Conflicts and Data-Firewall Policy
Ethics by design and privacy by design for a lawyer-owned platform that assesses lawyers.
Purpose and Scope
Ariadni LLC ("Ariadni") is a software platform that helps legal-services buyers ("Users") monitor counsel, including by scoring the quality, fee reasonableness, authorship, and responsiveness of lawyers and firms. Ariadni is owned by Damian Guzman, a California- and New York-licensed attorney, who also practices law under FTE Legal, a Social Purpose Corporation, a California social-purpose professional law corporation ("FTE Legal"). That overlap is the reason this policy exists. A lawyer who owns a tool that assesses lawyers, and who offers that tool to his own clients, sits astride several duties at once. This policy sets the guardrails that keep those roles separate, so that Ariadni can be trusted by the lawyers it assesses and their clients who use it, and so that FTE Legal never gains, and is never seen to gain, an improper advantage.
This policy binds Ariadni, its operators, and Guzman in his capacity as owner. It is a governance instrument, not legal advice to any user, and it does not create rights in third parties. Where it references rules of professional conduct, those references are guides to the values at stake; the controlling text is the current California and New York Rules of Professional Conduct. Ariadni provides information to the User, not legal advice, and use of it creates no attorney-client relationship with Ariadni or its owner; Users are encouraged to rely on their own legal ethics counsel. The Service includes an email intake feature, AskAriadni, through which a User may email Ariadni and receive an automated read; it is part of the Service and subject to this policy in full.
Core Principle: The One-Way Wall
Everything below follows from a single rule. Ariadni data and Users flow in one direction only. Nothing that Ariadni learns, holds, or observes may be used to benefit FTE Legal or Guzman as a practicing lawyer, and nothing about FTE Legal’s interests may reach into Ariadni’s data or influence how Ariadni scores anyone. The wall runs both ways: FTE cannot reach in, and Ariadni cannot reach out.
Founder Data Firewall
The owner and FTE Legal must be unable, not merely unwilling, to see the substance of what Ariadni holds. This is enforced by architecture, not by trust.
• No administrative read path exists. Every data endpoint returns only the requesting user’s own record, scoped by that user’s authenticated session. There is no endpoint that lists users, returns another user’s documents or scores, or exposes the user index to any user-facing surface.
• User documents are not retained. Documents are read in transit for a single analysis and are not stored by Ariadni; credentials are encrypted at rest.
• The AskAriadni email intake is subject to the same firewall. Inbound messages and attachments are processed in transit for a single automated reply and are not stored, and the owner has no access to them.
• The owner does not access individual user data, documents, inbox metadata, or any lawyer or firm assessed through Ariadni ("Scored Lawyers"). Scored Lawyers do not opt in and are typically not Ariadni users. Where operational access to infrastructure is unavoidable, it is logged, and substantive user content remains outside the owner’s reach.
• If Ariadni ever needs an operations role that can touch user data, that role is held by someone other than Guzman, or by a neutral third party, and is screened from FTE Legal.
No Lead-Mining and No Solicitation from the User Base
A person who signs up to monitor their counsel is, by definition, someone who may be dissatisfied with a lawyer. That makes Ariadni’s user base the most tempting prospect list imaginable for a law practice, and it is entirely off limits.
• Ariadni’s users, signups, usage, and any dissatisfaction signal may never be used to identify, target, or solicit clients for FTE Legal.
• FTE Legal may not be pitched, advertised, or promoted to Ariadni users through the product, its communications, or any list derived from it. Ariadni’s communications are about Ariadni.
• The prohibition is on using the platform to solicit. It does not restrict ordinary, rule-compliant advertising by FTE Legal to the general public through channels unconnected to Ariadni.
No Communicating or Using Scored Lawyer Results
A Scored Lawyer’s Ariadni output belongs to the User who generated it and to no one else. The owner and FTE Legal must never receive, relay, publish, or act on it. Because an assessment is the client’s own private instrument, and the owner neither sees nor shapes any individual result, no assessment is the owner’s statement about any lawyer.
• Results about any lawyer are not communicated to clients, prospects, or anyone else by the owner or FTE Legal.
• Ariadni knowledge about a lawyer is never used in FTE Legal’s practice, including in litigation or negotiation. If FTE is across the table from a lawyer who appears in Ariadni, nothing the platform knows may be used.
• Ariadni knowledge never informs an FTE Legal conflicts check or intake decision, because under the firewall it does not reach the firm at all.
Scoring Neutrality and Integrity
Because the owner competes with the lawyers being scored, the engine must be provably even-handed, and the owner must be unable to put a thumb on the scale.
• Every lawyer is scored by the identical pipeline, including FTE Legal. There is no per-firm special-casing in the code, and none may be added.
• The self-assessment path is the same as every other path. When a client points Ariadni at FTE Legal, FTE is scored exactly as any other firm would be. Subjecting the owner’s own work to the same scrutiny is a feature and is encouraged.
• No one, including the owner, can edit, suppress, boost, or delete a score, whether the owner’s own or a competitor’s. There is no score-mutation path in the product.
• The scoring rubric is documented and versioned. Changes are recorded, and no change may be designed to favor FTE Legal or disfavor a competitor. The methodology is available for inspection, so its neutrality can be tested rather than taken on trust.
No Public Rankings and No Use of Scores in Marketing
Scored Lawyers never consented to being graded. Keeping their scores private is both fair and the way to avoid defamation, interference, and unfair-competition exposure, all of which are heightened because the owner is a competitor. To limit that exposure, assessments stay specific and anchored to the document under review, and avoid conclusory judgments about a lawyer’s character or competence.
