9How we keep it safe#

  • Documents are scanned for malware on upload and quarantined until they pass.
  • Access is decided by role, per dossier, and is refused by default. Every action on a dossier is written to an audit trail.
  • Sign-in is by one-time link. Staff and partner accounts additionally require a second factor, with recovery codes and an explicit list of trusted devices; a password policy and rate limiting apply on every sign-in surface.
  • Data is encrypted in transit (TLS, enforced site-wide) and at rest on Cloudflare's storage. Financial values carry an additional application-level envelope, AES-256-GCM, so that a database dump does not yield them.
  • Error reports carry no personal data. Request bodies, headers, cookies and file paths are stripped before an event is sent to our monitoring provider.
  • Links to a dossier are signed and expire. A document URL cannot be guessed, shared indefinitely or reused after it lapses.
  • Changes are tested before they ship. The platform's test suite includes checks that a handler cannot serve tenant data without first resolving who is asking — a guard against exactly the class of bug that leaks one client's file to another.

If you believe you have found a vulnerability, write to contact@suradeed.com. We would rather hear it from you than from anyone else, and we do not treat a good-faith report as an attack.

If a breach occurs that is likely to result in a risk to your rights, we notify the CNIL within 72 hours of becoming aware of it, and we tell you directly where the risk is high. The partner firm has its own duty under the Thai Act and we coordinate with it rather than around it.

10Your rights, and how to use them#

You can ask for access to your data, correction of it, erasure, restriction of processing, and portability of what you gave us. You can object to processing based on legitimate interest. Where processing rests on consent, you can withdraw it at any time, without affecting what was lawful before.

Write to contact@suradeed.com. We answer within one month, and tell you if a complex request needs longer. There is no charge.

How erasure works here, concretely: your name and contact details are removed from our records and your account is closed; documents you uploaded yourself are deleted from storage on your confirmed request. What an erasure cannot reach, and why:

  • the verification file itself — the firm's evidence, findings and the signed certificate — is kept for the ten-year period, because it is the legal record your certificate rests on;
  • what we must keep to invoice you, to meet accounting duties, or to defend a claim;
  • routine encrypted backups, which expire on the forty-day schedule above;
  • the partner firm decides what its own professional file must contain, and those requests are made to the firm. We will tell you which firm, and give you its contact, the same day you ask.

Under the Thai Personal Data Protection Act the same rights exist in substantially the same form, and a request made to us about processing carried out in Thailand is passed to the firm and tracked until it is answered.

11Automated decisions and profiling#

The price you are offered follows a published grid applied to the facts you declare. It is a rule, not a profile, and it produces one of two outcomes: a fixed price, or a review by a person. Nothing about you is inferred and nothing is scored.

The document reading described in section 4 produces data, not decisions. There is no automated decision producing legal or similarly significant effects within the meaning of Article 22 GDPR — no verification outcome, no risk rating and no refusal is ever generated without a lawyer.

12Cookies and measurement#

The site sets the cookies needed to keep you signed in and to keep the service secure, plus one six-month cookie — sd_consent — that records the choice you make on the consent banner, a refusal included, so you are not asked again.

The public Chanote reader also uses a one-hour signed sd-ocr security cookie, with HttpOnly and SameSite=Strict protection (Secure on HTTPS). It identifies an anonymous reading session for abuse protection, not advertising or cross-site profiling. Cloudflare Turnstile verifies the security challenge before a reading. No OCR result is written to browser local storage.

We measure how the public pages are used. Cloudflare Web Analytics counts page views and page-speed measurements: it sets no cookie, stores nothing in your browser, builds no profile and cannot follow you to another site. The public pages also load Google Analytics 4 in consent mode with every purpose denied — no cookie is set, no advertising feature runs, and it never loads on the client, partner or administration surfaces, so nothing you type, upload or store is ever sent to it. Those two run with nothing stored in your browser, so there is nothing about them to consent to.

Meta advertising measurement runs only if you accept the banner. If you do, the Meta pixel loads on the public pages and sets the _fbp and _fbc cookies, and the platform sends Meta the same events from its own servers so a paid visit can be connected to what it led to — a request, an application, a payment. Identifiers used for matching, such as an email address, are hashed before they are sent; Meta receives no document, no dossier content and nothing from the signed-in surfaces, where none of this ever loads. If you decline, none of it runs — no pixel in your browser and no event from our servers. You can change your choice at any time with the cookie preferences control at the end of this page; withdrawing consent stops the sending from that moment.

Your browser's own controls remain yours: blocking cookies will end a signed-in session; blocking Meta's domains breaks nothing but that measurement.

13Marketing, and how to stop it#

We send service messages — a quote, a receipt, a sign-in link, a dossier update — because they are part of the contract. They cannot be unsubscribed from while a dossier is open, and they contain no marketing.

We send commercial email only to business contacts about the partner programme, or to people who asked for it. Every such message carries an unsubscribe link that works on the first click, and you can also write to contact@suradeed.com. We do not use your dossier content to decide what to send you.

Our advertising on third-party platforms is bought against audiences those platforms define — an interest, a location, a job description. We do not upload client lists to them. Where you have accepted the consent banner, the measurement described in section 12 also lets those platforms build audiences of people who visited these pages; declining the banner keeps you out of that entirely.

14Other points worth knowing#

  • If you withhold data, we may be unable to price, route or complete a verification. We will say so rather than proceed on a guess.
  • We do not respond to do-not-track browser signals. The only cross-site measurement here is the consented Meta measurement of section 12, and the banner — not a browser signal — is what controls it.
  • Links to other sites — a land office, a registry, a listing — are outside this policy, and their operators answer for them.
  • The platform is not directed at children and we do not knowingly collect data from anyone under 18. A minor appearing on a title deed is data we hold about the property, not a user account.
  • We do not reuse dossier documents to develop the product. An optional public Chanote contribution has the separate internal OCR evaluation purpose described in section 8. A visitor’s permission does not remove the rights of third parties named in a deed; rights requests remain available through section 16. Screenshots and examples used in marketing come from a dossier prepared for that purpose, with the client's agreement, or are redacted beyond recovery.

15Changes to this policy#

The current version is always the one on this page, with its date at the top. When something material changes — a new processor with access to dossier content, a new purpose, a shorter or longer retention period — we say so here and we tell clients with an open dossier and registered partner firms directly. We do not change this policy retroactively to cover something already done.

16How to reach us, and how to complain#

For any privacy request — access, correction, erasure, an objection, or a question about this policy — write to contact@suradeed.com, or by post to AI Mentors, Bâtiment A1, 4 rue Robert Caumont, 33300 Bordeaux, France.

If our answer does not satisfy you, you can complain to a supervisory authority:

  • in France, the CNIL — 3 place de Fontenoy, TSA 80715, 75334 Paris CEDEX 07 — cnil.fr;
  • in any other EU or EEA country, the authority where you live or work;
  • in Thailand, the Personal Data Protection Committee — pdpc.or.th;
  • about the legal work itself, the partner firm's professional body. We will identify the firm, provide your file, and support you in raising it.