Privacy Policy

Effective date: July 5, 2026 · Operator: Skylark Creations LLC, doing business as “Billionaire Army” · Contact: hello@skylarkcreations.com

1. Overview

This Privacy Policy explains how Billionaire Army collects, uses, discloses, retains, and protects information when you use the Service.

The Service involves two different groups of people:

• Registered users and visitors — people who browse the Service, create accounts, vote, comment, rate goals, submit rewrites, propose additions, or contact us.
• Profile subjects — people whose names, public-record information, news coverage, scores, summaries, photos, or other information may appear on the Service, whether or not they use the Service or consent to inclusion.

Those groups raise different privacy and legal issues. This Policy describes both.

2. Scope

This Policy applies to the Service. It does not apply to third-party websites, APIs, news sources, public databases, hosting providers’ own websites, social media platforms, or other services we do not control.

The Service is operated from the United States and is intended for a U.S. audience. If you use the Service from outside the United States, you understand that your information may be processed in the United States, where privacy laws may differ from those in your location.

3. Information we collect from registered users and visitors

3.1 Account information

If you create an account, we collect information needed to create and maintain the account, such as:

• email address;
• password or authentication credential processed through our authentication provider;
• optional display name if provided or later supported;
• account identifiers, timestamps, and account status information.

We do not intentionally collect phone numbers, physical addresses, payment-card information, bank-account information, government identifiers, biometric data, or precise GPS location from registered users.

3.2 User activity

If you use interactive features, we may collect and store:

• votes and approval/disapproval activity;
• comments and comment metadata;
• goal ratings, SMART-criteria ratings, and priority scores;
• proposed goal rewrites and related comments;
• proposed additions of people to the Service, including the proposed person’s name, reason, industry tags, state, Wikidata ID, and related metadata;
• reports, correction requests, takedown requests, support messages, and other communications;
• timestamps, internal IDs, and related records needed to operate and protect the Service.

Some activity may be public or may affect public content. For example, comments may be publicly visible, votes may be displayed in aggregate, and proposed additions may affect public profile data. Do not submit information you want to keep private.

3.3 Automatically collected information

When you use the Service, we and our hosting or infrastructure providers may automatically process technical information such as:

• IP address;
• device, browser, and operating-system information;
• pages visited;
• referring URLs;
• access times;
• request logs;
• error logs;
• security, fraud-prevention, and performance information.

At this time, the application does not maintain its own IP-address database field, but hosting providers may transiently process IP addresses and request logs to provide and secure the Service.

3.4 Cookies and similar technologies

We may use cookies, local storage, and similar technologies that are necessary or useful for authentication, session management, security, preferences, and basic Service operation.

We do not currently use advertising cookies, behavioral advertising networks, or third-party analytics tools in the live product. If we add analytics, advertising, donation, payment, newsletter, or similar tools later, we will update this Policy as appropriate before or when those tools begin processing personal information.

4. Information we publish or process about profile subjects

The Service may collect, generate, store, display, and update information about profile subjects from public records, public APIs, news sources, public websites, user submissions, and AI-generated or algorithmic processing.

This may include:

• name, aliases, birth year, death year, country, state, industry tags, gender, photos, and public biographical details;
• net-worth estimates and related source data;
• foundation and philanthropic-giving data;
• political-contribution data and party-affiliation indicators derived from public records;
• SEC filing and ownership information;
• news headlines, article links, summaries, and source metadata;
• profile summaries and feed-card summaries generated or assisted by AI;
• Public Benefit Score values, grades, badges, rankings, comparisons, and underlying scoring features;
• user-submitted proposals, source suggestions, comments, votes, and other community signals related to a profile.

Profile subjects may not have provided this information to us, may not use the Service, and may not have consented to inclusion. We process and publish this information for public-interest, civic-accountability, commentary, research, reporting, and discussion purposes.

We do not intentionally publish private home addresses, family-member details, personal-security information, government identifiers, financial-account numbers, biometric data, or precise GPS location for profile subjects. Users are prohibited from submitting that information.

5. How we use information

We may use information to:

• provide, operate, maintain, and secure the Service;
• create and manage user accounts;
• authenticate users;
• enable votes, comments, ratings, rewrites, proposals, and correction requests;
• display public content and aggregate community signals;
• build, update, score, compare, and explain public profiles;
• retrieve and organize public records, filings, public datasets, news articles, and source links;
• generate or assist with summaries, feed cards, classifications, and explanatory content;
• detect abuse, spam, manipulation, scraping, security threats, and policy violations;
• moderate, remove, or restrict content;
• respond to questions, legal notices, privacy requests, correction requests, and takedown requests;
• analyze and improve Service reliability, quality, and safety;
• enforce our Terms;
• comply with legal obligations;
• protect the rights, safety, reputation, and security of users, profile subjects, the public, and us.

