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Privacy Policy

Last updated: June 23, 2026

Last updated: June 23, 2026

1. SCOPE AND RELATIONSHIP TO THE TERMS OF SERVICE

This Privacy Policy (the "Policy") describes how CallRank.AI LLC ("CallRank," "we," "us," or "our") collects, uses, discloses, retains, and protects personal information in connection with the CallRank service, including the website located at callrank.ai (or any successor domain), the associated APIs, mobile applications, email communications, and any related services (collectively, the "Service").

Where the UK GDPR applies, references to "personal information" should be read as "personal data" within the meaning of Article 4(1) UK GDPR. Where the CCPA and CPRA apply, "personal information" has the meaning given in California Civil Code Section 1798.140.

This Policy is incorporated into the Terms of Service by reference and forms part of the agreement between you and CallRank. Where this Policy and the Terms address the processing of personal information, this Policy controls.

This Policy applies:

Capitalized terms not defined in this Policy have the meanings given to them in the Terms of Service. The Terms define "Scored Individual," "Public Post," "CallRank Score," "Scored Output," "Stat Card," "Watchlist," "Insights," "AI Chat," "Elite Subscriber," and "Subscriber."

2. WHO WE ARE

CallRank is operated by CallRank.AI LLC, a New Jersey limited liability company with its principal place of business at 971 US Highway 202N, Suite R, Branchburg, New Jersey 08876. For the purposes of the UK GDPR, CallRank.AI LLC is the data controller of the personal data described in this Policy and determines the purposes and means of processing. The subprocessors listed in Appendix C act as data processors on CallRank's behalf under written contract within the meaning of Article 28 UK GDPR.

Where required by law, CallRank has appointed an Article 27 UK representative as set out in Section 16. On the subscriber side, CallRank is a US-targeted product: marketing, language, currency, and payment methods are not localized to any non-US jurisdiction. Subscribers who access the Service from jurisdictions other than the United States do so on the Service's standard terms. On the Scored-Individual side, the Service publishes editorial commentary about public-figure forecasters globally, including UK residents; that processing is conducted as editorial analytical journalism under UK GDPR Article 85 and the UK Data Protection Act 2018, Schedule 2, Part 5, with the rights mechanism set out in Section 13.

3. PERSONAL INFORMATION WE COLLECT FROM SUBSCRIBERS AND VISITORS

We collect the following categories of personal information from Subscribers and Visitors.

3.1 Information You Provide Directly

3.2 Information Collected Automatically

3.3 Information From Third Parties

3.4 Information We Do Not Collect

We do not collect: precise geolocation, government-issued identifiers, biometric data, or special-category personal data within the meaning of Article 9 UK GDPR. We do not knowingly collect information from persons under 18.

4. PERSONAL DATA WE PROCESS ABOUT SCORED INDIVIDUALS

Independently of any account relationship, the Service ingests and evaluates public statements authored by Scored Individuals and publishes editorial commentary derived from that evaluation. The categories of personal data processed about Scored Individuals are:

We do not ingest content from accounts that have made their posts non-public, and we do not attempt to circumvent platform-level privacy controls. If a Public Post is deleted at its source platform after ingestion, we delete the raw text from active storage within twenty-four (24) hours of receiving notice of the deletion, while retaining derived analytical metadata (CallRank Score, post identifier, timestamp, deletion marker) as part of the published audit trail.

Processing of personal data about Scored Individuals is conducted as editorial analytical journalism on public-figure conduct, within the meaning of the journalism exemption at UK GDPR Article 85 and the UK Data Protection Act 2018, Schedule 2, Part 5. The lawful-basis architecture is set out in Section 6, and the rights mechanism specific to Scored Individuals as data subjects is set out in Section 13.

Special-category data within the meaning of Article 9 UK GDPR are not collected as scoring inputs and are not systematically processed by the Service. Public Posts may incidentally contain content that touches on a special category (for example, a forecaster's reference to a political event). The analytical pipeline does not classify, extract, infer, or score on Article 9 attributes; references of that kind are not used to characterize the Scored Individual.

