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Privacy Policy

Your privacy is important to us. It is LUNASHARK®’s policy to respect your privacy regarding any information we may collect from you across our website, https://lunasharkmedia.com, and other sites we own and operate.

1. Information we collect

Log data
‍When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details.

‍Device data
‍We may also collect data about the device you’re using to access our website. This data may include the device type, operating system, unique device identifiers, device settings, and geo-location data. What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.

‍Personal information
‍We may ask for personal information, such as your:
– Name
– Email
– Payment information

‍Business data
Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.
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These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us); it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests; you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
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We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

  • to provide you with our platform’s core features;
  • to process any transactional or ongoing payments;
  • to enable you to access and use our website, associated applications and associated social media platforms;
  • to contact and communicate with you; for internal record keeping and administrative purposes; for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms; and to comply with our legal obligations and resolve any disputes that we may have.

4. Disclosure of personal information to third parties We may disclose personal information to:

third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators; our employees, contractors and/or related entities; courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and third parties to collect and process data.

We also share certain of your information with creators (“Creators”). The personal information that we share with Creators (“Subscriber Data”) is limited to the following:

  • Account information, including your name and email address
  • Purchase information, including amount paid, your address, and other billing information (but never your complete card number, which we also don’t get)
  • IP address
  • Information about your use of Creator content, including downloads

5. International transfers of personal information

The personal information we collect is stored and processed in United States, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.
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We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.
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Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

6. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.
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Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
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Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.
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Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
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Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
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Notification of data breaches: We will comply laws applicable to us in respect of any data breach.
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Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
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Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

7. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified. Please refer to our Cookie Policy for more information.

8. Business transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.

9. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

10. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.
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If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.
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LUNASHARK® Productions, LLC
‍info@lunasharkmedia.com
This policy is effective as of May 10, 2023.

Artificial Intelligence Usage Guidelines & Policy

1. Purpose

The purpose of this guideline document is to establish standards for the responsible and ethical use of artificial intelligence (AI) by LUNASHARK® owners employees, contractors, and contributors.

These guidelines are informed by the journalistic principles of truth, transparency, accuracy, and honesty. They are also designed to protect the rights, dignity, and likeness of individuals — whether public figures, private citizens, guests, or LUNASHARK® personnel — who appear in or are referenced by our content.

2. Definitions

Artificial Intelligence (AI)

A broad term used to describe computer systems designed to perform tasks that typically require human intelligence, such as pattern recognition, language processing, and decision-making.

Limited-Memory AI

The most common category of AI tools in use today. These systems analyze existing data and past inputs to generate outputs or recommendations, but they do not possess understanding, consciousness, or independent judgment. Large language models (LLMs) are a subset of limited-memory AI and are commonly associated with generative AI tools. Examples include ChatGPT, Claude, Perplexity, Copilot, Gemini, NotebookLM, and Grok.

Reactive AI

Systems that operate strictly on predefined rules and respond only to current inputs. They do not learn or adapt over time. Simple rule-based automation, such as basic spam filtering, falls into this category.

Generative AI

AI systems that generate content — such as text, images, audio, or video — based on patterns learned from existing data. For purposes of this policy, the stricter restrictions outlined herein apply to Generative AI whenever content involves real persons.

Name, Image & Likeness (NIL) Refers to a person’s identifying characteristics: their name, face, voice, appearance, signature, or any other attribute by which they can be recognized or associated. NIL rights are legally and ethically protected and cannot be used without consent.

CORE PROHIBITION — APPLIES TO ALL USES

LUNASHARK® shall not use, license, or authorize any third party to use Generative AI platforms, technology, or tools to alter, manipulate, replicate, or simulate any recorded participation in the Podcast or Content — including the creation or use of digital voice replicas or digital likenesses of any host(s) or guest(s) — without the prior express written consent of subjects and/or senior leadership in each instance.