• Scores are private to the User who generated them. Ariadni does not publish, aggregate into a public leaderboard, or otherwise broadcast Scored Lawyer scores.
• FTE Legal does not cite, quote, or imply an Ariadni score in its own marketing, and does not describe itself as Ariadni-rated or use any score as an endorsement.
• Ariadni's assessments remain framed as observations supported by evidence, not as accusations or findings.
Client-Representation Firewall
For clients who both retain FTE Legal and use Ariadni, the two relationships stay separate.
• Representation is never conditioned on using Ariadni, and access to Ariadni is never conditioned on retaining or remaining a client.
• A client’s use of Ariadni, and any result it produces, does not enter the representation, the advice given, or the fee charged.
• If a client points Ariadni at FTE Legal and receives a mediocre or poor result, there is no retaliation and no effect on the engagement. The tool’s output about FTE is walled off from how FTE treats the client.
Third-Party Confidentiality and Privacy by Design
Ariadni handles Users’ confidential and sometimes privileged material, including material concerning parties adverse to FTE Legal. Privacy is designed in, not added on.
• Absolute bar on document access. Neither the owner nor FTE Legal accesses any User’s documents through Ariadni. This is enforced by the same architecture as the founder firewall. This holds even where a User monitors counsel adverse to FTE Legal in a live matter; the firewall gives the owner no access in that case or any other.
• Data segregation in both directions. Ariadni user data does not flow into FTE Legal systems, and FTE client data does not flow into Ariadni beyond the minimum described below.
• Minimized, one-way client allowlist. If FTE clients receive Ariadni access as a benefit, membership is verified from a minimized, one-way feed. Client identifiers are stored as hashes or as a domain-level allowlist rather than a plaintext client roster, or membership is checked without warehousing the list at all. The feed is refreshed on a schedule and never flows back to FTE Legal.
• Data minimization and retention. Ariadni collects the least it needs, does not retain document text after analysis, and provides users with retention and deletion controls. Scores and a de-identified assessment history persist on the User’s own record until the User unsubscribes or deletes the relevant matter, record, or account. For the AskAriadni email intake, no message content or attachments are retained; only a hashed, aggregate usage count is kept to enforce rate limits.
• Honest de-identification. De-identification is imperfect. Users are told plainly that document text is analyzed on a third-party AI interface and that de-identification is not a guarantee.
• Incident response. A breach or exposure triggers a defined response, including notice where appropriate.
Disclosure and Consent to Clients
When Ariadni is offered to FTE Legal clients, the offer is transparent and optional. The prudent course treats the arrangement with the care the business-transaction-with-a-client rules call for, even where a free benefit may not squarely trigger them.
• Clients are told, in plain language and in writing, that Guzman owns Ariadni, that it is a separate company, that use is optional, and that it is independent of the legal engagement.
• Clients are told what Ariadni accesses, that document text is analyzed on a third-party AI interface, and that de-identification is imperfect.
• Where appropriate, informed written consent is obtained, and clients are advised of the desirability of independent advice, consistent with California Rule 1.8.1 and New York Rule 1.8(a).
• The offer is made available, not pushed. FTE Legal does not steer or pressure clients toward a product the owner profits from.
Advertising and Solicitation Discipline
Any outward description of Ariadni as a client benefit is marketing and runs through the same attorney-advertising discipline FTE Legal already applies. Claims are truthful and substantiated, comparisons and endorsements follow the rules, and nothing implies that Ariadni’s assessments are a service of the law firm.
Governance
• This policy is adopted in writing and reviewed at least annually, and whenever the product or the offering to clients materially changes.
• A screen separates the owner from any Ariadni operations role that can reach user data; where feasible that role sits with a neutral operator.
• Access to infrastructure is logged and auditable.
• The Ariadni use case is run through an impact assessment and use-case triage, and the record is retained.
• The separation of the two entities is maintained in branding, communications, books, and systems. An FTE-Legal-branded client edition is disfavored precisely because it re-entangles what this policy keeps apart.
Enforcement
How each guardrail is enforced today, and what remains to be built.
• Self-scoped data access; no admin or cross-user read.
Enforcement: Code (architecture). Status: In place, verified.
• No score-mutation path.
Enforcement: Code. Status: In place, verified.
• No per-firm special-casing; self-assessment parity.
Enforcement: Code. Status: In place, verified.
• Document-anchored, non-conclusory output.
Enforcement: Code. Status: In place.
• Credentials encrypted at rest; documents not stored.
Enforcement: Code. Status: In place.
• One-way, minimized, hashed client allowlist.
Enforcement: Code. Status: To build.
• In-app disclaimers (not legal advice; owner cannot access; ownership). Enforcement: Product. Status: To build.
• Published, inspectable scoring methodology.
Enforcement: Governance. Status: To build.
• No lead-mining from the user base.
Enforcement: Policy. Status: Adopt and observe.
• No communicating or using Scored Lawyer results.
Enforcement: Policy. Status: Adopt and observe.
• No public rankings; no scores in FTE Legal marketing.
Enforcement: Policy. Status: Adopt and observe.
• No tying; no retaliation; representation firewall.
Enforcement: Policy. Status: Adopt and observe.
• Screen or neutral operator; audit; impact assessment.
Enforcement: Governance. Status: Adopt and observe.