Even where the journalism exemption at UK GDPR Article 85 and the UK Data Protection Act 2018, Schedule 2, Part 5 would permit derogation from a specific obligation, CallRank voluntarily implements the safeguards set out in this Policy, including the editorial standards described in Section 13.3, the Data Protection Impact Assessment, and the published inquiry process. The exemption availability does not displace these safeguards in practice.

5. HOW WE USE PERSONAL INFORMATION

We use personal information for the following purposes:

We do not sell personal information for monetary consideration, and we do not engage in cross-context behavioral advertising. We do not use personal information to train third-party large-language models. See Section 8 regarding our use of third-party model-inference providers.

AI Chat feature data path. When an Elite Subscriber uses the AI Chat feature, the Subscriber's prompt text is sent to Anthropic, Inc. via the Claude API for response generation. The prompt is combined with a CallRank system prompt that bounds the response to descriptive output about CallRank's historical scored dataset. Anthropic processes the combined payload as a data processor from data centers located in the United States; the transfer is conducted under the international-transfer mechanism described in Section 8. Anthropic returns the response to CallRank for rendering to the Subscriber. CallRank does not provide the Subscriber's account information to Anthropic in the API payload. Under Anthropic's commercial API terms, Anthropic does not use AI Chat inputs or outputs to train its general-purpose Claude models. CallRank logs each AI Chat prompt and the model response for refusal-rate measurement, dataset-gap identification, and Subscriber-flagged-event review under the residual-risk allocation in the Terms; the log entries are stored under the retention period set out in Section 10.

Editorial pipeline data path. Public Post content ingested for editorial scoring is sent to Anthropic, Inc. for analytical processing, including natural-language interpretation, chart interpretation, and forecast classification. Subscriber personal information is not included in any payload sent to these providers. The data sent comprise the Public Post content and the post identifiers required to associate the analytical output back to the source post in the audit trail. Under their applicable API terms, these providers do not use the Public Post content sent to them to train their general-purpose models. Transfers to providers located outside the United Kingdom are conducted under the international-transfer mechanism described in Section 8.

Stat Cards. When a Subscriber or Scored Individual generates a Stat Card image through the Service, CallRank records the generation event, the Stat Card identifier, the requesting account if the request originates from a Subscriber account, and the issue date. The Stat Card image itself does not embed any Subscriber personal information. Stat Cards shared by Subscribers or Scored Individuals on public social platforms travel with the embedded methodology disclaimer required by the Terms; CallRank does not track downstream sharing or reshares of Stat Cards on public platforms.

6. LAWFUL BASES FOR PROCESSING (UK GDPR)

Where the UK GDPR applies, we rely on the following lawful bases under Article 6(1).

6.1 Lawful-Basis Table

6.2 Legitimate Interests Assessment Summary

Where we rely on legitimate interests under Article 6(1)(f) to process personal data about Scored Individuals, we have conducted a Legitimate Interests Assessment ("LIA") that records the following.

The LIA is documented and in place as of the effective date of this Policy; the summary in this Section is the operative record of that assessment. A more detailed, public-facing LIA is planned as Phase 3 work and will supplement, not replace, the assessment described above. A copy of the documented LIA is available on request to callranksupport@gmail.com.

6.3 Article 22

Editorial CallRank Scores do not produce legal effects or similarly significant effects on the data subject within the meaning of UK GDPR Article 22(1). The Service does not engage in automated individual decision-making, including profiling, that produces legal effects concerning the data subject or similarly significantly affects the data subject. Scored Outputs are editorial commentary published on the Service; they do not deny credit, deny employment, deny insurance, or deny any other entitlement to the Scored Individual. CallRank does not use Scored Outputs to make credit, employment, insurance, or comparable adverse decisions about Scored Individuals. The Terms of Service prohibit Subscribers from redistributing or republishing Scored Outputs as investment advice or as the output of a regulated advisory service. Article 22 is not engaged for the use case set out in this Policy.

