Meritocrat | meritocrat.us
Privacy Policy
Effective Date: July 5, 2026 · xoCaliber Inc.
1. Introduction
xoCaliber Inc. (the "Company," "we," "us," or "our") operates meritocrat.us and the Meritocrat platform (the "Platform"), an AI-assisted workspace that helps immigration visa applicants and immigration attorneys prepare evidence and evaluate case readiness for evidence-based immigration visas such as EB-1A, EB-2 NIW, and O-1 petitions.
This Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and the rights available to you. By using the Platform, you agree to the practices described in this Policy.
If you are an immigration attorney or law firm using the Platform on behalf of your clients, additional terms in the Attorney Workspace section below apply to your use.
2. Who We Are and How This Policy Applies
2.1 Data Controller
For applicant users and attorney subscribers, the Platform acts as a data controller — we determine how and why your personal information is processed.
2.2 Data Processor
When immigration attorneys use the Platform to manage their clients' case information, the Platform acts as a data processor on behalf of the attorney (as the data controller). The attorney's use of client data within their workspace is governed by their agreement with the Company and their own privacy obligations to their clients.
2.3 Scope
This Policy applies to personal information collected through the Platform, our website, and any related services. It does not apply to information that attorneys collect from their clients outside the Platform.
3. Information We Collect
3.1 Information You Provide Directly
Depending on how you use the Platform, we may collect:
- Account information: name, email address, and contact details.
- Immigration pathway information: the visa category you are pursuing, your immigration history, and related case details.
- Professional and background information: employment history, educational credentials, publications, awards, citations, media coverage, and other achievements relevant to your visa petition.
- Uploaded evidence documents: letters of recommendation, journal articles, evidence of awards, contracts, pay stubs, and similar case materials.
- Structured questionnaire responses: answers to guided questions about your background, achievements, and case context.
- Subscription and billing information: payment details are processed by our payment processor and are not stored on Meritocrat's servers.
You are responsible for ensuring that the information, documents, and materials you provide to the Platform are accurate, complete, and not misleading. The quality and reliability of AI-generated outputs depend materially on the accuracy and completeness of the information you provide.
3.2 Sensitive Personal Information
Immigration status and citizenship information are sensitive personal information under the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA). We collect and use this category of information solely to provide the Platform's core services. We do not sell this information or use it for advertising.
3.3 Attorney Workspace Information
If you are an immigration attorney or law firm administrator, we collect: account and subscription information for your firm's workspace; case workspace data that you or your team enter, upload, or generate within the Platform; and attorney knowledge base content, if you enable the optional knowledge base feature. Knowledge base content may contain confidential legal work products. By uploading content to the knowledge base, you represent that you have the authority to do so and that uploading such content to a third-party system is consistent with your professional obligations. Meritocrat does not provide legal ethics guidance.
3.4 Automatically Collected Information
When you use the Platform, we automatically collect: log data (IP address, browser type, pages visited, timestamps, and referring URLs); device information; usage data; and cookies and similar technologies used for authentication, session management, and Platform analytics.
3.5 AI Interaction Logs
When you use AI-assisted features on the Platform, prompts and outputs may be logged for service reliability, quality, and debugging purposes. AI interaction logs are not used to train foundation models.
4. How We Use Your Information
We use the information we collect to:
- Provide the Platform: organize your evidence, evaluate petition readiness, map information to visa criteria, generate readiness signals, and produce attorney-reviewable workspace outputs.
- Operate and improve the Platform: fix bugs, improve features, conduct analytics, and develop new capabilities.
- Communicate with you: send account notifications, service updates, and support responses.
- Process payments and manage subscriptions.
- Comply with legal obligations and respond to lawful requests from government authorities.
- Protect the security and integrity of the Platform.
We do not use your personal information, including immigration case data or attorney knowledge base content, to train AI foundation models.
5. AI-Assisted Processing
The Platform uses artificial intelligence, including large language model (LLM) technology, to analyze the information you provide and generate case readiness signals, evidence maps, and workspace outputs. This AI-assisted processing is a core feature of the service you are purchasing.
AI-generated outputs are informational and organizational in nature only. They do not constitute legal advice, a legal opinion, a legal assessment of your case, or a prediction of immigration outcomes, regardless of how they are framed, labeled, or presented within the Platform. AI-generated outputs are starting points and organizational aids only — they may contain errors, omissions, inaccuracies, or outdated information, and should not be relied upon without independent review.
The Company does not guarantee that use of the Platform will result in approval of any visa petition, a favorable adjudication, or any other particular immigration outcome.
5.1 Notice of Automated Decision-Making Technology
The Platform uses automated decision-making technology ("ADMT") — including large language model processing and AI-assisted analysis — to generate outputs such as case readiness signals, evidence maps, and gap analyses from the information you provide.
If you are a California resident, you have the right to opt out of ADMT processing of your personal information where that processing constitutes the use of automated decision-making for a "significant decision" affecting you. You may submit an opt-out request at any time by contacting us at legal@meritocrat.us with the subject line "ADMT Opt-Out Request."
