Privacy Policy
1. Introduction and Scope
Sentinel LAI, Inc., a Delaware corporation ("Sentinel," "we," "us," or "our"), provides a contract verification and simulation platform for legal and transactional professionals.
This Privacy Policy explains how we collect, use, disclose, and protect personal information in connection with: (a) the website at sentinel-lai.com and related web properties (the "Site"); and (b) the hosted Sentinel platform that we operate and make available over the internet (the "Platform"). The Site and the Platform are referred to together as the "Services."
1.1 What this policy does not cover. We also licence the Sentinel software for installation on infrastructure controlled by a customer, including on-premises and air-gapped deployments. In such a deployment the customer — not Sentinel — hosts the software, holds the data, configures the model provider, and sets every retention period. This Privacy Policy does not describe those deployments, and nothing in it is a representation about how data is handled in one. Such deployments are governed by a separate written agreement.
1.2 This Privacy Policy also does not apply to the practices of any third party we do not control, or to any employer, law firm, or client of yours that may have its own privacy practices governing information you handle.
1.3 The Services are offered to business and professional users. Where you are located in the European Economic Area, the United Kingdom, or Switzerland, Sections 5.2, 13.3 and 14 set out the additional information and rights that the General Data Protection Regulation and the UK GDPR require.
2. The Two Roles We Play
It matters, for your rights and for our obligations, which of two capacities we are acting in.
2.1 As a controller (and, under the CCPA, a "business"). For information about your use of the Site, your account, your communications with us, and our commercial relationship with you, we determine the purposes and means of processing. "CCPA" means the California Consumer Privacy Act as amended by the California Privacy Rights Act.
2.2 As a processor (and, under the CCPA, a "service provider"). For Customer Content — the contracts, documents, and other materials uploaded to the Platform, and the analyses and reports generated from them — we act on the documented instructions of the customer that uploaded it. Any personal information contained inside those contracts is processed in this capacity. Our contractual obligations in this role are set out in Section 8 of our Terms of Use, which contains the data processing terms required by Article 28(3) of the GDPR and the certification required by the CCPA.
2.3 Consequence for data subject requests. If you are an individual whose personal information appears inside a contract that one of our customers uploaded, we are not the party that decides how that information is used. Direct your request to the customer that controls it. If you contact us, we will, where we can identify the relevant customer, refer your request to them and assist them in responding.
2.4 Processor and service provider commitments. In this role we will not: retain, use, or disclose Customer Content for any purpose other than performing the Services for the customer and the other business purposes permitted by applicable law; sell or share Customer Content; retain, use, or disclose Customer Content outside our direct business relationship with the customer; or combine Customer Content with personal information received from other sources, except as the law permits.
3. Personal Information We Collect
3.1 Information you provide directly.
| Category | Examples |
|---|---|
| Identifiers | Name, business email address, business postal address, business telephone number, employer or firm name, job title, account username |
| Account credentials | Password, stored only as a salted PBKDF2-HMAC-SHA256 hash; we never store or log a plaintext password |
| Commercial information | Records of evaluations, pilots, demonstrations requested or conducted; correspondence regarding pricing and scope; the account's usage ledger and allowance |
| Professional or employment-related information | Your role, practice area, seniority, and organization, where you provide it |
| Customer Content | Contracts and other documents you upload (PDF and DOCX), which may themselves contain personal information about signatories, counterparties, officers, employees, or other individuals named in them, together with the analyses and reports generated from them |
| Preferences and consents | Your interface language and reading-level settings, and your training-data consent choice, each change of which is recorded with its time, the previous value, the version of the consent text, and the source network address |
| Communications | The content of emails, support requests, meeting notes, and other correspondence with us |
3.2 Information collected automatically by the Platform. The Platform contains no analytics, advertising, crash-reporting or telemetry instrumentation. What it records is an operational and security record:
| Category | Examples |
|---|---|
| Account activity record | Sign-ins and failed sign-in attempts; password changes and administrator resets; consent changes; each completed analysis and its computed cost; the opening of a document and the viewing of a report; administrator actions affecting the account — each with the source network address and a UTC timestamp |
| Server logs | Usernames, request paths, status codes, error and diagnostic records. These logs never contain document text |
| Connection data | IP address, and the browser and operating system data a browser sends with a request |
3.3 Information collected automatically by the Site. The Site is a static marketing page. It loads assets and embedded content from third parties — a scheduling embed used to book demonstrations, web-font and script content delivery networks — and those third parties receive your IP address and request metadata and may set their own cookies. See Section 10.
