Below is a privacy policy established for the Media Intelligence & OSINT Platform: DALIL. DALIL is a platform developed to enhance the effectiveness of navigating through information overload globally, through AI-driven solutions.

This policy was last updated on October 27th , 2025.

This privacy policy (“Privacy Policy”) constitutes a legally binding agreement made between you, (“you” or “your”)and Siren Analytics and Consulting Limited. (“we,” “us”, or “our”) regarding your access to and use of the: (1) DALILdesktop website (the “Site”); (2) the DALIL software as a service platform (“Cloud Services”) and (3) any on premises deployments of DALIL provided to clients (“On Premises Services”).

This Privacy Policy covers the processing, collection, usage, storage and protection of Personal Data pertaining tousers of the DALIL Site in relation to the fact-checking services we provide (the “Services”).

By agreeing to this Privacy Policy, you agree to the collection, use, processing, and disclosure of your Personal Data inaccordance with the terms set out in this Privacy Policy.

Also, by using our Site and/or Services, you acknowledge that you have read and understood this Policy.

Definitions

The words of which the initial letter is capitalized have meanings defined under the following conditions. The followingdefinitions shall have the same meaning regardless of whether they appear in singular or in plural.

“Account” means a unique account created for you or your organization to access our Site or Services or parts of each.

“Cookies” are small files that are placed on your Device (as defined below) by the DALIL Site, containing the details ofyour browsing history on that Site among its many uses.

“Data Controller” means the entity that, alone or jointly with others, determines the purposes and means of theprocessing of Personal Data.

“Data Processor” means the entity that processes Personal Data on behalf of the Data Controller.

“Device” means any device that is used to access the DALIL Site.

“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable naturalperson is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, anidentification number, location data, an online identifier or to one or more factors specific to the physical, physiological,genetic, mental, economic, cultural or social identity of that natural person.

“Services” refers collectively to the Dalil website (“Site”), the Dalil SaaS platform (“Cloud Services”), and on-premises deployments of Dalil for clients (“On-Premises Services”).

“Usage Data" is usage related information such as the time spent by a User on the Site, the pages visited, the date andtime of visits.

"User” means you, the individual accessing and/or using the DALIL Site, or the company, or other legal entity onbehalf of which such individual is accessing and/or using the DALIL Site, as applicable. A User can be (a) A member ofa fact-checking organization (hereinafter referred to as the Fact-Checker), (b) a person that can identify themselves asa journalist[FH1]  (hereinafter referred to as the Journalist), and/or (c) any public or private organization using DALIL to manage and navigate information overload (hereinafter referred to as the Organizational User) d) any other individual using the DALIL Site (hereinafter referred to as the Public User).

Scope

This Privacy Policy has been established in compliance with the applicable data protection and privacy legislation, including but not limited to:  United Kingdom legislation i.e., the United Kingdom General Data Protection Regulation(the UK-GDPR) and the Data Protection Act 2018 (as amended in 2021 to be read in conjunction with the new UK-GDPR) as well as data protection and privacy principles enshrined in applicable international best practices (such asConvention 108+ and the European General Data Protection Regulation).

This Privacy Policy does not cover: (1) data through which the identification of a natural person is not possible, andwhich can be made available to the public; (2) Third party websites, applications, or digital services that may be linked from our Site or Services. Each of those third parties maintains its own privacy practices, and we encourage you to review their policies.

Please note that this Privacy Policy is only applicable to the use of direct services of the DALIL Site, the use of the DALIL SaaS platform, and does not extend to any other website, application or digital service that you may accessthrough our Site (if any), each of which may have their own privacy policies that differ from this one. This PrivacyPolicy relates solely to the online information collection and use practices of the DALIL Site. We recognize that youmay be concerned about the information you provide us with, and how we manage it. This Privacy Policy has beenestablished to address those concerns.

By asking you to carefully read and agree to this Privacy Policy, we want to ensure that your use of the DALIL Site is safeand that any Personal Data you might share with us or that we might collect throughout your user journey, is processed ina transparent, lawful, fair and secure manner.

Please read this Privacy Policy carefully so that you can understand what our policy and procedures areregarding the processing of your Personal Data.

Who is your data controller & data processor?

When processing your personal information through your use of the DALIL Site, we act as a data controller. This meansthat we are responsible for the protection of your personal information. We have appointed a Data Protection Officer to oversee compliance with applicable data protection laws. DPO can be contacted by users at the address specifiedbelow.

When you or your organization upload, submit, or process Customer Data through DALIL SaaS platform, we act as a Data Processor. In that case, your organization remains the Data Controller, and we process Customer Data only in accordance with your instructions and any applicable Data Processing Agreement.