The editorial safeguards described in Section 13.3, including manual review of contested Scored Outputs and the Data Protection Impact Assessment, are voluntary editorial standards adopted as best practice for a responsible analytical publisher. They are not Article 22 safeguards and CallRank does not invoke them as such.

7. HOW WE SHARE PERSONAL INFORMATION

We share personal information only as described below.

8. SUBPROCESSORS AND INTERNATIONAL TRANSFERS

Our subprocessors are listed in Appendix C. We update Appendix C when we add or replace a subprocessor; Subscribers may request advance notice of subprocessor changes by emailing callranksupport@gmail.com.

CallRank is operated from the United States, and our subprocessors are located in the United States. Where personal data are transferred from the United Kingdom to a country that the UK has not recognized as providing an adequate level of protection, we rely on the UK International Data Transfer Addendum ("IDTA") to the European Commission Standard Contractual Clauses ("SCCs") and supplementary technical and organizational measures appropriate to the transfer.

9. COOKIES AND SIMILAR TECHNOLOGIES

We use a small number of cookies and similar technologies, organized into the following categories.

We do not use third-party advertising cookies and we do not participate in cross-context behavioral advertising. You may manage cookie preferences at any time through the cookie banner or in Settings.

10. DATA RETENTION

We retain personal information only for as long as necessary for the purposes for which it was collected, subject to legal, accounting, and reporting requirements. Default retention periods are set out below.

11. SECURITY

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, alteration, disclosure, and destruction. These include encryption in transit (TLS 1.2 or higher), encryption at rest for production databases, role-based access controls, audit logging, vulnerability scanning, and a documented incident response process. Internal access to Subscriber and Scored Individual personal information is restricted under least-privilege principles to the smallest engineering and editorial team necessary to operate the Service; access to production data systems is logged.

No system is perfectly secure. If we become aware of a personal data breach within the meaning of Article 4(12) UK GDPR that is likely to result in a risk to the rights and freedoms of data subjects, we will notify the Information Commissioner's Office ("ICO") within 72 hours of becoming aware, where required by law, and notify affected data subjects without undue delay where the breach is likely to result in a high risk.

12. YOUR RIGHTS

Subject to applicable law, as a data subject you have the following rights with respect to personal information we process about you.

Subscribers can exercise the rights of access, rectification, portability, and erasure directly in Settings. Other rights may be exercised by emailing callranksupport@gmail.com. We will respond to verified requests within the timeframes required by applicable law (generally 30 days under the UK GDPR; 45 days under the CCPA, extendable as permitted).

California residents have additional rights under the CCPA and CPRA, including the right to know the categories of personal information collected, the right to opt out of sale or sharing for cross-context behavioral advertising (we do not engage in either), the right to limit the use of sensitive personal information (we do not collect sensitive personal information as that term is defined under the CPRA), and the right not to be discriminated against for exercising these rights. See Appendix D for the CCPA and CPRA categories disclosure.

Because CallRank does not sell personal information and does not share personal information for cross-context behavioral advertising as those terms are defined in the CPRA, CallRank does not provide "Do Not Sell or Share My Personal Information" links. Because CallRank does not collect or process sensitive personal information as that term is defined under the CPRA, CallRank does not offer a "Limit the Use of My Sensitive Personal Information" control.

13. RIGHTS OF SCORED INDIVIDUALS

13.1 Statutory Rights

Scored Individuals have the statutory rights of a data subject set out in Section 12 with respect to personal data processed about them, including the right of access, the right to request rectification of factual errors, the right to object to processing carried out on the basis of legitimate interests under Article 21 UK GDPR, and the right to request erasure under Article 17 UK GDPR.

Where a Scored Individual exercises the right of erasure, we evaluate the request under Article 17 UK GDPR and the journalism exemption at UK GDPR Article 85 and the UK Data Protection Act 2018, Schedule 2, Part 5. Where the underlying Public Post has been deleted at its source platform, we treat the deletion as a request to update the corresponding record under Section 4. Where the underlying Public Post remains public, erasure of the Scored Output may be refused under Article 17(3) UK GDPR, as implemented in the United Kingdom by Schedule 2, Part 5 of the Data Protection Act 2018, which permits the processing of personal data for the special purposes of journalism in connection with editorial commentary on matters of public interest.

