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Personal data & GDPR

Privacy Policy

Last updated: May 2026

1. Introduction

Compass is a political intelligence platform operated by CL Corporate Affairs Consulting E.I. (hereinafter “CL” or “CL Corporate Affairs Consulting”, used interchangeably throughout this document), headquartered at 1 avenue de l’Observatoire, 75006 Paris, France (SIREN: 902 992 189), with a representation office at Avenue de Tervueren 103, B-1040 Brussels, Belgium. This Privacy Policy explains how we collect, use and protect personal data within the Compass platform, in compliance with Regulation (EU) 2016/679 (the “GDPR”) and the French Loi Informatique et Libertés.

Compass is built and operated by a working public affairs consultancy, and may be made available to fellow practitioners, in-house public affairs teams, trade associations, NGOs and other organisations whose activity overlaps with our own field of practice. This particular context shapes the way we have designed the platform: while CL upholds, as a foundational professional duty, a strict commitment to refusing any conflict of interest (see also section 3 of the Terms and Conditions), we believe that this contractual and ethical commitment must be matched by technical and organisational guarantees giving each user real, demonstrable control over their own data. The provisions that follow — in particular the optional end-to-end encryption (section 10.1) and our deliberate AI policy (section 9) — are the practical expression of that conviction. They are not generic compliance statements: they reflect a positioning choice that we consider inseparable from the kind of platform a public affairs consultancy can responsibly offer to its peers.

2. Data controller

CL Corporate Affairs Consulting E.I.
1 avenue de l’Observatoire, 75006 Paris, France
Avenue de Tervueren 103, B-1040 Brussels, Belgium
Contact: cl.eu.com/contact

3. Roles and responsibilities under the GDPR

The allocation of data protection roles within Compass depends on the specific context of use, assessed on a case-by-case basis in accordance with Articles 4(7), 4(8), 26 and 28 of the GDPR. The determining factor is which party decides the purposes and essential means of each processing operation — not the contractual label alone.

When CL uses Compass for its own consulting activity, CL Corporate Affairs Consulting acts as sole data controller for all data processed within the platform, including reference data, stakeholder mapping, position analysis and engagement records.

When a third-party user accesses Compass in the context of their own public affairs activities, the respective roles are determined by the nature of the mission and the degree of autonomy of each party:

In all cases, CL Corporate Affairs Consulting is committed to implementing appropriate technical and organisational measures to ensure the security and confidentiality of personal data, in compliance with the GDPR. Where CL Corporate Affairs Consulting acts as data processor, the Terms and Conditions of the platform govern the obligations of each party in accordance with Article 28 GDPR.

3.1 Specific case — CL-designed analytical methodologies

The roles described in section 3 distinguish who decides what within a given processing operation. Within that framework, one nuance deserves to be stated explicitly: Compass embeds a number of analytical methodologies designed by CL Corporate Affairs Consulting — in particular the influence weighting applied to stakeholders, the urgency scoring that flags time-sensitive engagement, the activate-target detection that surfaces priority contacts, and the predictive estimation of legislative timelines derived from past procedural patterns. The user controls who is added to the platform, what data is entered, and the strategic purpose pursued; CL is the author of the methodology that turns that user-controlled data into a score, a ranking or an estimate.

Under the GDPR, the determination of essential means of processing is one of the criteria that distinguishes a controller from a processor (Article 4(7) GDPR; EDPB Guidelines 07/2020 on the concepts of controller and processor, §38 onward). Because the weighting and ranking methodologies embedded in Compass shape how a user’s data is analysed and presented, CL Corporate Affairs Consulting acknowledges that, for these specific analytical operations, it retains a share of responsibility for the methodological design — alongside the user, who remains the controller for the underlying data, the choice of data subjects and the strategic purpose pursued. This is consistent with the case-law of the Court of Justice of the EU, which has held that joint controllership can arise for specific phases of a processing operation (judgments C-210/16 Wirtschaftsakademie and C-40/17 Fashion ID).

