CONTENT PRIVACY POLICY

Last published: March 21 2025

This policy supplements Livesnap's general Privacy Policy, which applies to Customers and visitors to the Website.

In the event of any discrepancy, this policy shall prevail with respect to Consumer Personal Information collected in connection with the services.

LIVESNAP MONITORS CONTENT THAT MAY INCLUDE PERSONAL INFORMATION

To provide our market intelligence services, we may collect information from various sources, including via partners and via the Internet (websites, blogs, forums, social networks).

In some cases, this information may contain Personal Information. We analyse this information and produce reports for our Customers.

We would remind you that our monitoring service consists of content analysis designed to help our customers better understand what Consumers are saying about a sector, a brand, an issue or a product.

The aim of these analyses is not to profile or target individuals on a personalised basis, but to identify trends, perceptions or signals that are useful for strategic decision-making.

We only monitor information that our partners provide to us or that is published or otherwise made public by web users on the Internet.

This policy therefore only applies to Personal Information of Consumers, which may be collected and processed as part of the market intelligence services we provide to our Customers.

As part of the services provided to our Customers, we generally act as a sub-contractor (or "service provider") and process Personal Information on behalf of our Customers, who remain responsible for the processing.

Personal Information

For the purposes of this Policy, "Personal Information" means any information about an identifiable individual, including any information that directly or indirectly identifies that individual.

Collection of Personal Information from Consumers

As part of the market intelligence services we provide to our Customers, we may collect certain Personal Information that we gather from our partners or that is made public by Consumers themselves on the Internet.

The latter is done mainly from publicly accessible sources, such as websites, online media, blogs, forums or social networks.

The Personal Information we collect varies depending on the content publicly available at the time of analysis.

It may include, but is not limited to:

• a name, pseudonym or public identifier;
• a position or professional title associated with a company or organisation;
• a photo or image shared publicly;
• quotations, opinions or comments published by a person;
• approximate location data (e.g. city associated with a public profile);
• or other information associated with a person's identity in a public context.

Certain publicly available Personal Information may be considered sensitive depending on the context, in particular when it reveals information relating to a person's health, political opinions, religious beliefs, sexual orientation, financial situation or ethnic origin.

Livesnap does not actively target this type of information and endeavours, as far as possible, to exclude it from the content it analyses or transmits to its Clients.

Mechanisms are put in place to limit collection to what is relevant for monitoring purposes, in accordance with the principle of minimisation provided for by applicable laws.

If a Customer wishes such Sensitive Personal Information to be included in the results sent to it, Livesnap will require the Customer to have obtained the explicit consent of the person concerned, or will itself endeavour to obtain such consent, if possible in the circumstances.

In the absence of explicit consent, this information will not be used for this purpose.

Our intention is not to process sensitive Personal Information, nor to profile or monitor individuals, but to identify general trends, sector signals and content of public interest available online.

Basis for Processing Personal Information

Livesnap may collect and process some of your Personal Information in order to be able to provide its services to its Customers.

The following is a description of the basis on which Livesnap collects and processes your Personal Information:

If you are located in the EU or the UK, this section applies to you.

The General Data Protection Regulation (GDPR) and the UK GDPR require us to explain the valid legal bases on which we rely to process your personal information.

For example, we may rely on the following legal bases to process your Personal Information:

• Consent. We may process your information if you have given us permission (i.e. consent) to use your Personal iInformation for a specific purpose. You may withdraw your consent at any time.
• Fulfilment of a contract. We may process your Personal Information where we believe it is necessary to fulfil our contractual obligations to you, including the provision of our Services or at your request prior to entering into a contract with you.
• Legitimate interests. We may process your information where we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms. For example, we may process your Personal Information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services.
  • To analyse how our Services are used so that we can improve them to engage and retain users.
  • Diagnose problems and/or prevent fraudulent activities.
  • To understand how our users use our products and services so that we can improve the user experience.
• Legal obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or regulatory agency, exercising or defending our legal rights, or disclosing your information as evidence in a legal dispute in which we are involved.

If you are located in Canada, this section applies to you.

• Your consent. As required by privacy laws, Livesnap collects the majority of your Personal Information on the basis of your consent, favouring collection directly from you where possible. In some cases, Livesnap also justifies its collection of Personal Information on the basis of an exception permitted by applicable privacy laws.
• Other permissible legal bases, such as the performance of our contracts. As permitted by applicable privacy laws, Livesnap may collect Personal Information without your explicit consent, for example to comply with our obligations under applicable laws or to perform our contracts.

