Privacy & Cookie Policy

The protection of your personal data is Skeepers’ top priority.

The purpose of this Privacy and Cookie Policy (hereinafter the “Privacy Policy”) is to inform You (“Users” of our Services but also Internet Users) of the processing of your personal data carried out by Skeepers, and of your rights in this respect.

The Policy applies as soon as you arrive on the Skeepers website from the following URL address: https://skeepers.io/ (the “Site”) and governs the data processing carried out there. The Policy informs you of the use of Data made by Skeepers when you browse the Site and all the Services offered by Skeepers.

However, in order to obtain complete information on the processing of your Data that takes place within the framework of our Services (“Consumer Videos”, “Influencer Marketing”, “Rating & Reviews”), we kindly ask you to consult the relevant Privacy Policies:

“Influencer Marketing”: https://community.skeepers.io/privacy-policy/

“Consumer Videos”: https://legal.ugv.skeepers.io/PP/en/

“Verified Reviews”: https://www.verified-reviews.com/en/

Regarding our other Services, we kindly ask you to consult our Customers’ Privacy Policies, for a more complete information on their use of your Data.

The Privacy Policy may be modified to take into account, in particular, changes in the processing of Data implemented and applicable legislation. You are therefore invited to read any new version made available by Skeepers.

This document was last updated the 24th October 2025.

In the event of disagreement with the new wording of the “Privacy Policy”, you retain the right to request the deletion of all Personal Data concerning you by complying with the terms and conditions set out in section “10: Rights relating to Personal Data and their management”.

The Privacy Policy is divided as follows:

1: Definitions

2: General Information

3: Data Controllers and Data Subjects covered by this Privacy Policy

4: The processing of Personal Data by the Skeepers Group (origin of your data)

A) The processing of Personal Data carried out by Skeepers (Data Controller) on its website

1. Request a demo

2. Subscribe to the Newsletter

3. Request a Support

4. Download the e-book

5. Register for our Webinars / Events and Replay

6. Management of applications and interviews (creation of a CV database)

7. Cookies

B) The processing of Personal Data carried out by Skeepers (Data Processor) as part of its Verified Reviews, FeedBack Management, Customer Data Activation, Live Shopping and Brand Communities solutions

C) The processing of Personal Data carried out by Skeepers and its Clients (Separate Data Controllers) under its Influencer Marketing and Consumer Videos solutions

D) The processing of Personal Data by Skeepers (Data Controller) with respect to its Clients

5: “DO NOT USE MY SENSITIVE DATA” (CCPA/CPRA)

6: Social Media Data

7: Data Sharing / “DO NOT SHARE/SELL MY PERSONAL DATA” (CCPA/CPRA)

8: Data retention period

9: Data storage and security measures in place

10: Rights relating to Personal Data and their management

1: Definitions

Capitalized terms and phrases shall have the following meanings:

“Campaign” means an operation created by Customer on the Skeepers platform, shared with Creators, for the product(s) or service(s) that Customer has determined for the purpose of promoting it.

“Community“: refers to all registered and active users on the Community Platform. These users, called Members, interact with each other and with the Client via the chat rooms.

“Consent” of the data subject, means any freely given, specific, informed and unambiguous indication of his or her wishes by which the data subject agrees, by a statement or by a clear affirmative action, to the processing of personal data concerning him or her;

“Consumer“, “End Client” means a natural person who acts for purposes that do not fall within the scope of his or her commercial, industrial, craft or liberal activity; These are Data Subjects within the meaning of the GDPR;

“Content”: refers to texts, including reviews, images, sounds, videos, photographs, drawings, avatars, and more generally any visual, textual or graphic publication representing or referring to the products and/or services of Skeepers’ Customers, disseminated by a Creator as part of the Solution;

“Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing; where the purposes and means of such processing are determined by Union law or the law of a Member State, the controller may be designated or the specific criteria applicable to its appointment may be provided for by the law of the European Union. the Union or by the law of a Member State;

“Creator”: A person previously registered and accessing the Skeepers platform for the purpose of generating Content. These are Data Subjects within the meaning of the GDPR;

“Customer”, “Client” or “Brand” means the person or entity benefiting from Skeepers’ Services;

“Data Protection Regulation”: Includes REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, known as the General Data Protection Regulation (or GDPR), the Directive on Privacy and Electronic Communications 2002/58/EC (as amended by Directive 2009/136/EC, and as amended and replaced where necessary) and their transposition into national law, Law No. 78-17 of 6 January 1978 relating to data processing, files and freedoms, known as the “Data Protection Act”; and any regulations, rules, derivative or related legislation implemented by the European Union, a Member State of the European Economic Area and any country outside the European Union and the European Economic Area concerning the processing and protection of Personal Data (as amended and replaced from time to time);

“Influencer”: Creator who has received a product for free so that they can post dedicated Content on their social network (e.g. Instagram, TikTok, YouTube, Pinterest, Blog, etc.). These are Data Subjects within the meaning of the GDPR;

“Internet users”: persons browsing the https://skeepers.io/ website. These are Data Subjects within the meaning of the GDPR;

“Joint controllers” means two or more controllers who jointly determine the purposes and means of the processing(s) of personal data that they implement;

“Member(s)“: a Community Member means any person registered and active on the Community Platform. Members participate in discussions, interact with other Members and the Client, create and share content, and take part in Campaigns organized on the Platform. These are Data Subjects within the meaning of the GDPR;

” Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “Data subject“); an identifiable natural person means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity.