Concretely, the user remains free to disagree with a score, to override it manually, and to use Compass without relying on the suggested weighting — positions and influence values can always be set or overridden by hand. CL describes the high-level logic of each scoring methodology in the platform’s in-product help, documents methodology changes in transparent release notes, and stands by the methodology it designs. That residual methodological responsibility does not extend to the user’s overall mapping work: for the data entered, the subjects selected and the purpose pursued, the user remains the controller.

4. Categories of data processed

Compass processes three distinct categories of personal data, each with its own regime:

User account data (name, email address, company, phone number if provided, hashed login credentials) is also processed for the purpose of providing access to the platform.

Browsing data: a single session cookie (HTTP-only, strictly functional, no tracking) is used for authentication.

5. Legal basis and purposes

The processing of personal data within Compass is based on the following legal grounds:

6. Legitimate interest assessment

In accordance with Article 6(1)(f) of the GDPR, the reliance on legitimate interest as a legal basis for the processing of stakeholder data has been assessed as follows:

7. Publicly available data and special categories

A significant portion of the personal data processed in Compass relates to public figures acting in their official capacity (Members of the European Parliament, Commissioners, Council officials, registered interest representatives). This data is sourced from official, publicly accessible institutional databases:

Where the data processed includes information that may reveal political opinions within the meaning of Article 9(1) GDPR (e.g. recorded votes, publicly declared positions on legislative files, political group affiliation), such processing is permitted under Article 9(2)(e) GDPR, as it relates exclusively to personal data which the data subject has manifestly made public through official institutional channels, parliamentary votes, public statements or voluntary publications on public social media accounts. This exception is applied strictly to data that is already in the public domain by virtue of the data subject’s own actions in their official capacity.

8. Our approach to user control and transparency

Two of the most consequential design choices of Compass — the optional end-to-end encryption of user-authored content (section 10.1) and the platform’s AI policy (section 9) — are governed by the same underlying principle. Modern technologies (advanced cryptography, language models) bring real value to public affairs work, but they also raise legitimate questions about who can read what, where data flows, and what the user actually controls. Rather than answer those questions through generic reassurances, Compass is designed so that the answers are visible, verifiable and chosen by the user.

This translates into three operational rules that apply equally to encryption and to AI:

The two sections that follow apply this framework to the two specific cases of AI-assisted analysis (section 9) and end-to-end encryption (section 10.1).

9. AI services

Compass includes an AI layer that supports analytical tasks such as position classification, stakeholder analysis and strategic briefings. The platform is designed around a firm principle: the user always chooses which AI configuration is used, if any, and may at any time switch back to a configuration where no AI is involved.

CL Corporate Affairs Consulting has made a deliberate choice to limit Compass’s AI scope to Mistral, the European AI provider headquartered in Paris (France). No other third-party AI provider — neither OpenAI, nor Anthropic, nor any non-European model — is integrated into the platform, and none is contemplated for future integration. The user may choose between two Mistral-based configurations, described below.

9.1 Local AI — Ollama on the user’s own machine

In this configuration, a Mistral model runs directly on the user’s own computer via the Ollama runtime. The user installs Ollama, downloads a Mistral model (typically ollama pull mistral) and configures Ollama to accept requests from the Compass interface by setting the environment variable OLLAMA_ORIGINS=https://compass.eu.com before starting the service.

In this configuration, no data ever leaves the user’s device for AI processing. The Compass web interface communicates directly with the local Ollama instance through the browser, on http://localhost:11434 — a loopback address treated as a secure context by all modern browsers (Chrome, Firefox, Safari), per the W3C Mixed Content specification. The platform’s server is not involved in the AI exchange, and CL Corporate Affairs Consulting has no technical means of inspecting either the prompts sent or the responses returned.

This is the maximum-privacy option and the configuration recommended for highly sensitive material. It requires a one-off technical setup on the user’s part (Ollama installation, model download, environment variable configuration); detailed installation guidance is provided in the user-facing settings.