3. Benefits and Pitfalls of Using AI

3.1 Benefits

  • Enhance productivity and reduce time on repetitive tasks
  • Streamline complex processes
  • Assist in research and analysis of large quantities of data
  • Improve accessibility (captions, transcripts, etc.)
  • Enhance creativity and ideation
  • Support consistent brand and editorial voice across platforms

3.2 Pitfalls

  • AI can generate false or misleading information (“hallucinations”)
  • Possible security and data privacy risks
  • Potential for malicious or deceptive use
  • Possible copyright and intellectual property concerns
  • Risk of misrepresenting real persons if outputs are not verified
  • Audience trust erosion if AI use is undisclosed or overused

4. Core Task Management Principles

The following principles apply across all use categories in this policy:

Principle Requirement
Human Editorial AI should not replace core journalistic or editorial judgment.
Human Review All outputs generated by AI must be independently reviewed and verified by at least one member of senior leadership before publication under the LUNASHARK® banner.
Disclosure Any photos, videos, or audio created using AI must include a clear disclaimer: “AI-generated content.”
Verification AI may be used for time-consuming tasks that are easy to verify. The burden of accuracy rests with the human reviewer, not the AI tool.
Data Protection Sensitive, personally identifiable, or legally privileged information must never be submitted to generative AI tools.
Approvals Any use of AI in connection with real persons’ name, image, or likeness requires prior express written consent from that subject or if not available to contact, from senior leadership.

5. Acceptable Uses of AI

The following uses are expressly permitted, subject to the task management principles in Section 4 and the restrictions in Section 7. As AI tools evolve, this list may be updated. All AI usage must align with journalistic ethics. Employees and contractors should consult Luna Shark leadership with questions.

5.1 Editorial & Production (Pre-Existing)

  • Creation of written transcripts from audio files for research and editorial purposes
  • Creation of podcast episode names and episode description options
  • Creation of captions for video clips to support accessibility
  • Copyediting tasks such as grammar and clarity review
  • Creation of generic/stock video clips or photos for published videos without infringing on name, image, or likeness reproductions restricted by law
  • Creation of generic/stock audio clips without infringing on NIL (e.g., recreating court transcripts where real audio recordings are unavailable or prohibited)
  • Idea generation or exploratory research
  • Data and trend analysis
  • Summary, cross reference and comparison of documents to derive insights

5.2 Episode Production

AI may be used in the following episode production contexts:

  • Show notes & episode summaries: AI may draft first-pass show notes, chapter markers, and episode summaries for human review and editing.
  • Research compilation: AI may aggregate publicly available information for research memos, background briefings, and case timelines — all subject to independent verification.
  • Script ideation: AI may assist in generating outline options, topic suggestions, or introductory language — but must not author final scripts used on-air.
  • Transcript cleanup: AI may be used to clean and format auto-generated transcripts for editorial or accessibility purposes.
  • Sound design — generic: AI-generated ambient or background audio (e.g., non-identifiable environmental sound, music beds) is permitted, provided it does not simulate any real person’s voice.
  • Guest research: AI may compile publicly available background on guests for interview prep. All compiled information must be independently verified before use on-air or in published materials.

EPISODE PRODUCTION GUARDRAIL

AI must not generate, alter, or synthesize the voice, likeness, or on-air identity of any host, guest, or subject — living or deceased — without prior express written consent from senior leadership. This applies to ad reads, promotional clips, re-creations, and archival content.

5.3 Social Media & Marketing

AI may be used in social media and audience-facing marketing contexts as follows:

  • Caption drafting: AI may draft social media captions for review and editing by a Luna Shark team member before posting.
  • Hashtag and keyword research: AI may assist with identifying relevant hashtags, keywords, and SEO terms.
  • Post scheduling assistance: AI-powered scheduling and analytics tools may be used to optimize posting cadence and engagement tracking.
  • Ad copy ideation: AI may generate first-draft advertising or promotional copy. Final copy must be reviewed and approved by a senior team member.
  • Graphic descriptions: AI may generate text descriptions or alt-text for images to support accessibility.
  • Generic/stock imagery: AI may generate non-identifiable background or decorative imagery for social graphics. No AI-generated imagery may depict any real, recognizable person.
  • Audience Q&A prep: AI may assist in drafting responses to common audience questions, which must be reviewed by a team member before sending.