Personal information about minors

Given the importance of protecting children's privacy, we do not knowingly collect Personal Information from minors.

However, the nature of our services could affect minors, for example if an article or publication contained information about a minor.

Consequently, we make every effort to limit our collection of Personal Information to information concerning adults only.

If a parent or guardian becomes aware that Personal Information of his or her minor child may have been collected in connection with our services without our obtaining appropriate consent, such parent or guardian has the right, upon request, to inspect the Personal Information provided by the child and/or to require that it be deleted from our records.

In this case, we ask the child's parent or guardian to contact us using the contact details provided in the "Privacy Officer" section.

Accuracy of Personal Information

Livesnap strives to collect, process and maintain Personal Information that is accurate and up-to-date, to the extent possible.

As the data we analyse may come public sources on the Internet (e.g. media, websites, forums, social networks), we cannot always verify its accuracy at source.

We do, however, implement mechanisms to take account of the deletion or modification of certain content, where this is technically detectable.

For example, the deletion of a publication on a social network may be taken into account automatically using the data streams we receive.

If you find that any Personal Information about you accessible via our services is inaccurate or out of date, we recommend that you first correct or delete this data directly on the platform or website where you originally published it.

This will ensure a consistent update across all publicly accessible sources.

You may also inform us directly of any perceived inaccuracy by contacting us using the contact details provided in the "Privacy Officer" section.

We will evaluate your request diligently and in compliance with applicable laws.

Please note that, depending on the context and our role with the Customer, we may not be able to modify or delete information collected from a third party source.

In some cases, your request may need to be redirected to our Customer, the data controller.

Analysis using Artificial Intelligence

Livesnap uses analysis tools, including technologies based on artificial intelligence, to structure and interpret the public data collected as part of its market intelligence services.

The aim of this processing is to provide our customers with an overview of what is being said publicly online about a sector, an issue or a brand.

Analysis operations may include, in particular:

• deduplication of identical content;
• automatic language detection;
• recognition of named entities (e.g. names of people, companies or places);
• analysing the tone or sentiment expressed in a piece of content;
• metadata enrichment (e.g. geographical approximation or thematic categorisation);
• grouping similar content;
• trend detection; and
• extraction of relevant visual or textual content.

The purpose of this processing is to improve the relevance and readability of the results provided to our Customers.

They are not used to make automated decisions that have legal or significant effects on the data subjects.

Communication of Personal Information

Your Personal Information will not be sold to third parties.

We share your Personal Information with third parties only when this is necessary to (i) achieve our objectives, (ii) meet requirements or requests made under applicable laws, (iii) perform tasks entrusted to us by contract by our Customers.

In the majority of cases, this information was initially collected with your consent by our Customer, who then transmitted it to us or made it accessible in the context of our services.

Sometimes, applicable laws authorise us to share your Personal Information with third parties without your consent, in specific cases.

More specifically, we may have to share your Personal Information, sometimes without your consent:

• With our employees. In the course of their work, our employees and officers may have access to your Personal Information. Their access is limited to what is necessary for the performance of their duties.
• With our providers. Our business partners may need to access or receive certain Personal Information in order to perform their services (such as payment providers, cloud data hosts, maintenance, analysis, fraud detection and development). In such cases, we implement reasonable contractual and technical safeguards, including Privacy Impact Assessments, to ensure that these third parties keep all Personal Information they process strictly confidential. Please note that these third parties may not be located in your country, province or territory of residence. For more information on this subject, please consult the section entitled "Third parties located abroad".
• With our customers. Our Customers may access your Personal Information through our services. Our standard service agreements require our Customers to comply with all applicable legal and regulatory requirements, including privacy laws and intellectual property and copyright laws (including in relation to photos and images), when using our services and accessing the data we provide. Our Customers undertake not to use your Personal Information for any other purpose, including promotional purposes, without your consent.
• With authorities or persons authorised by law. We may share your Personal Information if required to do so by law or in the good faith belief that such action is necessary to:  
  • Complying with the law;
  • Comply with the order of a competent judicial authority in any jurisdiction;  
  • Complying with legal proceedings;
  • Protect and defend the rights or property of Livesnap;
  • Enforce or verify your compliance with any part of your contracts with us;
  • Prevent fraud or any other illegal activity perpetrated through the service;
  • or  
  • To act in urgent circumstances to protect the personal safety of users of our services or the general public.
• With potential buyers of our company. We may need to share your Personal Information without your consent in the event of a merger, acquisition or sale of all or part of the business, for example, as part of due diligence. In such a case, we limit the sharing to what is necessary to assess the feasibility or advisability of the transaction.