9.2 Cloud AI — Mistral commercial API

In this configuration, AI requests are sent to Mistral AI’s commercial API (api.mistral.ai). Mistral AI is a French company; the API is operated from European infrastructure (France and Sweden) and the entirety of the AI processing takes place within the European Union, with no transfer to a third country.

Reference documentation — Mistral terms: legal.mistral.ai/terms · Data Processing Addendum: legal.mistral.ai/terms/data-processing-addendum.

9.3 No AI provider is ever imposed on the user

Activation of either AI configuration requires a deliberate user action in Manage my account. The default state of every Compass account is “no AI” — the AI-assisted features are simply absent until the user explicitly chooses Option 9.1 or Option 9.2. The user may also switch between options or revert to “no AI” at any time, with no data persistence between configurations.

AI-generated content, whether produced locally (Option 9.1) or via the Mistral API (Option 9.2), is provided for informational purposes only and should always be reviewed and validated by the user before being acted upon or shared externally. CL Corporate Affairs Consulting does not guarantee the accuracy, completeness or reliability of AI-generated outputs.

10. Data security and hosting

All data processed by Compass is stored on a private, dedicated server located within the European Union, under the physical control of CL Corporate Affairs Consulting. The platform implements the following security measures:

Emails related to account management (password creation, reset, change notifications) are sent via SMTP with TLS encryption.

10.1 Optional end-to-end encryption

Why this feature exists. Compass is built and operated by a working public affairs consultancy whose users are often, themselves, public affairs professionals working on sensitive matters — sometimes on dossiers that touch the same policy areas as engagements pursued by CL itself or by its other clients. Even though CL Corporate Affairs Consulting upholds, as a foundational professional duty, a strict policy of refusing any conflict of interest (see also section 3 of the Terms and Conditions) and contractually commits never to read user-authored content (see section 11 of the Terms and Conditions), we believe that users should not be required to take that commitment on trust alone. End-to-end encryption is the technical translation of that conviction: it gives users a way to ensure, by the design of the platform itself, that their analytical work is mathematically out of reach of CL operators, of any third party gaining access to the servers, and of any authority seeking compelled disclosure. It is, in our view, a natural consequence of building a tool for one’s own profession.

What it is, in practical terms. In addition to the baseline security measures above, Compass offers an optional end-to-end encryption mode that users may activate at any time in Manage my account. This feature is not enabled by default; it is an explicit opt-in, intended for users who handle particularly sensitive material and who wish to add a technical guarantee on top of CL’s contractual commitments. Users who do not activate it are, of course, fully covered by the contractual non-consultation commitment, which applies regardless of encryption status; the feature is offered as an additional layer for users who want it, not as a prerequisite to use the platform.

What is encrypted. When end-to-end encryption is enabled on an account, the following data is encrypted in the user’s browser before being stored on the server: the list of dossiers the user tracks, personal notes, the user-authored content of the stakeholder mapping (attributed position summaries, supporting arguments, private comments and curated sources), watch keywords (in Secure Search mode), topic names, user-authored biographies and profile notes, engagement log entries (meeting records, takeaways, signals), the user’s personal radar cache, and any other content authored personally by the user. The scope of encryption is deliberately broad and aims to prevent any observer of the server — including CL operators — from profiling the user’s activity, interests or analytical positions.

What is not encrypted, and why. The following categories remain unencrypted, by design: public reference data shared across all users (Members of the European Parliament, Commissioners, Commission staff, Council staff, Transparency Register organisations, institutional calendar events, all sourced from official EU databases); account information required for authentication and notifications (first name, last name, email, phone number, organisation); technical identifiers required for SQL joins (primary keys, foreign keys, user identifiers); audit timestamps (creation, modification, login times); cryptographic lookup hashes (irreversible SHA-256 digests of watch keywords in Secure Search mode, used for server-side matching without revealing the keyword); and the analytical scores and the rankings derived from them (the influence, urgency, involvement and attitude scores attached to each stakeholder, together with the priority quadrant and activate-target flags computed from them). These last are not free text authored by the user but values produced by the analytical methodologies designed by CL (influence weighting, urgency and activate-target scoring), which the server computes and re-computes; keeping the numeric scores legible to the engine is precisely what lets the platform position stakeholders on the map, rank them and recompute their quadrant. The written reasoning that justifies each score is itself encrypted, and a bare figure — an influence of 80, say — is in any event far less revealing than the analyst’s rationale, which stays protected. These categories are either already public by nature, or necessary to the technical operation of the service. We list them here, rather than mention encryption in vague terms, because we consider that an honest description of the boundaries of the guarantee is part of the guarantee itself.

