Government and Public Authority Data Request Policy

Adopted September 8, 2026. Owner: Chief Executive Officer, OwlThat Inc.

This policy applies to all personal data OwlThat Inc. ("OwlThat", "we", "us") holds, including data our customers connect to Cortex from third-party platforms such as Facebook and Instagram. It governs how we respond when a public authority (a court, law enforcement agency, regulator or other government body) asks us for personal data.

1. Legality review

Every request from a public authority for personal data, whether a subpoena, court order, warrant, national security request or informal request, is reviewed before any response. The review confirms that the request is in writing, identifies the issuing authority and its legal basis, names the specific data sought, and is valid under the law of the jurisdiction that issued it. We do not respond to informal or verbal requests.

2. Challenging unlawful or overbroad requests

Where the review finds a request unlawful, overbroad or lacking a valid legal basis, we seek to narrow or challenge it, engaging outside counsel where needed, before disclosing anything. We notify the affected customer of the request unless we are legally prohibited from doing so.

3. Data minimization

Only the minimum data necessary to satisfy a valid request is disclosed. Requests are answered from the specific records named, never by bulk export, and data belonging to customers or people not named in the request is excluded.

4. Documentation

Every request and our response is recorded in a request log with the date received, the issuing authority, the legal basis cited, the data requested, the outcome and reasoning of the legality review, any challenge made, the people involved, and what was disclosed and when. Records are retained for at least five years.

5. Data received from Meta platforms

Requests touching data received through Facebook or Instagram are additionally handled in accordance with Meta's Platform Terms and Developer Policies, including notifying Meta where those terms require it. See our Privacy Policy for how that data is used and deleted.

6. Contact

Questions about this policy, or legal process directed at OwlThat Inc., should be sent to info@owlthat.com.