Privacy Policy

Invictus Counsel, PLLC
An Affiliated Law Firm of Invictus AI Corporation
Effective Date: October 9, 2026

IMPORTANT: This Privacy Policy applies to invictuscounsel.com and to the legal services Invictus Counsel provides through the Verena™ platform. Invictus Counsel, PLLC is a licensed law firm subject to attorney-client confidentiality obligations that go beyond standard commercial privacy law. Please read this Policy in its entirety, as it governs both website visitors and clients of the Firm.

1. About Invictus Counsel

Invictus Counsel, PLLC ("Firm," "IC," "we," "our," or "us") is a professional limited liability company organized under the laws of the State of Arizona and a licensed law firm. We are an affiliated law firm of Invictus AI Corporation ("IAI") and provide AI-assisted legal services supervised by licensed attorneys. Our attorneys are licensed in the States of Arizona and California and in applicable areas of federal law.

Because we are a licensed law firm, our handling of client information is governed not only by applicable privacy law but also by professional responsibility rules, including Arizona ER 1.6 and California RPC 1.6 (attorney-client confidentiality). In the event of any conflict between this Privacy Policy and our professional responsibility obligations, our professional responsibility obligations prevail.

2. Scope: Website Visitors and Clients

This Privacy Policy covers two distinct groups of individuals with different relationships to Invictus Counsel.

2.1 Website Visitors (Pre-Engagement)

Individuals who visit invictuscounsel.com, submit contact inquiries, or otherwise interact with our website before a formal attorney-client relationship is established. Website visitors are not clients of the Firm. Communications before formal engagement do not create an attorney-client relationship and are not protected by attorney-client privilege.

IMPORTANT: Do not transmit sensitive, confidential, or legally sensitive information through general contact forms or unsolicited inquiries before a formal attorney-client relationship has been established.

2.2 Clients (Post-Engagement)

Individuals and entities whose Legal Services Agreement has been signed by the client and countersigned by the Firm. Once the Legal Services Agreement is countersigned, the full attorney-client relationship exists, including all duties of confidentiality and loyalty required by applicable rules of professional conduct. Client information is governed both by this Privacy Policy and by the attorney-client confidentiality framework in Section 5.

3. Information We Collect

3.1 From Website Visitors

When you visit invictuscounsel.com, we may collect:

Contact information submitted through inquiry forms (name, email, phone number, company);
Technical data such as IP address, browser type, device identifiers, and referral URLs;
Usage data about how you interact with our website;
Cookie and tracking data as described in Section 9 and in our Cookie Policy.

3.2 From Clients

When you engage the Firm for legal services, we collect and process:

Personal identification and contact information (name, address, email, phone, company details);
Information about your legal matter, including facts, documents, correspondence, and communications you share in the course of your representation;
Financial and billing information for processing plan and credit charges;
Platform usage data relating to your interaction with Verena™;
Technical data from your devices and browsers.

Client matter information is subject to the heightened confidentiality protections described in Section 5 and is not treated as ordinary commercial data.

4. How We Use Information

4.1 Website Visitor Data

We use information collected from website visitors to respond to inquiries and assess whether we can establish an attorney-client relationship; to conduct conflict-of-interest checks before accepting an engagement; to operate and improve the invictuscounsel.com website; to measure and, with your consent, personalize our marketing as described in Section 9; and to comply with applicable legal and regulatory obligations.

4.2 Client Data

We use client information to provide and administer legal services under our Legal Services Agreement; to supervise Verena™ workflows; to maintain client files and records as required by professional responsibility rules; to process billing and plan charges; to communicate with clients about their matters and the status of their representation; and to comply with legal and ethical obligations.

We do not use client matter data for marketing, product promotion, or any purpose unrelated to providing legal services.

5. Attorney-Client Privilege and Confidentiality

5.1 Duty of Confidentiality

Consistent with Arizona ER 1.6 and California RPC 1.6, we maintain strict confidentiality of all information relating to a client's representation. We will not disclose information relating to your representation without your informed consent, except as permitted or required by applicable law or professional responsibility rules (for example, to prevent reasonably certain death or substantial bodily harm, or as required by court order).