3.4 Sensitive personal information and special categories. We do not intentionally collect "sensitive personal information" as defined by the CCPA or "special categories of personal data" as defined by Article 9 of the GDPR, and we ask you not to upload them. Because we do not inspect documents before they are processed, contracts you upload may nonetheless contain such information. Where it reaches us inside Customer Content, we process it only as a processor on the customer's behalf, solely to provide the Services, and never to infer characteristics about any individual. We do not use or disclose sensitive personal information for any purpose that would trigger a right to limit its use under the CCPA.
3.5 Information we do not collect. We do not collect personal information from data brokers, and we do not purchase personal information. The Platform does not profile, score, or make automated decisions about individuals: its analysis is directed at contract terms and at the parties to a contract in their contractual capacity, and it produces no legal effect concerning, and does not similarly significantly affect, any individual within the meaning of Article 22 of the GDPR.
4. Sources of Personal Information
We collect personal information from: you and your authorized users directly; your organization, where it arranges access or administers accounts on your behalf; automatically from your device and browser when you use the Services; and, for business contact information used in our own outreach, from publicly available professional sources such as company websites and professional networking platforms.
5. How We Use Personal Information, and Our Legal Bases
5.1 Purposes. We use personal information to:
(a) provide, operate, maintain, and secure the Services, including authenticating users and enforcing access controls and usage allowances;
(b) process Customer Content to produce the analyses, simulations, and reports the customer requests;
(c) respond to inquiries, provide support, and send service, security, and administrative announcements;
(d) establish, manage, and administer our commercial relationship with you, including evaluations, pilots, and any resulting agreement;
(e) monitor, diagnose, debug, and improve the reliability, performance, accuracy and security of the Services;
(f) detect, investigate, prevent, and respond to fraud, abuse, security incidents, and violations of our Terms of Use;
(g) comply with applicable law, respond to lawful requests, and establish, exercise, or defend legal claims; and
(h) send business communications about our products where you have requested them or where permitted by law, with an opt-out available in every such message.
5.2 Legal bases (EEA, UK and Switzerland). Where the GDPR or UK GDPR applies to processing for which we are the controller, we rely on:
| Purpose | Legal basis |
|---|---|
| 5.1(a), (c), (d) — providing the Services, administering the account and the relationship | Article 6(1)(b), performance of a contract with you or steps at your request |
| 5.1(e), (f), (h) — securing and improving the Services, preventing abuse, business outreach to professional contacts | Article 6(1)(f), our legitimate interests in operating a secure and reliable service and in developing our business, balanced against your interests and rights |
| 5.1(g) — legal compliance | Article 6(1)(c), compliance with a legal obligation, and Article 6(1)(f) for the defence of legal claims |
| Training-data opt-in under Section 7 | Article 6(1)(a), consent, which you may withdraw at any time |
Where we act as a processor for Customer Content, the legal basis for that processing is determined by the customer that uploaded it, not by us.
5.3 Aggregated and de-identified data. We use aggregated and de-identified operational metrics — such as processing times, error rates, latency and feature usage counts — to operate and improve the Services. These metrics contain no contract text and do not identify any individual, and we do not attempt to re-identify them.
6. Artificial Intelligence Processing and Subprocessors
6.1 What happens to the contracts you upload. The Platform performs its analysis by transmitting the text of Customer Content over an encrypted connection to a third-party provider of large language model inference services. Model inference is used at several stages — detection of findings, simulation of scenarios, the review of candidate findings before they are shown, drafting of redlines and memoranda, and the document assistant — so contract language reaches that provider whenever an analysis runs. This is the routine and expected operation of the Platform, not an exception to it.
6.2 Who the providers are. As at the Last Updated date above, we engage:
| Subprocessor | Role | Location of processing |
|---|---|---|
| Together AI, Inc. | Large language model inference; the model currently configured is from the GLM family published by Z.ai (Zhipu AI). The model weights are operated by Together AI on its own infrastructure; no contract data is sent to the model's publisher | United States |
| [INSERT CLOUD HOSTING PROVIDER] | Hosting, compute, storage and backup of the Platform | United States |
We engage each subprocessor under a written agreement that limits its processing to providing services to us, imposes confidentiality obligations, and requires data protection commitments no less protective than those we owe you.
Training by the model provider. Our model inference provider's published terms state that it does not use data collected through its interface to train its models without the customer's explicit opt-in, and that such sharing is not enabled by default. We have not given that opt-in and will not give it.