How it works — in plain language. When a user activates end-to-end encryption, two things happen inside their browser, both invisible to the server. First, a new master key is generated locally: this is the key that will actually encrypt the user’s content. Second, this master key is itself put inside a sealed envelope whose lock is opened only by the user’s login password. The server stores the sealed envelope, but never the master key in clear form, and never the password. Each time the user logs in, the password unlocks the envelope locally in the browser, the master key is recovered for the duration of the session, and the encrypted fields can be read; when the user logs out, everything goes back inside its sealed envelope on the server side. CL never holds the master key and cannot reconstruct it: the cryptographic guarantee is that what is stored on our servers, in encrypted form, is unreadable to us by construction.

How it works — in technical terms. The scheme is zero-knowledge: the keys that decrypt user data never leave the user’s device and are not stored on the server in any retrievable form. More specifically:

What this means in everyday use. The two-key design has a direct, practical benefit for users:

Consequences for CL. Because the key that protects the master key is derived from the user’s password and never leaves their browser, CL Corporate Affairs Consulting and its administrators cannot, by construction, read the encrypted fields of an account that has end-to-end encryption turned on. This property is enforced technically, not merely contractually, and applies even in the face of an internal investigation, a security incident or a legal order: CL does not hold the key, cannot reconstruct it, and cannot be compelled to produce the clear-text content of encrypted fields. This limitation applies equally to CL itself and is assumed as a deliberate consequence of the zero-knowledge design (see also section 11 of the Terms and Conditions).

Fields that are not encrypted remain technically accessible to CL operators. In the absence of end-to-end encryption, this includes the content of notes, stakeholder mapping, attributed positions, private comments and all other user-authored content. The non-consultation of these fields by CL is governed exclusively by the contractual commitment set out in section 11 of the Terms and Conditions and is not, in the absence of end-to-end encryption, enforced by a technical impossibility. We consider that this distinction must be stated explicitly: it is the difference between a guarantee that we promise to honour and a guarantee that the platform itself enforces.

Even when end-to-end encryption is activated, certain operational metadata remain technically visible to CL operators, as an unavoidable consequence of running a web service. These metadata do not allow reconstruction of encrypted content, but may allow inference of certain usage characteristics:

These structural metadata fall within the same contractual non-consultation commitment as any other non-encrypted data (section 11 of the Terms and Conditions). CL Corporate Affairs Consulting commits not to exploit them for any purpose other than the technical supervision of the service (security monitoring, debugging, capacity planning). We document them here, rather than omit them, because the credibility of the broader guarantee depends on a transparent description of its boundaries.

Conversely, fields that have been encrypted with end-to-end encryption cannot be read by anyone other than the user, including CL itself. This is a property of the cryptographic design, not a contractual promise: the decryption key is derived from the user’s password inside their own browser and never leaves the user’s device. CL does not hold the key, cannot reconstruct it, and cannot be compelled to produce the clear-text content of encrypted fields — neither in response to a legal order, nor in the course of a security investigation, nor at the request of a third party who would gain access to the servers. This limitation applies equally to CL Corporate Affairs Consulting and is assumed as a deliberate consequence of the zero-knowledge design.

10.2 Separation between the Compass platform and CL Corporate Affairs consulting practice

CL Corporate Affairs Consulting operates two distinct activities through a single legal entity: the publication of Compass and a public-affairs consulting practice. This dual role may, in some cases, create a conflict-of-interest risk that the contractual non-consultation commitment (section 11 of the Terms and Conditions) and the optional end-to-end encryption (section 10.1) already address. The following provisions complete that framework with practical commitments that do not require any formal compliance apparatus to honour.