For On-Premises Deployments, you or your organization are solely responsible as the Data Controller for all Customer Data hosted in your environment. We do not access or control that data, except where explicitly authorized for support or maintenance purposes.

What data is collected?

When using the DALIL Site, Cloud Services, or On-Premises Services, Personal Data may be collected; this includes (butis not limited to) the below:

If you are a registered User (including but not limited to researchers, analysts, journalists, enterprise or government representatives, or members of the public): upon signing up to the Site or Services, we will ask you to share with us and may use:

• Your first and last name

• Your date of birth

• Your gender

• Your contact details (particularly, your email address as provided by you or by another member of your organization who chooses to sign up)

• Your chosen username

• Your work affiliation

• Your countries of interest

• Your topics of interest

• Your subscription and billing details (for paid SaaS accounts)

Customer Data (Client-Provided Content): If you or your organization use the Dalil Cloud Services, you may upload, submit, or process content (“Customer Data’).

For Cloud Services, we process Customer Data on your behalf as a Data Processor, and your organization remains the Data Controller.

For On-Premises Services, Customer Data remains fully under your control, and we do not access it unless explicitly authorized for support or maintenance purposes.

Whenever you access the Site or Services whether a User or not, we will automatically collect and process the following Usage Data solely for analytical purposes as set out below:

• Device type and name

• Browser type and version

• Unique device identifiers and other diagnostic data

• Pages that are visited and time spent on the Site

• Date and time of visit

• Device operating system and version

• IP address and approximate location (where available)

• Log files, crash reports, and performance/feature usage data

When do we process your personal data?

We process the information listed above:

• When you visit and use the DALIL Site or Cloud Services

• When you create an account to sign up to the DALIL Site or SaaS platform

• When you register to one of the webinars/workshops advertised in the “Courses” section of the DALIL Site or through our communication channels

• When you submit a claim by contacting us either directly through the platform or by reaching out byWhatsApp, email, phone or any other communication channels

• Whenever you access the DALIL Site or Services but choose not to sign up, we will automatically collect andprocess the above-listed browsing information for the purpose of improving your and other users’ experienceon the DALIL Site and Services.

• When your organization uses Dalil On-Premises Services and we interact with you for support, maintenance, or account administration

• When you engage with us for billing, invoicing, customer support, or receive our newsletters/marketing communications (where permitted by law and with the option to opt out).

Why do we process your personal data?

Your first and last name as well as your contact details (email) are collected:

To allow you to create an account on DALIL Site or SaaS platform and authenticate you via email.

We may collect your email address from other members of your organization if they share it with us so that we can invite you by email to create your own account on DALIL 

To share updates that we think may be interesting to you based on the interests you shared with us(countries of interest, topics of interest), or in relation to your organization's subscription

• To contact you if necessary

If you are a Fact-Checker or a Journalist, or a member of a participating organization, your first and last name will also be displayed to other fact-checkers and journalists in the “Discussion” feature of the DALIL Site to enable you to interact live and chat with them in view of verifying authenticity of an information

Your gender may be collected to ensure gender mainstreaming objectives are met and for internal reporting or diversity monitoring when permitted by law.

Your professional details may be collected to identify your organization and to manage enterprise or government clients' accounts.

Information on your interests and preferences is used to personalize your experience and use of the DALIL Site and services.

Usage Data and other technical and analytics information are used to monitor the usage of the DALIL Site and Services, to provide and maintain it and to help us improve your user experience and for statistical purposes

Your Personal Data might be also used for business transfers (as we may use it to evaluate or conduct amerger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets,whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data heldby us about the users of DALIL is among the assets transferred. We will ensure that any acquiring entity or successor is bound to respect this Privacy Policy and applicable data protection laws.

What legal bases do we use to process your personal data?

Any processing of your Personal Data is based on one or many of the following lawful bases:

Consent: We rely on your consent for your creation of an account and the processing of the requested informationlisted above that enables you to create this account. At any time, you are free to withdraw your consent by deleting youraccount, after which the personal data collected for the creation of your account will be deleted from our servers.Similarly, we rely on your consent when you register to a workshop or an e-learning course through the DALIL Site.

Contractual necessity: We process Personal Data where it is necessary to perform a contract with you or your organization, or to take steps prior to entering into such a contract. This includes providing access to the DALIL SaaS platform, maintaining your account, processing payments, delivering support, and fulfilling service commitments.

Legitimate interest: We also often base the processing of your Personal Data on our legitimate interest in enhancingthe effectiveness of our services, whenever such processing is necessary and proportionate to that interest.

Legal obligations: We process Personal Data where necessary to comply with legal requirements, such as tax and accounting rules, anti-money laundering regulations, export controls, or respond to lawful requests from public authorities.