Retention by the model provider. That provider's default terms permit it to store the prompts it receives and the responses it returns and to use them for its own product improvements. We have therefore enabled its zero-data-retention setting, under which the content of a request is not persisted by the provider and is not used for any secondary purpose beyond returning the response to us. A provider's terms can change; the position in force, and the date on which we last verified it, is recorded on our subprocessors page.
6.3 Current list. A current list of the subprocessors we engage, the category each falls into, the location of processing, the training and retention position in force for each, and the date on which we last verified it, is maintained at sentinel-lai.com/subprocessors. We update that page when we add or replace a subprocessor and, as described in Section 8.6 of our Terms of Use, give notice there before the change takes effect.
6.4 Other outbound connections. Two further connections exist and carry no Customer Content: the Platform downloads its document-layout and entity-recognition model weights from a public model repository the first time it parses a document, and the deployment obtains and renews its TLS certificate from a certificate authority. Neither request includes anything about your documents.
6.5 On-premises deployment. Where your matter requires that Customer Content not leave infrastructure you control, an on-premises or isolated deployment is available under a separate agreement, in which no Customer Content is transmitted to a model provider engaged by us. Contact us before uploading Customer Content if this is a requirement for you.
7. We Do Not Train on Your Content Without Your Opt-In
7.1 We do not use Customer Content or the analyses generated from it to train, fine-tune, or otherwise develop our models or those of any third party, unless the account concerned has given a separate, express opt-in.
7.2 That opt-in is a distinct affirmative act: a setting in the account's own settings page, off by default, which the account holder turns on and can turn off again at any time. It is never bundled into acceptance of our Terms of Use or this Privacy Policy. Withdrawal is effective going forward; it does not oblige us to retrain or reverse the effect of any model already trained while the opt-in was in effect, and we will tell you plainly if that is the case. Turning the setting on or off moves, copies, or deletes nothing by itself.
7.3 Quality records, kept regardless of the opt-in. So that we can measure and regression-test the accuracy of the Services, the Platform writes a technical record of each analysis to the account's own storage. Where the account has not opted in, that record contains identifiers, cryptographic hashes and classification labels only, and the clause text is expressly withheld from it. Where the account has opted in, the record may also contain the quoted clause. These records are derived from Customer Content and are not anonymous; they are held as Customer Content, deleted when the document is deleted, and never used for model training for an account that has not opted in.
7.4 Separately, and regardless of opt-in status, we use the aggregated and de-identified operational metrics described in Section 5.3. Those contain no contract text and no personal information.
8. How We Disclose Personal Information
We disclose personal information only as follows:
8.1 Subprocessors, as described in Section 6, for the purpose of providing the Services.
8.2 Your own organization, where an administrator or account owner at your firm or company has rights over the account under which you operate. Such an administrator can see, and export, your account's activity record — including sign-ins, consent changes, completed analyses and their cost, and the fact that a given document was opened or a given report viewed, each with the source network address and time. Administrators cannot read the contents of another account's documents or reports through the Platform.
8.3 Professional advisors — lawyers, auditors, accountants, and insurers — bound by professional duties of confidentiality.
8.4 Legal and safety disclosures, where we reasonably believe disclosure is required by law, regulation, legal process, or governmental request, or is necessary to protect the rights, property, or safety of Sentinel, our customers, or the public. Where we are legally permitted to notify you before disclosing Customer Content in response to legal process, we will do so and will give you a reasonable opportunity to seek protective relief.
8.5 Business transfers, in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to the recipient's agreement to honor the commitments in this Privacy Policy with respect to information transferred.
8.6 With your direction or consent, for any other purpose disclosed to you at the time.
9. We Do Not Sell or Share Personal Information
We do not sell personal information, and we do not share personal information for cross-context behavioral advertising or targeted advertising, as those terms are defined by the CCPA and comparable U.S. state laws. We have not done so in the preceding twelve (12) months. We do not disclose the personal information of minors under sixteen (16) years of age for such purposes, because we do not knowingly collect it at all.
10. Cookies, Local Storage and Tracking
10.1 The Platform. The Platform sets a single strictly necessary cookie, sentinel_session, which carries your signed session token. It is HttpOnly, restricted to the same site, marked Secure over HTTPS, and expires fourteen (14) days after sign-in. It is required to sign in; blocking it makes the Platform unusable.
10.2 Local storage in your browser. The Platform also stores a small amount of data in your browser's local storage: the identity of the signed-in user, your what-if analysis history, and markers showing which redlines you have applied to each document. This data stays in your browser, is cleared when you sign out or your session expires, and a document's entries are removed when that document is deleted.