5.2 Attorney-Client Privilege

Communications between you and the Firm's licensed attorneys made in confidence for the purpose of obtaining or providing legal advice are protected by the attorney-client privilege. This privilege belongs to you as the client and may be waived only by you. Once your Legal Services Agreement is countersigned, communications with and through the Verena™ platform that are part of the attorney-client relationship are treated as confidential communications subject to attorney supervision and the Firm's duty of confidentiality.

5.3 Limitations on Privilege

Attorney-client privilege and the duty of confidentiality do not protect: (i) communications made in furtherance of a crime or fraud (the crime-fraud exception); (ii) information shared with third parties outside the scope of the representation; or (iii) information shared before the attorney-client relationship is formally established. These limitations apply broadly under applicable law.

6. Verena™ and Data Flows Between IC and Invictus AI Corporation

Invictus Counsel uses the Verena™ AI platform, developed and operated by Invictus AI Corporation ("IAI"), to assist attorneys in delivering legal services. Client information may be processed by Verena™ to support attorney-supervised legal work. The following protections govern all data flows between IC and IAI:

Minimum Necessary: IAI receives only the client data necessary to perform the specific platform functions required by your plan.
Purpose Limitation: Client data processed through Verena™ may not be used for any purpose other than delivering the platform services specified in your plan.
No Commercial Sharing: IAI may not sell, license, or share client data for any commercial purpose.
AI Training Limited to De-identified Data: Your identifiable data, matter information, and confidential communications are not used to train AI models without your explicit written opt-in. Only aggregated, de-identified operational data may be used to improve the Verena™ platform.
Encryption: All data processed by Verena™ is encrypted in transit and at rest in accordance with IC's data security policies.

7. Information Sharing

We do not sell client information. We do not share client matter data for marketing, commercial, or research purposes. We may share information only in the following limited circumstances.

7.1 Within the Firm

Client information may be shared within Invictus Counsel with attorneys, paralegals, and authorized support staff who have a need to know in connection with your representation. All such individuals are bound by the Firm's confidentiality obligations.

7.2 Invictus AI Corporation (Verena™ Platform)

Limited client data may be shared with IAI solely to operate the Verena™ platform in connection with your plan, subject to all protections described in Section 6.

7.3 Third-Party Service Providers

We may engage third-party service providers for cloud hosting, payment processing, platform infrastructure, website analytics, and advertising measurement. These providers may only use your data as necessary to provide services to us and are subject to appropriate confidentiality and data protection obligations. Analytics and advertising providers receive website visitor data only, never client matter data, and only as described in our Cookie Policy.

7.4 Legal and Professional Obligations

We may disclose information where required by applicable law, court order, legal process, or applicable professional responsibility rules, including mandatory reporting obligations. Where permitted by law, we will notify you of any such disclosure.

7.5 Business Transactions

In connection with a transfer of the Firm's business, client files may be transferred to a successor law firm, subject to applicable bar rules and client notification requirements. We will provide advance notice to clients as required by professional responsibility rules.

8. Data Retention

Invictus Counsel retains client files and engagement records for the period required by applicable professional responsibility rules across our covered jurisdictions.

Minimum Retention Period: Seven (7) years following termination or conclusion of the engagement. This incorporates the longest applicable requirement across our covered jurisdictions (Arizona, California) and applicable federal IRS and regulatory record-keeping standards.

During the retention period, client files are stored securely consistent with ongoing confidentiality obligations. After the retention period expires, files are destroyed in a manner that protects confidentiality. Clients may request a copy of their file at any time.

Website visitor data (excluding client matter information) is retained only as long as necessary for the purposes described in this Policy, typically no more than 24 months.

9. Cookies and Website Analytics

The invictuscounsel.com website uses cookies and similar tracking technologies in four categories:

Necessary Cookies: Required for the website and platform to function. These cannot be disabled without impairing functionality.
Functional Cookies: Remember your preferences and settings. Set only with your consent.
Analytics Cookies: Help us understand how visitors use the website. Set only with your consent.
Marketing / Advertising Cookies: Used by third-party advertising providers to measure and target our marketing, including retargeting. Set only with your consent.

No cookies other than Necessary cookies are set until you opt in through our cookie banner. You can change or withdraw your consent at any time using the Cookie Preferences link in the website footer. Our Cookie Policy, available at invictuscounsel.com/cookies, lists the providers we use and explains how to manage your choices.