Vital interests (exceptional cases): In limited circumstances, we may process Personal Data to protect your vital interests or those of another person, such as in response to urgent security or safety risks.

Please note that we will only use your data for the purposes for which we collected it, unless we reasonably considerthat we need to use it for another related reason and that reason is compatible with the original purpose. If we need touse your data for an unrelated purpose, we will seek your consent to use it for that new purpose.

What do we share with third parties?

Some of the Personal Data that we collect might be shared with third parties as respectively mentioned below:

1. Service providers: providing internal technical support where needed as dedicated technical units from our service providers might require access to your Personal Data on a need-to-know basis to provide support where necessary and to subsequently assess any other problems which may be causing the reported issue(s). We may share your Personal Data with site providers to monitor and analyze the use of our Site and to contact you

2. Affiliates & Partners: We may share some of your Personal Data with our affiliates (i.e., any company that we control or that are under common control with us) and with trusted business partners partners such as ARIJ and JOSA,to honor and fulfill our services and activities and to offer you certain products, services or promotions, in this case we will require those affiliates and business partners to honor this Privacy Policy and comply with applicable data protection laws.

3. Law enforcement& Legal Compliance: Under certain circumstances, we may be required to disclose yourPersonal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government body). We may also disclose data as necessary to establish, exercise, or defend legal claims, or to comply with regulatory obligations.

4. Other circumstances of disclosure: We may disclose your Personal Data in the good faith belief that such action is necessary to: comply with a legal obligation, protect and defend our rights or property, prevent or investigate possible wrongdoing in connection with the DALIL Site, protect the personal safety of Users and other user of theDALIL Site or the public and protect against legal liability

What rights do you have?

We undertake to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.

You also have the right under this Privacy Policy, to:

• Request access to your Personal Data. The rights to access, update or delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within youraccount settings section. If you are unable to perform these actions yourself, please contact us to assist you. This alsoenables you to receive a copy of the Personal Data we hold about you.

• Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.

• Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as thelegal basis for our processing and there is something about your particular situation, which makes you want to objectto our processing of your Personal Data on this ground. You also have the right to object where we are processingyour Personal Data for direct marketing purposes.

• Request erasure of your Personal Data. You have the right to ask us to delete or remove Personal Data when thereis no good reason for us to continue processing it.

• Withdraw your consent. You have the right to withdraw your consent on using your Personal Data. If you withdraw your consent, we may not be able to provide you with access to your account and/or other specific functionalities of theDALIL Site.

To exercise any of these rights, please contact us using the details provided in the “Contact Us” section of this Privacy Policy. We may need to verify your identity before fulfilling your request, and we will respond within the timelines required by applicable law.

Retention and storage of data

Your Personal Data will be retained for as long as necessary to fulfill the purposes indicated in this Privacy Policy, enhance user experience and use of the Site and Services, comply with legal obligations, resolve disputes, and enforce legal agreements and policies.

Usage Data for internal analysis purposes will generally be retained for up to 5 years, after which the data shall be deleted or anonymized and only used for statistical purposes, except when this data is used to strengthen the security or to improve the functionality of the DALIL Site, or when a legal obligation justifies retaining this data for a longer period.

When the retention period expires or the processing purpose no longer applies, we will ensure that Personal Data is securely deleted or anonymized in accordance with applicable data protection laws.

Security

To provide the highest level of security to the servers hosted by Amazon Web Services we have put in placeprocedures and technologies as per good industry practices and in accordance with applicable laws, to maintainsecurity of all data from the point of collection to the point of destruction. For On-Premises deployments, security of the hosting environment is the responsibility of the client organization, although we may provide guidance or support where contractually agreed. However, such measures do not offer a complete guarantee of security.

Who to contact for questions related to your personal data?

As mentioned above, for any inquiries about how your Personal Data is being processed or any other question related toyour privacy and related rights, please contact our Data Protection Officer:

Data Protection Officer

Name: Gabriel Khoury

Address: Beirut Digital District, Building 1227, Bloc A

Email: gabriel@sirenanalytics.com

Changes to this privacy policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new PrivacyPolicy on this page. We will let you know via email and/or a prominent notice on our Site, prior to the change becomingeffective and update the “Last updated” date at the top of this Privacy Policy. You are advised to review this PrivacyPolicy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Right to resort to court

Please note that, in accordance with applicable data protection laws, including the EU General Data Protection Regulation (EU GDPR), the UK General Data Protection Regulation (UK GDPR), and the UK Data Protection Act 2018, you or any ofyour heirs, may resort to the competent authorities, in order to ensure the exercise of your rights and to report the application of the provisions of the abovementioned law(s).