10.3 No tracking in the Platform. The Platform uses no analytics cookies, advertising cookies, marketing or conversion pixels, social media trackers, or session replay tools, and loads no third-party asset of any kind. We do not build advertising profiles.
10.4 The Site. The Site, by contrast, embeds third-party content: a scheduling widget used to book demonstrations, and content delivery networks serving web fonts and animation libraries. Those providers receive your IP address and request metadata and may set their own cookies under their own privacy policies. We do not use them to track you across other websites, and we do not use analytics or advertising tags on the Site.
10.5 Global Privacy Control. Because we do not sell or share personal information and do not engage in cross-context behavioral advertising, there is no sale or sharing for a Global Privacy Control or "Do Not Track" signal to stop. We honor such signals by continuing not to engage in those practices.
11. Retention and Deletion
11.1 Customer Content. We retain Customer Content and the analyses generated from it for as long as the account remains active, or until it is deleted. Deleting a document removes its parse, its reports, its versions, its exports, its progress records, its browser-side history, and its entries in the quality record described in Section 7.3, from active systems promptly.
11.2 On account closure or termination. The account is disabled immediately and its sessions are invalidated. Its entire store — documents, parses, reports, versions and exports — is permanently deleted after a seven (7) day window during which the closure can be reversed, and in any event within thirty (30) days.
11.3 Cached model answers — a residue that outlives deletion. To avoid paying for and re-running identical model calls, the Platform caches model answers keyed by a cryptographic hash of the prompt that produced them, and those prompts contain contract language. This cache is shared across accounts by design and is not partitioned per account. A cached answer can only be reached by a request that already contains the same text, so it cannot expose your contract to anyone who does not already hold it; but the cached bytes remain on disk after a document or an account is deleted, until the cache retention window collects them. That window is thirty (30) days, and the cache is swept every twenty-four (24) hours. If your policy requires erasure on a shorter cycle, write to leo@sentinel-lai.com and we will disable caching for your deployment.
11.4 Account and business records. When an account is purged, a usage ledger and a summary record of the account — containing no documents, no contract text and no credentials — are archived for accounting, tax and audit purposes and retained for no longer than seven (7) years. Correspondence and commercial records are retained for as long as necessary for the purposes described in this Privacy Policy and thereafter as required for tax, accounting, audit, and legal limitation purposes.
11.5 Activity and security records. The per-account activity record described in Section 3.2 is retained for three hundred and sixty-five (365) days. Server logs, which contain no document text, are retained for fourteen (14) days.
11.6 Backups. Encrypted backup copies may persist for up to thirty (30) days after deletion from active systems, after which they are overwritten in the ordinary backup rotation. Backups are not accessed for any purpose other than disaster recovery.
11.7 Legal holds. We may retain information longer where required by law or where it is subject to a litigation hold, regulatory investigation, or preservation obligation. We will delete it when the obligation ends.
12. Security
12.1 What we do. We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include:
(a) encryption of data in transit using TLS, both between you and the Platform and between the Platform and its subprocessors;
(b) storage of the Platform's data on encrypted volumes;
(c) passwords stored only as salted PBKDF2-HMAC-SHA256 hashes with 200,000 iterations, compared in constant time, and never written to disk or to a log in plaintext;
(d) signed, HttpOnly session tokens with a cross-site request forgery guard, session invalidation on password change, administrator reset or account disable, rate limiting of sign-in attempts and account lockout after repeated failures;
(e) a strict Content Security Policy and related browser security headers on the Platform, which loads no third-party script or asset;
(f) separation of each account's documents, reports, exports and records into its own storage area, resolved through the signed-in account, with no administrator-readable view of another account's documents;
(g) access to production systems on a least-privilege basis, with authentication requirements for personnel and logging of that access; and
(h) an activity record of sensitive reads as well as writes, as described in Section 3.2.
12.2 What we do not claim. No method of transmission or storage is completely secure, and we do not guarantee absolute security. In particular: the Platform does not offer multi-factor authentication, single sign-on or SAML federation; uploaded files are not scanned for malicious code; the model-answer cache described in Section 11.3 is deliberately shared across accounts rather than partitioned; and a person with operating-system level access to our production infrastructure could read data on it, which is why such access is restricted, authenticated and logged.
12.3 Incidents. If we become aware of a security incident affecting your personal information or Customer Content, we will notify you without undue delay and as required by applicable law.
