Privacy Policy

Effective Date: 13 August 2025

Company: Unravel Global, Inc. ("Company", "we", "us")

Service: Unravel Global Platform ("Platform") - an online service for contracted business customers ("Customers") to submit verification requests ("Verification Requests") for review by our network of independent fact-checkers and journalists ("Fact-Checkers") and receive fact-check reports ("Results").

By using the Platform, you agree to these Terms. If you do not agree, do not use the Platform.

1. Scope

This Privacy Policy explains how we collect, use, and protect personal data processed via the Platform.

This policy applies to:

• Authorized representatives of Customers
• Independent fact-checkers (“Fact-Checkers”) engaged in the verification process
• Visitors to our corporate website (if applicable)

2. Roles Under Data Protection Laws

• Customer as Data Controller: Customers are the “data controller” for all personal data contained in their Verification Requests or other content they submit.
• Company as Data Processor: We process that personal data only as instructed by the Customer, in line with the Data Processing Agreement (DPA) in the Customer’s contract.
• For personal data about our own contacts (e.g., account managers, billing contacts), we are the data controller.

3. Personal Data We Process

We may process the following categories of personal data:

• Platform Account Data: name, work email, job title, company, login credentials
• Verification Request Data: any information included in claims or supporting material (text, images, links, metadata) — which may include names, photos, social handles, or other personal identifiersCustomer Content: Customers retain ownership of Verification Requests and any supporting material ("Customer Content") submitted to the Platform. By submitting Customer Content, you grant us a non-exclusive, worldwide, royalty-free license to use it internally only for:
  -  Processing the Verification Requests
  - Improving our services (including AI model training and classifier development)
  - Quality assurance, auditing, and record keeping
  
• Usage Data: IP addresses, browser type, activity logs, and security logs
  
• Fact-Checker Data: profile information, communications, payment details (if applicable)
  

4. Sources of Data

We receive personal data from:

• Customers directly via account creation or Verification Requests
• Publicly available sources, if included in claims submitted by Customers
  
• Automated collection (usage logs, security monitoring)
  

5. Purposes and Legal Bases of Processing

We process personal data for:

• Delivering and operating the Platform
• Processing and verifying submitted claims
  
• Providing Results to Customers
  
• Security, fraud prevention, and compliance
  
• Improving our services (including internal AI model training)
  

Legal bases under GDPR (as applicable):

• Performance of contract (Art. 6(1)(b))
• Legitimate interests (Art. 6(1)(f)) — e.g., security, quality control
  
• Compliance with legal obligations (Art. 6(1)(c))
  

Note for Customers: You are responsible for ensuring a valid lawful basis for all personal data you submit to us.

6. Data Sharing

We share personal data only with:

• Independent Fact-Checkers under contractual confidentiality obligations
• Service providers supporting the Platform (e.g., hosting, security)
  
• Legal authorities, when required by law
  

We do not sell personal data.

7. Data Location and Transfers

We may store and process data in multiple jurisdictions. Where required, we implement appropriate safeguards for international transfers (e.g., EU Standard Contractual Clauses).

8. Retention

We retain personal data for as long as necessary to:

• Fulfill the purposes outlined above
• Meet legal, contractual, or audit requirements
  
• Customer Content and Results may be retained after account termination for compliance, auditing, and internal use, unless otherwise agreed.
  

9. Security

We implement technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These include access controls, encryption, monitoring, and regular security reviews.

10. Your Rights

If you are in the EU/EEA/UK (GDPR) or California (CCPA), you may have rights to:

• Access, correct, or delete personal data
• Restrict or object to certain processing
  
• Data portability
  
• Not be discriminated against for exercising CCPA rights
  Requests should be sent to: support@unravel.global
  When we act as a data processor, we will forward requests to the relevant Customer (data controller).
  

11. Children’s Data

The Platform is not intended for use by anyone under 16, and we do not knowingly process children’s personal data.

12. Changes to This Policy

We may update this Privacy Policy. Material changes will be communicated to active Customers.

13. Contact

Unravel Global, Inc.

2261 Market Street STE 85205,
San Francisco,
California, 94114

+1 (650) 300 0547