(a) Non-reuse of user data in CL consulting engagements. CL Corporate Affairs Consulting commits never to use, in its own consulting engagements, any data, analysis, position, mapping, comment, draft amendment, watchlist or insight entered by a Compass user — whether end-to-end encryption is activated or not. This commitment covers the identity of the dossiers tracked by the user, the substance of their analytical work, and even the simple fact that the user takes an interest in a given topic. Where end-to-end encryption is activated, the commitment is additionally enforced by cryptographic impossibility (section 10.1).

(b) Three-tier data taxonomy. Compass processes three distinct categories of data, each with its own protection regime:

(c) Access policy. Access to the production database is strictly limited to the technical functions required to operate the service, and every privileged action is recorded in the audit trail referenced in section 10. The platform runs on a private server located in the EU and under the physical control of CL Corporate Affairs — without reliance on a public-cloud provider or on any third party with access to user content. The partitioning between accounts is enforced at the application level by user-scoped queries, and reinforced — for accounts with end-to-end encryption activated — by per-user encryption envelopes: no user can access another user’s analytical content.

(d) Reinforced confidentiality commitment. Beyond the GDPR, CL Corporate Affairs Consulting voluntarily aligns its practice with the professional confidentiality standards applicable to public-affairs practitioners: the EU Transparency Register Code of Conduct annexed to the 2021 Interinstitutional Agreement between Parliament, Council and Commission (in particular its provisions on the honest obtaining, handling and release of EU information); the values of integrity, transparency, accuracy and confidentiality set out in the SEAP (Society of European Affairs Professionals) Code of Conduct; and the deontological standards of the French High Authority for Transparency in Public Life (HATVP) for declared interest representatives — notably the prohibition on obtaining information through fraudulent means and on selling information obtained from public officials. When accepting a new consulting engagement, CL Corporate Affairs checks in good faith for any obvious overlap with the known activity of a Compass user, and declines the engagement where one is found.

(e) Simple conflict signalling, in both directions.

Each signal is taken seriously. Every report received — from a user, from CL itself, or from a third party — is examined with ethical and legal diligence. We treat this as a core condition of the platform’s credibility, not as an optional courtesy: in a profession where discretion is part of the deliverable, a tool that mishandled conflict-of-interest signals would lose what makes it worth using in the first place.

11. Data retention

12. Recipients of data

Personal data processed within Compass is accessible only to authorised users of the platform. Each user accesses only the data relevant to their own activity. Internal notes and engagement records are visible only to the user who created them.

No data is shared with third parties, except:

13. Your rights

The GDPR grants specific rights to individuals whose personal data is processed. Within Compass, these rights apply differently depending on the category of person concerned:

Platform users (account holders) may at any time:

Persons referenced as stakeholders (public figures, institutional actors) whose publicly available data is processed in Compass may:

Who to contact: requests relating to user account data should be addressed to CL Corporate Affairs Consulting. Where a third-party user acts as data controller for stakeholder data they have entered, requests from stakeholders relating to that data should be directed to the relevant user (data controller). CL Corporate Affairs Consulting will assist in routing such requests where appropriate.

To exercise any of these rights, please contact us via our contact form. You may also lodge a complaint with the CNIL (cnil.fr) or any competent supervisory authority.

14. Cookies

Compass uses a single functional session cookie (HTTP-only, SameSite=Strict) required for authentication. This cookie does not collect any personal data beyond the session identifier, does not track users across websites, and expires after 7 days. No tracking, profiling or advertising cookies are used. No audience measurement tool is deployed on the Compass platform.

15. Changes to this policy

This policy may be updated to reflect changes in the platform’s features, applicable legislation or regulatory guidance. Changes will be published on this page with an updated date. Where changes materially affect the processing of personal data, users will be notified upon their next login.