13. Your Privacy Rights
13.1 California residents. Subject to verification and to the exceptions in the CCPA, you have the right to:
(a) Know what personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting it, the categories of third parties to whom we disclose it, and the specific pieces of personal information we hold;
(b) Delete personal information we have collected from you;
(c) Correct inaccurate personal information we maintain about you;
(d) Opt out of the sale or sharing of personal information — we do not sell or share personal information, so there is nothing to opt out of;
(e) Limit the use and disclosure of sensitive personal information — we do not use sensitive personal information for purposes that trigger this right; and
(f) Non-discrimination — we will not deny you services, charge you a different price, or provide you a different level of service for exercising any of these rights.
13.2 Residents of other U.S. states. Several other U.S. states have enacted comprehensive privacy laws. Most of those laws exclude information processed in a purely business-to-business or employment context, which is the context in which we ordinarily process information. Where a state law does apply to information we hold about you, we will honor the rights it grants, including any right to appeal a refused request. Contact us and identify your state of residence.
13.3 Individuals in the EEA, the United Kingdom and Switzerland. Where the GDPR or UK GDPR applies to processing for which we are the controller, you have the right to: access your personal data; have inaccurate data rectified; have data erased; restrict processing; receive the data you provided in a portable format; object to processing carried out on the basis of our legitimate interests, including direct marketing, which we will stop on request; withdraw consent at any time without affecting the lawfulness of processing before withdrawal; and lodge a complaint with your national supervisory authority or, in the United Kingdom, the Information Commissioner's Office. We do not subject you to decisions based solely on automated processing that produce legal or similarly significant effects.
13.4 How to exercise a right. Submit a request to leo@sentinel-lai.com with the subject line "Privacy Request." Tell us which right you are exercising and provide enough information for us to locate your records.
13.5 Verification. We will verify your identity before acting on a request, in a manner proportionate to the sensitivity of the information — typically by confirming control of the email address associated with your account, and for requests concerning sensitive information, by requesting additional corroborating information. We use information provided for verification only for that purpose.
13.6 Timing. We will acknowledge your request within ten (10) business days and respond substantively within forty-five (45) calendar days, or within one (1) month where the GDPR or UK GDPR applies. Where reasonably necessary we may extend — by a further forty-five (45) days under the CCPA, or by up to two (2) further months under the GDPR — and will tell you why within the original period.
13.7 Authorized agents. An authorized agent may submit a request on your behalf with written proof of authorization. We may ask you to verify your identity directly with us and to confirm that you granted the authority.
13.8 Requests concerning Customer Content. Where your request concerns personal information contained inside a contract uploaded by one of our customers, we act only as a processor and cannot act on the request unilaterally. See Section 2.3.
14. International Transfers and Location of Processing
14.1 The hosted Services are operated from and hosted in the United States. Personal information we process is stored and processed in the United States and in any other country in which a subprocessor listed in Section 6.2 operates.
14.2 Transfers out of the EEA, the UK and Switzerland. Where personal data is transferred from the EEA, the United Kingdom or Switzerland to us or to our subprocessors in a country that has not received an adequacy decision, the transfer is made under the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or the Swiss equivalent, as applicable, together with any supplementary measures the transfer requires. Those clauses are incorporated into our Terms of Use by reference. You may request a copy of the relevant clauses at leo@sentinel-lai.com.
14.3 Customers outside the United States generally. The hosted Services are provided from the United States regardless of where the customer is established. If the law of your jurisdiction requires that the personal data you handle be stored or processed within that jurisdiction — as data localization rules in some countries do — the hosted Services are not a compliant route for that data. Contact us before uploading it; a separately licensed deployment on infrastructure you control may be.
14.4 Availability. We do not offer the Services where doing so would breach applicable export control or sanctions law. See Section 4 of our Terms of Use.
15. Children
The Services are intended solely for business use by adults. We do not direct the Services to children, and we do not knowingly collect personal information from anyone under eighteen (18) years of age. If we learn that we have collected such information other than incidentally within Customer Content, we will delete it.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date above and post the updated policy on the Site. If the changes are material, we will provide at least thirty (30) days' additional notice — by email to registered users or by a notice within the Platform — before the changes take effect. We encourage you to review this policy periodically.
17. Contact Us
Questions, requests, or complaints regarding this Privacy Policy or our handling of personal information may be directed to:
Sentinel LAI, Inc.
2618 College Avenue
Berkeley, CA 94705
United States
Email: leo@sentinel-lai.com
EEA and UK representative. [INSERT NAME AND ADDRESS OF ARTICLE 27 REPRESENTATIVE — to be appointed before the Services are offered in the EEA or the United Kingdom.]
We will respond to privacy inquiries within a reasonable period and, for requests carrying a statutory deadline, within the periods stated in Section 13.6.