If you opt out of ADMT processing, the Platform's AI-assisted features will no longer generate outputs from your personal information. You may still use the Platform to upload and organize documents manually. Opting out does not affect your subscription status or billing.
7. Data Retention
We retain your personal information for as long as your account, role, or workspace is active. Upon account termination, role removal, or contract termination, active user and case data will be deleted or returned within 30 days upon request or as specified in your applicable agreement. Backup copies may be retained temporarily beyond the 30-day window and are deleted according to our normal backup lifecycle. Deletion certification is available upon request at legal@meritocrat.us.
We may retain certain information as required by applicable law or as necessary for legitimate business purposes such as dispute resolution and enforcement of our agreements.
8. Your Privacy Rights
8.1 California Residents (CCPA/CPRA)
If you are a California resident, you have the following rights:
- Right to know: request that we disclose the categories and specific pieces of personal information we have collected about you.
- Right to delete: request deletion of your personal information, subject to certain exceptions.
- Right to correct: request correction of inaccurate personal information.
- Right to portability: receive a copy of your personal information in a portable format.
- Right to limit use of sensitive personal information: request that we limit our use of your sensitive personal information to what is necessary to provide the services you request.
- Right not to be discriminated against for exercising your privacy rights.
To submit a request, contact us at legal@meritocrat.us. We will respond to verified requests within 45 days, with a possible 45-day extension for complex requests.
8.2 Other US State Residents
Residents of states with comprehensive consumer data privacy laws have the following rights: right to access, right to delete, right to correct, right to portability, right to opt out of sale or sharing, right to opt out of profiling, and right to appeal. Contact us at legal@meritocrat.us with the subject line "Privacy Rights Request – [Your State]."
By creating an account and actively submitting your immigration information to the Platform, you provide your affirmative consent to the Company's processing of your immigration status and related information for the purposes described in this Privacy Policy. You may withdraw this consent at any time by contacting us at legal@meritocrat.us; however, withdrawal of consent will prevent us from providing the Platform's core services.
8.3 How to Submit a Request
Email legal@meritocrat.us with the subject line "Privacy Rights Request." Include your name, email address associated with your account, and a description of your request. We may ask you to verify your identity before processing your request.
10. Data Security
We implement technical and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit and at rest, access controls, and audit logging. No security system is impenetrable. In the event of a data breach, we will notify affected users and relevant authorities as required by applicable law. Attorney workspace customers will be notified within 72 hours of discovery of a breach affecting their workspace data.
11. Attorney Workspace — Additional Terms
When you use the Platform as an immigration attorney or law firm:
- You are the data controller for your clients' personal information that you enter or upload into your workspace. The Company processes that information on your behalf as a data processor.
- You are responsible for obtaining any necessary consents from your clients for the use of their information on the Platform and for complying with your professional privacy and confidentiality obligations.
- The optional attorney knowledge base feature indexes materials you upload to enable context-aware retrieval within your workspace only. Knowledge base content is strictly isolated — one firm's content is never accessible to another firm's workspace.
- Meritocrat does not use attorney workspace data, client case files, or knowledge base content to train AI foundation models.
12. Children's Privacy
The Platform is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child under 18, contact us at legal@meritocrat.us and we will delete it.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Policy on our website with a new effective date and, where appropriate, by sending you an email notification. Your continued use of the Platform after the effective date of an updated Policy constitutes your acceptance of the changes.
This Privacy Policy is incorporated into and governed by our Terms of Service. Any dispute arising out of or relating to this Privacy Policy is subject to the governing law and dispute resolution provisions of our Terms of Service.
14. Contact Us
For privacy questions, requests to exercise your rights, or concerns about our data practices, contact:
The Platform is designed and operated for users in the United States. If you are located outside the United States and choose to use the Platform, your personal information will be transferred to and processed in the United States. If you are located in the European Economic Area, the United Kingdom, or Switzerland, contact us at legal@meritocrat.us for information about how GDPR applies to your use of the Platform.
15. Expert Advisor Marketplace
15.1 What the Expert Advisor Marketplace Is
The Company operates a marketplace within its Platform and website through which former USCIS officers ("Expert Advisors") offer non-legal advisory services to visa applicants, immigration consulting companies, and immigration attorneys. The Expert Advisor service is a separate product from the Meritocrat subscription Platform. Expert Advisors do not access your Meritocrat subscription data, case files, uploaded documents, or AI-generated outputs.
15.2 Advisor Relationship Disclosure
Some Expert Advisors listed on the Platform are equity holders in xoCaliber Inc. and receive compensation through the Company for sessions booked through the Platform. Expert Advisors operate through their own independent business entities and are not employees or agents of the Company. The Company does not supervise, control, or guarantee the content of advisory sessions.
15.3 Information We Collect for the Marketplace
When you use the Expert Advisor marketplace, we collect: booking records, payment metadata, booking context notes (used only to facilitate your session), session completion records, and reviews and ratings if you submit a review. Booking context notes are not used for analytics, product improvement, or marketing.
