Legal

Privacy Policy

Last updated September 2026

1. Introduction

Refactor AI is operated by Latent Insurance, Inc. (“we,” “our,” or “us”). We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose and safeguard information when you visit usegemma.com or engage us to build and run Agent systems for your organisation.

2. Information We Collect

We may collect the following types of information:

  • Contact information: name, email address, phone number, company and role, provided when you book a call, request a demo or contact us.
  • Engagement information: details about your systems, workflows and requirements that you share so we can scope and deliver work.
  • Customer content: configuration, documents, messages and other material you give our Agents access to in the course of an engagement. We process this on your behalf and under the agreement that governs the engagement.
  • Usage data: information about how you interact with our website, such as IP address, browser type, pages visited and time spent on pages.

3. How We Use Information

We use the information we collect to:

  • Respond to your enquiries and schedule and run discovery calls and demos
  • Scope, deliver and support the work you engage us for
  • Operate, secure and improve our website and services
  • Send updates about our services, where you have agreed to receive them
  • Comply with legal obligations

Your configuration, documents and conversations are never used to train AI models.

4. Information Sharing

We may share information with:

  • Service providers: vendors that help us operate our business, such as hosting, scheduling and communications tools, and the AI model providers we use to run Agents, under agreements that restrict their use of the data to providing the service.
  • Your own systems and environment: where an engagement runs inside your infrastructure or on models you license directly, data stays there.
  • Legal requirements: when required by law, or to protect our rights, safety or property.

We do not sell personal information.

5. Data Security

We implement appropriate technical and organisational measures to protect information against unauthorised access, alteration, disclosure or destruction, including access controls, encryption in transit and an audit trail on the work our Agents produce. No method of transmission over the Internet is completely secure, so we cannot guarantee absolute security.

6. Data Retention

We keep contact and engagement information for as long as needed to provide our services and meet legal obligations. Customer content processed during an engagement is retained according to the terms of that engagement and returned or deleted at its end on request.

7. Your Rights

Depending on where you live, you may have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Request deletion of your information, subject to legal requirements
  • Opt out of marketing communications

To exercise any of these rights, contact us using the details below.

8. Cookies

Our website may use cookies and similar technologies to understand how it is used and to improve it. You can control cookies through your browser settings.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the new policy on this page and update the date at the top.

10. Contact Us

If you have questions about this Privacy Policy, please schedule a call with us. Latent Insurance, Inc., San Francisco, CA.