10. International Data Transfers

Invictus Counsel processes data primarily in the United States. For clients in the European Economic Area or United Kingdom, we rely on appropriate transfer mechanisms, including Standard Contractual Clauses, for any transfers of personal data. You may request information about our transfer mechanisms by contacting privacy@invictuscounsel.com.

11. Your Privacy Rights

Depending on your location and the nature of your relationship with us, you may have the following rights.

11.1 General Rights

Access: Request confirmation of whether we hold personal information about you and obtain a copy.
Correction: Request correction of inaccurate or incomplete personal information.
Deletion: Request deletion of personal information, subject to our professional responsibility obligations to retain client files for the mandatory retention period.

11.2 EEA/UK Residents (GDPR)

Data Portability: Receive your personal data in a structured, machine-readable format.
Restriction of Processing: Request restriction of processing in certain circumstances.
Objection: Object to processing based on legitimate interests.
Withdrawal of Consent: Withdraw consent to Functional, Analytics, or Marketing cookies at any time.
Complaint: Lodge a complaint with your local data protection authority.

Our lawful bases for processing include: performance of our Legal Services Agreement; compliance with legal obligations (including professional responsibility rules); your consent (for non-Necessary cookies); and our legitimate interests in operating the Firm securely and effectively.

11.3 California Residents (CCPA/CPRA)

California residents have the right to: (i) know what personal information is collected, used, and shared; (ii) request deletion (subject to professional responsibility retention obligations); (iii) correct inaccurate personal information; (iv) opt out of the sharing of personal information for cross-context behavioral advertising; and (v) non-discrimination for exercising these rights. We do not sell personal information. If you consent to Marketing / Advertising cookies, website visitor information may be shared with advertising providers for cross-context behavioral advertising. You may opt out at any time through the Cookie Preferences link in the website footer or by contacting us. Client matter data is never shared for advertising.

11.4 Submitting Requests

To exercise any privacy right, contact privacy@invictuscounsel.com. We will respond within timeframes required by applicable law. Requests for deletion of client matter files may be limited by our professional responsibility obligations to retain those files for the mandatory period in Section 8.

12. Data Security

We implement technical and organizational measures appropriate to the sensitivity of the information we hold, including encryption of data in transit and at rest, access controls and multi-factor authentication, regular security assessments and monitoring, and training for all personnel with access to client information. In the event of a security incident affecting client confidential information, we will notify affected clients as required by applicable law and professional responsibility rules.

13. Third-Party Links

This website may contain links to third-party websites for informational purposes. We do not endorse and are not responsible for the content, accuracy, or privacy practices of any third-party website. Links do not constitute a referral or endorsement of legal counsel.

14. Relationship to Other Policies and Agreements

This Privacy Policy should be read alongside our Terms of Service and Legal Services Agreement, available at invictuscounsel.com/terms, and our Cookie Policy, available at invictuscounsel.com/cookies. The Terms of Service contain additional detail regarding AI disclosure, confidentiality, data flows, and retention (see Sections 5, 11, 12, and 13). In the event of conflict, applicable professional responsibility rules govern first, then the Terms of Service.

Invictus AI Corporation maintains separate privacy policies for the Verena™ platform, at verena.ai/legal/privacy, and for invictus.ai, at invictus.ai/legal/privacy-policy. Those policies govern use of Verena™ as a standalone product, separate from the legal services provided by Invictus Counsel.

15. Changes to This Policy

We may update this Privacy Policy from time to time. For active clients, we will provide at least thirty (30) days' advance notice of material changes via the Verena™ platform or by email. For website visitors, we will post the revised Policy with an updated effective date. Continued use of the website or services constitutes acceptance of the revised Policy.

16. Contact Us

For questions or concerns about this Privacy Policy, to exercise your data protection rights, or for any privacy-related matter, please contact:

Invictus Counsel, PLLC

PO Box 93116, Phoenix, AZ 85070

Email: privacy@invictuscounsel.com

Website: https://invictuscounsel.com

ATTORNEY ADVERTISING NOTICE: This website and its contents may constitute attorney advertising under applicable rules of professional conduct. Prior results described on this website do not guarantee a similar outcome.