15.4 How We Share Marketplace Information
Booking confirmation and your contact details are shared with the relevant advisor's business entity for session coordination purposes. We do not share your booking information with other users or third parties for marketing or advertising purposes.
15.5 Retention of Marketplace Records
Booking and payment records related to Expert Advisor sessions are retained for seven (7) years to comply with applicable tax and financial record-keeping requirements. Session completion and review records are retained in accordance with our standard account data retention practices described in Section 7.
15.6 The Advisor Service Is Not Legal Advice
Expert Advisors are former USCIS officers, not attorneys. Advisory sessions are informational and organizational in nature only and do not constitute legal advice, legal representation, a legal opinion, or a guarantee of any immigration outcome. Use of the Expert Advisor marketplace does not create an attorney-client relationship.
15.7 Third-Party Reviewers
The Platform may permit or facilitate review of Platform outputs or user case materials by third parties other than Expert Advisors and licensed attorneys ("Third-Party Reviewers"). Third-Party Reviewers are not attorneys and are not authorized to provide legal advice, legal opinions, or immigration representation. You are solely responsible for independently evaluating any Third-Party Reviewer feedback and for consulting a licensed immigration attorney before making any filing decision.
16. Meritocrat Attorney Connect
Attorney Connect is an opt-in directory of licensed attorneys who have voluntarily chosen to list themselves on the Meritocrat Platform. Meritocrat does not recommend, rank, match, or select attorneys for applicants. The directory is a listing service only.
16.1 Attorney Profile Data
Attorneys who opt into the directory provide professional profile information including name, bar number, jurisdictions admitted, practice areas, firm name, and contact information. Attorneys may update or remove their profile at any time. Upon opt-out or account closure, directory profile data is removed from display within 24 hours and deleted from our systems within 30 days.
16.2 Applicant Use of the Directory
Applicant subscribers may browse the attorney directory and view attorney profiles. Browsing alone does not result in any applicant data being shared with directory attorneys. Browse activity is not used for recommendations, marketing, or AI model training.
16.3 Applicant-Controlled Sharing
Applicants may, at their own initiative, contact a directory attorney or share their prepared Company case materials with a specific attorney. This sharing is entirely applicant-directed. Before sharing, applicants will be shown a preview of the materials that will be sent and must confirm the action. The Company does not independently share applicant case materials with directory attorneys.
16.4 No Conflict Screening
The Company does not perform conflict-of-interest screening for directory attorneys. Attorneys listed in the directory are solely responsible for conducting their own conflict checks before accepting any matter.
16.5 Attorney Rights
Attorneys listed in the directory may access, correct, or delete their profile data at any time through their account settings. Attorneys may opt out of the directory without closing their Platform account. Contact us at legal@meritocrat.us for questions about directory profile data.
17. Project Studio — Attorney Subscription Product
Project Studio is a separate B2B subscription product for licensed attorneys and law firms. Attorneys and law firm personnel are the only users of Project Studio — clients do not access Project Studio directly.
17.1 Meritocrat's Role in Project Studio
When attorneys use Project Studio to work on their clients' immigration matters, the Company acts as a data processor — processing client personal data on the attorney's behalf and under the attorney's instructions. The attorney (or law firm) is the data controller for their clients' personal data in Project Studio. This processor relationship is governed by a Data Processing Agreement (DPA) executed between the Company and each attorney customer before any client data is processed in Project Studio.
17.2 What Data Is Processed in Project Studio
Attorneys may upload or input: client identity and contact information; immigration history, visa category, and application records; case documents and evidence materials; attorney work product including drafts, research memos, and strategic notes; and any other materials the attorney chooses to upload for case work.
17.3 AI Processing in Project Studio
AI processing in Project Studio is performed under the attorney's direction and instruction. The Company does not use data processed in Project Studio — including client case files, attorney work product, privileged communications, or AI-generated outputs — to train, fine-tune, or improve any artificial intelligence or machine learning model. This prohibition applies to Meritocrat and to all subprocessors.
17.4 Team and Firm Access
Project Studio supports team-based access for attorneys and law firms. Access to client case records is controlled at the matter level and is logged — all access events are recorded with a timestamp, user identifier, and matter identifier.
17.5 Data Subject Rights for Attorney Clients
Because Meritocrat acts as a processor for client data in Project Studio, data subject rights requests from attorney clients should be directed to the attorney or law firm as the data controller. Meritocrat assists attorneys in fulfilling those requests in accordance with the DPA. If you are unsure how to reach your attorney through Meritocrat, contact us at legal@meritocrat.us.
17.6 Dual-Track Clients
If you are an immigration applicant who both holds the Platform applicant subscription and whose attorney also uses Project Studio for your matter, your data exists in two separate tracks with different legal frameworks. A data rights request concerning your applicant subscription is handled directly by the Company. A request concerning your data in your attorney's Project Studio workspace should be directed to your attorney.
17.7 Retention
Client data in Project Studio is retained for the duration of the attorney's active subscription. Upon subscription termination or the attorney's deletion request, client data is deleted or returned within 30 days, per the terms of the DPA. Backup copies are deleted within 90 days of the deletion instruction.
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