Where a Scored Individual exercises the right to object under Article 21, we reassess the legitimate-interest balancing exercise recorded in Section 6.2 in light of the data subject's specific situation. We will either continue processing on the basis of compelling legitimate grounds (which we will explain in writing) or cease processing.

13.2 Published Inquiry Process

Independently of the statutory rights set out in Section 13.1, CallRank maintains a published inquiry process as a standard of responsible analytical journalism. The inquiry process is the recommended channel for the substantive concerns Scored Individuals raise most often: misclassification of forecast type or direction, incorrect evaluation-window selection, errors in component values, factual errors in the underlying market data, misquotation of the source Public Post, and misattribution of a post. Inquiries are accepted from any Scored Individual, regardless of whether the Scored Individual has created an account, subscribed to the Service, or asserted a statutory data-subject right.

Scored Individuals may submit inquiries through the channel published in the separate Scored Individual Policy at callrank.ai/scored-individual-policy. The Scored Individual Policy describes the intake channel, the response timelines, the identity-verification step, and the triage between factual-error correction and methodology-disagreement inquiries. CallRank acknowledges receipt of inquiries within the published timeline and responds substantively within the published timeline.

Inquiries are routed to disputes@callrank.ai. The inquiry process is editorial; it operates alongside the statutory rights described in Section 13.1 and does not condition, suspend, or replace any statutory right.

13.3 Voluntary Editorial Safeguards

These safeguards are voluntary editorial standards, not safeguards adopted to satisfy a specific statutory requirement; they apply to the production of editorial commentary and operate alongside the statutory rights set out in Section 13.1.

13.4 Relationship to Article 22

CallRank's editorial safeguards described in Section 13.3, including manual review of contested Scored Outputs and the DPIA, are voluntary editorial standards adopted as best practice for a responsible analytical publisher. They are not Article 22 safeguards and CallRank does not invoke them as such.

14. CHILDREN

The Service is not directed to and may not be used by persons under 18 years of age (or the age of legal majority in your jurisdiction, whichever is greater). We do not knowingly collect personal information from persons under that age. If we learn that we have collected personal information from a person under that age, we will delete it promptly. If you believe a child has provided personal information to us, please contact callranksupport@gmail.com.

15. CHANGES TO THIS POLICY

We may update this Policy from time to time. Where the changes are material, for example a new category of personal information collected, a new purpose of use, or a new category of recipients, we will give Subscribers at least 30 days' advance notice by email and through a prominent in-product notice, and the change will take effect at the end of that notice period. Non-material changes, for example clarifications of existing language or updates to the subprocessor list within an existing category, will take effect when posted, and the "Last updated" date at the top of this Policy will be revised.

16. CONTACT

Questions, requests, and complaints relating to this Policy should be directed to:

CallRank.AI LLC

971 US Highway 202N, Suite R, Branchburg, New Jersey 08876

Email: callranksupport@gmail.com

Scored Individual inquiries: disputes@callrank.ai

CallRank has not designated a Data Protection Officer under Article 37 UK GDPR; data-protection queries may be directed to callranksupport@gmail.com.

APPENDIX C: SUBPROCESSOR LIST

The following data processors and subprocessors process personal information on our behalf as of the effective date of this Policy, under written contracts within the meaning of Article 28 UK GDPR. We update this list when we add or replace a subprocessor; Subscribers may request advance notice of subprocessor changes by emailing callranksupport@gmail.com.

APPENDIX D: CATEGORIES OF PERSONAL INFORMATION (CCPA / CPRA DISCLOSURE)

The table below sets out the categories of personal information defined in California Civil Code Section 1798.140, indicates whether CallRank has collected each category in the preceding 12 months, and identifies the categories of sources, business or commercial purposes, and recipients.

CallRank has not sold personal information for monetary consideration in the preceding 12 months and does not share personal information for cross-context behavioral advertising. CallRank does not knowingly collect personal information from persons under 18.

End of Privacy Policy.