6. How we disclose information

We may disclose information in the following ways.

6.1 Public disclosure through the Service

Certain content is public by design, including profile pages, public scores, public rankings, source links, AI-generated or editorial summaries, feed cards, comments, aggregate vote results, goals, and other public-facing content.

Do not submit comments, proposals, corrections, or other content that contains information you do not want made public or reviewed by administrators.

6.2 Service providers

We may disclose information to service providers that help us operate the Service, such as hosting, database, authentication, infrastructure, security, and AI providers. Current service providers and data flows include:

• Supabase — database and authentication hosting;
• Render — website/API hosting and infrastructure;
• OpenAI — AI generation and verification involving public-record, news-derived, and profile-subject data; we do not intentionally send registered users’ email addresses, passwords, votes, or comments to OpenAI;
• public-record and source APIs used to retrieve or verify profile-subject data, such as FEC, SEC EDGAR, ProPublica Nonprofit Explorer, NewsAPI.ai, GDELT, and Wikidata.

We may add, replace, or remove providers as the Service changes. If a material change affects personal-information handling, we will update this Policy as appropriate.

6.3 Legal, safety, and enforcement disclosures

We may disclose information if we believe it is reasonably necessary to:

• comply with law, subpoenas, court orders, legal process, or government requests;
• enforce our Terms;
• investigate or prevent fraud, abuse, security incidents, manipulation, harassment, doxxing, threats, or unlawful activity;
• protect the rights, safety, reputation, property, or security of users, profile subjects, the public, service providers, or us;
• establish, exercise, or defend legal claims.

6.4 Business transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, asset sale, or similar transaction, information may be transferred as part of that transaction, subject to applicable law and appropriate notice where required.

7. No sale of personal information; no advertising

We do not sell registered-user personal information. We do not sell profile-subject personal information. We do not currently display advertising, use advertising networks, or share personal information for cross-context behavioral advertising.

If this changes, we will update this Policy and provide choices required by applicable law before or when the change occurs.

8. Public sources and public information

Some information on the Service comes from public records, government databases, public filings, public news sources, public websites, public APIs, public signatory lists, and similar sources. Public availability does not guarantee accuracy, completeness, fairness, currentness, or lawful use for every purpose.

We may combine public information with scoring methods, AI-generated summaries, editorial context, user submissions, and internal metadata. This combined output may differ from the original source material and may contain errors. We encourage users and profile subjects to review underlying source links and report material inaccuracies.

9. AI processing

We may use AI systems to help generate, summarize, classify, compare, score, verify, or explain content. AI processing may involve sending public-record, news-derived, source, and profile-subject data to AI providers.

We do not intentionally send registered users’ email addresses, passwords, votes, comments, or account credentials to AI providers for profile-summary or feed-card generation. Users should not include sensitive personal information in public comments, proposals, correction requests, or other submissions.

AI-generated content may be inaccurate, incomplete, outdated, or misleading. We may store AI outputs, prompts, source snippets, verification records, and related metadata to operate, audit, improve, and defend the Service.

10. Data retention

We retain information for as long as reasonably necessary for the purposes described in this Policy unless a shorter or longer period is required or permitted by law.

At launch, the Service does not have automated deletion or expiration for all data categories. In practice:

• account information may be retained while the account exists and for a reasonable period afterward for security, legal, audit, and abuse-prevention purposes;
• comments, votes, goal activity, proposals, and related records may be retained to preserve community integrity, prevent manipulation, enforce rules, and maintain public context;
• public-record, source, profile, score, AI-generated, and editorial data may be retained while relevant to the Service’s public-interest purpose;
• logs may be retained by infrastructure providers according to their systems and policies;
• legal, safety, correction, dispute, and abuse records may be retained as long as needed to address the issue and protect rights.

We may delete, anonymize, aggregate, de-identify, or preserve information in our discretion and as allowed by law.

11. Your privacy choices and requests

You may contact us at hello@skylarkcreations.com to request access, correction, deletion, or other action regarding personal information associated with your account or submitted by you.

We may need to verify your identity before fulfilling a request. We may decline or limit a request where we cannot verify it, where the request is fraudulent or abusive, where retention is required or permitted by law, where the information is public-record or editorial content, where deletion would impair security or integrity, or where another exception applies.

If you have an account, we may require you to submit certain requests from or in connection with the email address associated with your account.

