Privacy Notice — Privilege Navigator
1. Who we are
Privilege Navigator is provided by CILC L.L.C., a limited liability company incorporated in New York, United States. CILC L.L.C. is the controller of the personal data described in this notice.
CILC L.L.C. provides legal education tools and marketing tools for the attorneys affiliated with it. The practice of law is carried on by those attorneys.
For any privacy question, or to exercise the rights described in section 9, contact us:
- Email: info@c-ilc.com
- Postal address: CILC L.L.C., 515 West 23rd Street, New York, NY 10011, United States
We have not appointed a data protection officer. Our processing does not meet the criteria that would require one, and privacy enquiries are handled at the address above.
This notice covers Privilege Navigator only. Other parts of the CILC website are covered by the general CILC privacy policy.
2. What Privilege Navigator is, and what that means for your data
Privilege Navigator provides general information about the law of the covered jurisdictions and identifies questions for you to raise with your own counsel. It does not apply the law to your circumstances, does not tell you what to do, and does not create an attorney-client relationship with CILC or with any attorney who approved its content.
Its design limits the personal data it can hold:
- There is no free-text field anywhere in the exercise. Every answer is a choice from a fixed list. You cannot type a description of your situation, because no field exists that could receive one.
- No documents can be uploaded. There is no upload control anywhere in the service, and we operate no file store for it: no storage area exists, and no permission grants your browser access to one. An automated check confirms this on every release.
- No participant is named. You select categories of people, such as "outside counsel" or "external auditor". There is no field for a person's name, email address or employer, so none can be recorded.
- No generative AI is used. Results come from a fixed set of rules written and approved by a licensed attorney. Your answers are not sent to any AI model and are not used to train one.
We ask you not to attempt to convey confidential information, personal data about other people, trade secrets or the details of your matter through the questionnaire. It is not built to receive them. Discuss those with an attorney once an engagement and a secure channel are confirmed.
3. What we collect
Account data. Your email address, and an encrypted verifier of your password. We never store your password itself. If you enable two-factor authentication, we store the data needed to operate it.
Your answers and results. The options you selected for each question, the jurisdiction and forum you chose, the categories of participants you selected, and which of those categories you identified as your own position. We also store which questions and general explanations your answers caused to be shown to you.
Consent records. Which version of each legal document you acknowledged and when. Alongside this we store a salted one-way cryptographic hash of your IP address and browser user-agent — not the values themselves. These hashes let us evidence that an acknowledgement occurred, and we do not use them to build a profile of you. We should be precise about what that protects against: the hash is salted with a secret held only on our servers, so the values cannot be recovered by anyone who obtains the hashes alone. Anyone holding both the hashes and that secret could test a guess against them, because the range of possible IP addresses is small enough to search.
Legal review requests. If you ask for legal review, we record the exercise concerned, the jurisdiction, an indication of urgency, which side of the matter you indicated, and your consent to share the exercise.
Notes made by our staff. If you request legal review, CILC personnel may record notes about handling your request. These notes are written by our staff, not by you, and are the only free-text records in the service. They are not visible on your dashboard. You may ask us what they contain under section 9, and they are removed when your account is erased.
Technical and security data. Server logs necessary to operate the service securely, and error reports. Error reporting is configured to exclude request contents and cookies.
We do not collect special category data, and the questionnaire is not designed to elicit it.
Information about other people. The questionnaire records categories of participants, never names. We do not consider these selections to identify anyone. We recognize, though, that in a small organization a category such as "company secretary" may correspond to one identifiable person in the mind of someone who knows that organization. We therefore treat participant selections with the same care as the rest of your exercise: they are visible only to you unless you request legal review and consent to sharing, and they are removed on erasure. We ask you not to use the role options to convey who someone is.
Is providing this data required? Providing an email address is necessary to create an account, and we cannot provide the service without it. Answering the questions is entirely voluntary — you are under no obligation to complete an exercise, and there is no consequence if you do not, beyond our being unable to produce one. There is no statutory requirement on you to provide any of it.
4. Why we process it, and on what legal basis
| What | Why | Legal basis (GDPR) |
|---|---|---|
| Account data | To create your account, sign you in, and let you see your own exercises | Performance of a contract with you |
| Your answers and results | To select the questions and explanations shown to you, and keep them on your dashboard | Performance of a contract with you |
| Consent records | To evidence that required notices were presented and acknowledged | Legal obligation, and our legitimate interest in maintaining a reliable record |
| Legal review requests | To route your request to a participating attorney through CILC | Performance of a contract with you, and your explicit consent to share the assessment |
| Technical and security data | To keep the service available, secure and free from abuse | Our legitimate interests in security and service integrity |
| Staff notes on a review request | To handle and route your request | Our legitimate interest in operating the referral service, and in keeping a record of how a request was handled |
| Service emails | To send sign-in, verification and confirmation messages | Performance of a contract with you |
Where we rely on legitimate interests, we have considered the impact on you and concluded that the processing is limited to what is necessary and would be reasonably expected.
Where we rely on your consent — sharing an exercise with a participating attorney — you may withdraw it at any time by withdrawing the request in the service or by contacting us. Withdrawing consent does not affect the lawfulness of processing carried out on the basis of that consent before it was withdrawn.
We do not use your data for advertising, and we do not sell or share it. We do not use it to develop or improve the service, and we do not build datasets from it.
Automated decision-making. What you are shown is selected by a fixed set of rules rather than by a person or by an AI model. We do not consider this to be automated decision-making that produces legal effects concerning you or similarly significantly affects you. The output decides nothing about you, confers and withdraws nothing, reaches no conclusion, and is expressly not a determination — it is a list of questions worth putting to an attorney. It is not used to evaluate you, profile you, or make any decision about you, and you remain free to disregard it. If you disagree with that view, write to us and we will explain our reasoning and consider your view.