SOCIAL MEDIA GUARDRAIL

AI must not be used to generate, alter, or fabricate quotes, statements, or posts attributed to real persons — including hosts, guests, subjects of investigation, or public figures. AI-generated social content must be clearly reviewed before publication and must never impersonate a real individual.

5.4 Support & Administrative Functions

AI may be used to support internal operations and administrative tasks, including:

  • Scheduling & calendar management: AI tools may assist with meeting scheduling, reminders, and calendar coordination.
  • Internal communications: AI may assist with drafting internal memos, templated emails, and staff communications — not for use in legal, editorial, or external-facing correspondence without human review.
  • Membership & audience support: AI-powered tools (e.g., FAQ bots) may be used for premium membership platform or general audience support, provided responses are human-reviewed and do not contain legally sensitive or investigative content.
  • Financial tracking & reporting: AI may assist with organizing and summarizing financial data for internal reporting. Final figures must be verified by the responsible team member.
  • Award submission research: AI may compile eligibility information and draft award submission materials for Peabody, Gracie, Webby, Pulitzer, and similar submissions, subject to senior leadership review.
  • Contract and document summarization: AI may produce plain-language summaries of contracts or legal documents for internal orientation — never as a substitute for attorney review.
  • SEO and distribution strategy: AI may assist in identifying distribution opportunities, platform trends, and audience engagement strategies.

SUPPORT FUNCTIONS GUARDRAIL

Legally sensitive information — including attorney-client communications, active litigation materials, settlement discussions, source identities, and personally identifiable information of subjects or victims — must never be submitted to any generative AI tool.

5.5 Satire & Commentary

LUNASHARK® may engage AI assistance in the creation of clearly labeled satirical or editorial commentary content, subject to the following conditions:

  • Labeling requirement: All satirical or AI-assisted commentary content must be clearly and prominently labeled as satire or editorial opinion. Labels must appear before the content is consumed — not at the end.
  • No fabricated quotes: AI must not generate content that creates, implies, or attributes a fabricated statement to any real, named person — including public figures, law enforcement officials, attorneys, judges, or private citizens — even in a satirical context.
  • No photorealistic images of real persons: AI-generated imagery used in satirical content must be clearly illustrative, stylized, or abstract. Photorealistic depictions of identifiable real persons are prohibited.
  • Defamation risk review: Any satirical content involving named individuals or entities must be reviewed by Luna Shark legal counsel or designated senior leadership before publication. The satirical framing does not insulate Luna Shark from defamation liability.
  • Permitted satirical uses: AI may assist in generating clearly exaggerated commentary, illustrative hypotheticals, or humor related to public figures’ public conduct — provided such content cannot reasonably be mistaken for factual reporting.

SATIRE GUARDRAIL

Satire is not a blanket defense against defamation, false light, or right-of-publicity claims. Any AI-assisted satirical content involving real persons must be reviewed for legal exposure before publication, regardless of how clearly it is labeled. When in doubt, escalate to senior leadership.

6. Unacceptable Uses of AI

The following uses are expressly prohibited across all Luna Shark platforms, properties, and publications:

  • Creation of entire journalistic content using AI without substantial human authorship
  • Editing or creating audio to simulate the voice of any real, living person without their express written consent
  • Editing or creating images or video depicting a real, living person in a false, misleading, or sexualized context
  • Generating fabricated quotes, statements, or attributions for any real person — in any context, including satire
  • Submission of sensitive or personally identifiable information, source identities, or legal materials to generative AI tools
  • Using AI to generate content that could constitute harassment, defamation, or targeted intimidation of any individual
  • Using AI to automate or simulate the identity, voice, or persona of any Luna Shark host or contributor without explicit approval
  • Publishing AI-generated content on any Luna Shark property without independent human review and approval
  • Using AI to produce content that mimics the visual identity, voice, or editorial tone of a competitor or third-party outlet in a misleading way

7. Name, Image & Likeness (NIL) Protections

LUNASHARK® is committed to respecting the rights, dignity, and legal protections afforded to all individuals — including public figures, private citizens, victims, legal subjects, guests, and its own staff and hosts. The following guardrails apply to all AI-related activities.