Third parties located abroad

Your Personal Information may be disclosed and stored outside your province, state, territory or country of residency.

Our business partners and service providers may be located in Canada or other countries.

Please be aware that we have contractual agreements with these third parties and suppliers to ensure that your Personal Information is handled in accordance with the laws applicable to us.

Where applicable, we conduct Privacy Impact Assessments prior to any transfer of Personal Information to another jurisdiction, for example outside Quebec.

Retention and Destruction of Personal Information

Livesnap will retain your Personal Information only for as long as is necessary to fulfil the purposes for which it was collected, to fulfil our contracts with our Customers, in accordance with our internal retention policies or to comply with applicable legal, tax or regulatory requirements.

After such period, any Personal Information held by Livesnap will either be destroyed, deleted or irreversibly anonymized so that it can no longer be used to identify an individual.

Anonymized data may be used for internal research, development or improvement of our services.

We will also delete your Personal Information before the expiry of these periods if you so request, or if you have removed it from the original source (e.g. third party site or service) and have informed us, where technically possible and legally permitted.

Any destruction or deletion is done in a secure manner to prevent unauthorised access.

Security

The security of your Personal Information is a priority for us.

Your Personal Information is hosted by our service providers who undertake to use reasonable security measures to preserve the integrity and confidentiality of your Personal Information.

Our employees and suppliers are informed of the confidential nature of the Personal Information collected and are made aware of the appropriate security measures to prevent unauthorised access to Personal Information.

We maintain our service and all associated data with technical, administrative and physical safeguards to protect you against loss, unauthorised access, destruction, misuse, alteration and improper disclosure of your Personal Information.

These protection measures vary according to the sensitivity of the data in our possession and are based on the best industry standards.

Unfortunately, no data transmission or storage system can be guaranteed to be secure at 100%.

If you have any questions about the security of your interaction with us (if, for example, you believe that the security of any account you may have with us has been compromised), you may contact us at [INSERT E-MAIL ADDRESS].

Your Rights Regarding your Personal Information

Depending on the applicable laws, where you live and how you interact with the Site, the Application or the Platform, you may be granted certain rights regarding the Personal Information we hold about you.

For example, you may be entitled to:  

• To obtain access to the Personal Information we hold about you;
• To correct Personal Information held by us that is inaccurate, misleading or incomplete;
• Request the deletion of your Personal Information;
• To obtain additional information, for example on the categories of third parties to whom we communicate your Personal Information;
• To object to the processing of your Personal Information carried out on the basis of our legitimate interests and ask us to restrict the processing of your Personal Information;
• To request the transferability of your Personal Information in a structured, commonly used and machine-readable [format];
• To provide you with the parameters that led to an automated decision, where applicable;
• To withdraw your consent at any time, if we have collected and processed your Personal Information with your consent.
• Withdrawal of your consent will not affect the lawfulness of the processing we carried out prior to your withdrawal, or the processing of your Personal Information carried out on legitimate processing grounds other than consent.
• File a complaint with a regulatory authority for the protection of personal information, such as a privacy commissioner or the Commission d'accès à l'information.

Making a complaint

You may file a complaint with Livesnap's Privacy Officer if you are dissatisfied with our handling of your Personal Information or compliance with this Policy.

You are also entitled by law to file a complaint with a privacy commissioner or any other competent regulatory authority for the protection of Personal Information.

Exercising your rights

You can exercise your rights listed above by making a written request to our Privacy Officer.

He will be able to help you with your request if you need it.

For your protection, we will only process requests to exercise your rights from the same email address that you use to log in to your account.

We may also need to verify your identity before processing your request.

Depending on the applicable laws, we will inform you of the procedure to follow, the processing time and the information required, if any.

We aim to respond to requests promptly, usually within 30 days.

Person Responsible for the Protection of Personal Information

Our Privacy Officer will provide you with the necessary support in the event of any question, complaint or request relating to the protection of Personal Information:

Person responsible for the protection of personal information

Livesnap

We are committed to responding promptly to your requests.

Upon receipt of a complaint, the Privacy Officer will conduct an investigation.

If the complaint is justified, the situation will be corrected. Whatever our conclusion, we will keep you informed.