5. Marketing
Privilege Navigator sends service emails only — verification, sign-in, and confirmations of requests you make. We do not send marketing from this service. If you separately subscribe to a CILC newsletter, that subscription is handled under the general CILC privacy policy and you may unsubscribe at any time.
6. Who else processes it
We use a small number of service providers, each acting on our instructions under a written data processing agreement:
| Provider | Role | Location |
|---|---|---|
| Supabase | Database, authentication, and sending of sign-in and verification emails | United States |
| Vercel | Application hosting and content delivery | United States, with a global edge network |
If we add a provider — for example a separate email service or an error-monitoring service — we will update this table before that provider begins processing, and we will note the change in section 13.
If you ask for legal review and consent to share your exercise, CILC personnel and the relevant participating attorney will see the exercise. A participating attorney acts as an independent controller in respect of any engagement they accept, under their own terms and professional obligations.
We do not otherwize disclose your data, except where we are required to by law.
7. International transfers
Your data is stored in the United States. If you are in the European Economic Area, the United Kingdom or Switzerland, this means your personal data is transferred outside your jurisdiction to a country whose data protection laws may not provide the same level of protection.
For transfers from the European Economic Area we rely on the European Commission's Standard Contractual Clauses, incorporated in our agreements with each provider listed above, together with an assessment of the circumstances of the transfer.
For transfers from the United Kingdom we rely on those clauses together with the Information Commissioner's International Data Transfer Addendum, which is what UK law requires; the Commission's clauses alone are not a valid UK transfer mechanism. For transfers from Switzerland we rely on the clauses as recognized by the Swiss Federal Data Protection and Information Commissioner.
You may request further information about these safeguards, or a copy of the relevant clauses, at info@c-ilc.com.
The volume and sensitivity of personal data transferred is deliberately small: an email address, hashed technical values, and answers chosen from fixed lists that contain no names and no description of your matter.
8. How long we keep it
We keep personal data only for as long as the purpose it was collected for actually requires, and no longer. No law requires us to retain any of it, so these periods are set by what the service needs in order to work, not by a retention obligation.
| What | Retention |
|---|---|
| Exercises you started but never submitted | 90 days, then deleted. An abandoned draft serves no purpose |
| Exercises you submitted | 12 months from submission, then deleted, so that you can return to recent work |
| Legal review requests | 12 months, or erased with your account if sooner |
| Account data | While your account is open. Erased when you ask us to close it |
| Consent records | While your account is open, then erased with it. The record is tied to your identifier, and erasure is what removes it. We keep an anonymous record that an erasure took place, containing no identifier |
| Staff notes on a review request | While your account is open, and erased with it |
| Server and security logs | Held by our hosting and database providers under their standard log retention, which we do not set |
Two consequences worth being plain about. Deleting an exercise after 12 months means it disappears from your dashboard and cannot be recovered — if you need a copy, take one before then. And where a referral leads to an engagement, the attorney keeps their own file under their own professional obligations; that file is theirs, not ours, and this notice does not govern it.
To close your account and have your data erased, use "Delete my account" on your account page. It removes your account, your exercises and any requests for legal review held by CILC, at once. You may also write to info@c-ilc.com and we will do it for you and confirm when it is done.
9. Your rights
Depending on where you are, you may have the right to be informed about our processing, to access your data, to have inaccurate data corrected, to have data erased, to restrict processing, to data portability, to object to processing based on legitimate interests, and to withdraw consent where we rely on it.
Your dashboard shows you the exercises you have made. To exercise any other right — access to everything we hold, a copy of your data, correction, erasure, restriction, or objection — contact info@c-ilc.com. We will respond within the period required by applicable law, which is one month under the GDPR. Deletion is available from your account page; a self-service export is not yet available, so we handle export and the other requests by hand, and there is no charge for doing so.
Where your personal data and its processing are not subject to the GDPR, these rights do not necessarily apply, and nothing in this notice may be interpreted to establish rights or obligations beyond what applicable law requires.
Complaints. If you are in the European Economic Area, you may lodge a complaint with the supervisory authority of the country where you live, where you work, or where you believe the problem occurred. If you are in the United Kingdom, you may complain to the Information Commissioner's Office. We would be glad to hear from you first at info@c-ilc.com.
10. Cookies
Privilege Navigator uses cookies that are strictly necessary to sign you in and keep your session secure. It sets no advertising or tracking cookies, and loads no third-party scripts on exercise screens. Because we use only strictly necessary cookies, no consent banner is presented; disabling them will prevent you from signing in.
11. Security
Data is encrypted in transit and at rest by our infrastructure providers. Access to your exercises is enforced by the database itself rather than by application code, so that each customer's records are reachable only by that customer, and by CILC personnel only where you have requested legal review and consented to sharing — and no longer if you withdraw that request. Staff privileges require a second authentication factor in the current session; the database refuses staff access without one. We keep an audit record of significant events which cannot be altered or deleted, save by the single documented process that erases an account.
No system is perfectly secure, and we do not claim otherwize. If a breach occurs that is likely to result in a risk to your rights, we will notify the relevant supervisory authority and, where required, you.
12. Children
Privilege Navigator is intended for business customers and is not directed to children. We do not knowingly collect personal data from anyone under 13 in the United States, or under 16 in the European Economic Area or California.
13. Changes
If we change this notice we will publish a new version with a new effective date. Where the change is significant, we will ask you to acknowledge the new version before you continue using the service. Previous versions are retained so that we can show which version you acknowledged and when.