7.1 Voice & Audio Likeness

  • AI must not replicate, simulate, or synthesize the voice of any real person.
  • This prohibition applies to hosts, guests, subjects of coverage, public figures, and private individuals.
  • Court transcript re-enactments using AI audio must use clearly non-identifiable voices that do not resemble any known individual.
  • Any AI audio used in content must be disclosed as AI-generated.

7.2 Visual Likeness

  • AI must not generate photorealistic or near-photorealistic imagery of any real, identifiable person.
  • AI-generated imagery used in thumbnails, social graphics, or promotional materials must not depict recognizable facial features of real persons.
  • Stylized or abstract representations of public figures in clearly satirical contexts require legal review before publication.
  • Stock or decorative AI imagery must be vetted to ensure it does not unintentionally resemble a real person.

7.3 Name & Written Identity

  • AI must not generate content that falsely attributes statements, positions, or actions to any named real person.
  • AI-drafted research or background memos that reference real persons must be verified against primary sources before use in any published content.
  • AI must not be used to create fictional narratives or scenarios that feature real persons in misleading, harmful, or sexualized contexts.

7.4 Special Protections

  • Victims & private individuals: AI must never be used to generate content depicting, simulating, or attributing statements to victims, private individuals, or minors — in any form.
  • Luna Shark staff & hosts: The voice, image, or likeness of any Luna Shark employee or contractor may not be used in AI-generated content without their express written consent, regardless of the internal or external nature of the content.
  • Legal subjects: Individuals who are subjects of active legal proceedings or Luna Shark investigations carry heightened exposure to harm. AI-generated content involving such persons requires senior leadership approval and legal review before any use.
Subject Category AI Content Requirement
Hosts & Contributors Express written consent + senior leadership approval
Podcast Guests Express written consent + senior leadership approval
Public Figures (editorial) Legal review; no fabricated quotes or photorealistic imagery
Victims / Private Citizens Prohibited in all forms
Minors Prohibited in all forms
Legal Subjects (active) Senior leadership approval + legal review

8. Disclosure Requirements

LUNASHARK® is committed to transparency with its audience about AI use. The following disclosure standards apply:

  • Published AI content: Any photo, video, audio, or written segment that was materially generated by AI must carry a clear disclosure: “AI-generated content.” This disclosure must be visible before or alongside the content — not buried in credits or footnotes.
  • AI-assisted content: Content that was meaningfully shaped, edited, or structured by AI (even if authored by a human) should be disclosed as “AI-assisted.” Use editorial judgment on materiality.
  • Satire: AI-assisted satirical content must carry both a satire label and an AI disclosure.
  • Internal use: Internal documents, memos, research summaries, and draft materials generated with AI assistance do not require public disclosure but should be noted in internal records for accountability purposes.

9. Approval Workflow

The following approval thresholds apply based on content type and risk level:

Risk Level Approval Required
Low — internal/admin Team member self-review; document use in internal records
Medium — social, support, production drafts Review and approval by one senior team member before publishing
High — published content, satire, or any real person’s NIL Senior leadership approval; legal review recommended
Critical — voice/image replication, legal subjects, deceased Prior express written consent + senior leadership approval + legal review

10. Enforcement & Accountability

  • All LUNASHARK® employees, contractors, and contributors are responsible for understanding and adhering to this policy.
    Suspected violations should be reported to senior leadership immediately.
  • LUNASHARK® reserves the right to remove any AI-generated content that is found to violate this policy after publication, without prior notice.
  • Repeated or willful violations may result in termination of employment or contractor relationship.
  • This policy does not limit LUNASHARK®’s ability to pursue legal remedies in cases involving unauthorized or harmful use of AI in connection with its content or personnel.

11. Reference Policies from Other Outlets

The following external policies were reviewed in the development and maintenance of these guidelines:

LUNASHARK® Productions, LLC
‍info@lunasharkmedia.com
This policy is effective as of March 25, 2026.