Deleting your account may not remove content that has already been published, aggregated, de-identified, backed up, relied on for public context, preserved for legal or safety reasons, or submitted as public User Content, unless applicable law requires removal.

12. Requests by profile subjects

If you are a profile subject or an authorized representative, you may contact us at hello@skylarkcreations.com to request correction, annotation, source review, limitation, or removal of content about you.

Please include enough information to identify the profile and evaluate the request, including disputed statements, source links, reliable contrary sources, and the specific remedy you seek.

We may ask for information reasonably necessary to verify identity or authority. We will use verification information only for request handling, legal, safety, security, or dispute-resolution purposes, unless you consent to another use or law requires otherwise.

We may not remove information solely because it is unfavorable, critical, public, newsworthy, sourced from public records, or part of public-interest commentary. We may correct, annotate, limit, remove, or retain information depending on the circumstances, applicable law, source quality, public interest, safety, and editorial judgment.

13. State privacy notices

Depending on where you live and whether a particular law applies to us, you may have rights to know, access, correct, delete, obtain a copy of, or opt out of certain processing of personal information. You may also have the right not to be discriminated against for exercising privacy rights.

We do not currently sell personal information or share it for cross-context behavioral advertising. We will honor legally required opt-out signals if and when applicable to us and technically feasible for the relevant processing.

13.1 California notice

To the extent the California Consumer Privacy Act or similar California privacy laws apply, California residents may have rights to know, access, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and not be discriminated against for exercising those rights.

The categories of personal information we may collect include:

• identifiers, such as email address, account ID, public name, or IP address;
• internet or electronic network activity, such as log data and usage records;
• user-generated content and communications;
• inferences or scores derived from activity, such as aggregated voting or trust/integrity signals;
• publicly available information and news-derived information about profile subjects;
• sensitive personal information only to the limited extent account credentials or verification information fall within that category.

We do not use sensitive personal information to infer characteristics about registered users. We do not sell or share personal information for cross-context behavioral advertising.

13.2 Colorado notice

To the extent the Colorado Privacy Act applies, Colorado residents may have rights to access, correct, delete, obtain a portable copy of personal data, and opt out of certain processing such as targeted advertising, sale of personal data, or profiling that produces legal or similarly significant effects.

We do not currently sell personal data, use targeted advertising, or use the Service to make legal or similarly significant decisions about registered users. Public Benefit Scores and public profiles are public-interest editorial and informational content, not eligibility decisions for credit, employment, housing, insurance, lending, education, criminal justice, or essential services.

14. Children’s privacy

The Service is not directed to children under 13. Children under 13 may not use the Service, create accounts, submit comments, vote, propose people, or provide personal information. Users under 18 may not create accounts or submit content.

If you believe a child under 13 has provided personal information to us, contact hello@skylarkcreations.com. If we learn that we have collected personal information from a child under 13 without legally required consent, we will take appropriate steps to delete it or otherwise comply with applicable law.

15. Security

We use reasonable administrative, technical, and organizational measures designed to protect information. No website, database, transmission, hosting environment, authentication system, or AI provider can be guaranteed secure.

You are responsible for using a strong, unique password; protecting your login credentials; keeping your devices secure; and notifying us promptly of suspected unauthorized access.

16. Data breach notice

If we determine that a security incident requires notice under applicable law, we will provide notice as required by law. We may also take steps such as resetting passwords, disabling sessions, limiting access, investigating the issue, or notifying service providers.

17. Do Not Track and global privacy controls

Some browsers send “Do Not Track” signals. There is no single industry-standard response to Do Not Track signals. Because we do not currently sell personal information or share it for cross-context behavioral advertising, we do not treat Do Not Track differently from other requests at this time.

Where legally required and technically feasible, we will treat recognized global privacy control signals as opt-out requests for applicable sale, sharing, or targeted-advertising processing. We do not currently engage in those activities.

18. Third-party links and sources

The Service links to news sites, government databases, public APIs, source documents, and other third-party websites. We do not control those third parties, and their privacy practices are governed by their own policies.

19. Changes to this Policy

We may update this Policy from time to time. The “Effective date” above shows when this Policy was last updated. If changes are material, we may provide additional notice, such as by posting a notice on the Service or emailing registered users where appropriate.

Your continued use of the Service after an updated Policy takes effect means the updated Policy applies going forward.

20. Contact

Privacy questions, requests, correction requests, and legal notices may be sent to:

Skylark Creations LLC
1500 N Grant St, Ste R
Denver, CO 80203
hello@skylarkcreations.com

See also our Terms of Service.