More simply, “personal data” is to be understood as any information that is specific to you (surname, first name, age, address, email, telephone number, etc.);

” Personal data breach ” means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

“Processing” is a use of your Personal data, which can take any form (collection, recording, hosting, modification, transfer, etc.);

“(Data) Processor ” means the natural or legal person, public authority, agency or other body which processes personal data on behalf of the Controller;

“Skeepers Group” or “Skeepers” refers to the economic entity formed by the company Skeepers, SAS with a capital of €11,948,329, registered with the Marseille Trade and Companies Register under number 879 038 990, whose registered office is located at 18-20 Avenue Robert Schuman, CS 40494, 13002 Marseille, and all the Group’s Subsidiaries;

“Separate controllers” means two or more controllers who separately determine the purposes and means of the processing(s) of personal data that they implement;

“Service(s)” / “Solutions” means the service(s) provided by the Skeepers Group – Verified Reviews, FeedBack Management, Customer Data Activation, Influencer Marketing, Live Shopping, Consumer Videos and Brand Communities – that you use/subscribe to by the Client;

“Site” or “Platform” means the website from which the Skeepers Group offers its Verified Reviews, FeedBack Management, Customer Data Activation, Influencer Marketing, Live Shopping, Consumer Videos and Brand Communities solutions, accessible from the following domain name: https://www.Skeepers.io/ ; https://community.skeepers.io/en/; https://www.avis-verifies.com/index.php?page=mod_liste_client;

“Supervisory Authority ” means an independent public authority established by a Member State pursuant to Article 51 of the GDPR, and with which any data subject may lodge a complaint concerning the protection of his or her personal data, i.e. the Commission Nationale de l’Informatique et des Libertés (CNIL) in France;

“Tester”: Creator who has received a product free of charge in order to generate a video (Consumer Videos) or text (Influencer Marketing) review, which will be displayed on the Client’s and/or its partners’ e-commerce site.

“User” means any person using any of the Skeepers Solutions.

“User Generated Content (UGC) “: all content created by users relating to a product and/or service, i.e. all types of content, whether or not protected by Intellectual Property rights, generated or not via Skeepers’ Solutions, including text reviews, images, photographs, videos and Content.

UGC Widget: Customizable module developed by Skeepers and made available to its Customers. This module allows an optimized display of UGC by its integration on its Customers’ site.

Any term specific to the protection of personal data (Data Controller, Data Subject, etc.) is defined in Article 4 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (known as the “General Data Protection Regulation“). or “GDPR“) which Skeepers undertakes to comply with.

2: General Information

By accessing and/or using the Site, and in general the Skeepers Services, you acknowledge that you have read the provisions of the Privacy Policy as a whole.

Access to the Site and use of the Services is prohibited to any minor under the age of sixteen. Therefore, by accessing and using the Site and Services, you represent and warrant that you are over 16 years of age if you are European, over 15 years of age if you are French, and over 13 years of age if you are American. If you are under the age requirement, you must not at any time or in any way access or use the Site and Services. If you are a parent or legal guardian of a minor and you believe that we hold Data about that minor, you may obtain deletion of the Data after proving your identity and legal authority over the minor by writing to privacy@skeepers.io .

3: Data Controllers and Data Subjects covered by this Privacy Policy

Skeepers, a simplified joint stock company with a capital of €11,948,329, registered with the Marseille Trade and Companies Register under number 879 038 990, and whose registered office is located at 18-20 Avenue Robert Schuman, CS 40494, 13002 Marseille, is the owner of the website https://www.skeepers.io/ . It offers Verified Reviews, Feedback Management, Customer Data Activation, Influencer Marketing, Live Shopping, Consumer Videos and Brand Communities Services.

Skeepers is particularly concerned about issues related to confidentiality, as well as the protection of the Personal Data of Users of its website and/or services, as well as those relating to its Customers. It takes this into account from the design of any new solution it offers to its customers.

It thus guarantees the highest level of protection of Personal Data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (known as the “General Data Protection Regulation”, hereinafter “GDPR”), French law (Data Protection Act of 1978, known as “LiL”) and, in general, with any regulations applicable to it in terms of the protection of such Personal Data “Data Protection Regulation“.

This “Privacy & Cookie Policy” describes in detail the policy and practices of Skeepers (or the “Skeepers Group”) regarding the collection, use and disclosure of Personal Data that it processes on its behalf or on behalf of its Customers. The Data Subjects concerned by the processing of the Data are the Users of the Solutions, including in particular the Internet Users browsing the Site (“You“).

Skeepers is qualified as a Data Processor with respect to its Clients who have subscribed to the Verified Reviews Solutions, FeedBack Management, Customer Data Activation, Live Shopping and/or Brand Communities.

Skeepers is qualified as a separate Data Controller with respect to its Clients who have subscribed to the Consumer Videos and Influencer Marketing Solutions, to which it offers different types of Content, generated by Creators and/or Testers, sharing their experiences on the Brands’ Products received, with the aim of increasing their visibility, through the Influencers’ accounts on social networks and/or on the Brands’ websites and other Third-Party Platforms.

It is qualified as a joint Data Controller with the company Meta, the Instagram button inserted on the Site allowing access to the Instagram account of Skeepers. For more information on data processing and data protection at Meta: https://www.facebook.com/about/privacy . To have access to the Data Controller Agreement, which determines the respective responsibilities for compliance with the obligations arising from the GDPR with regard to the Joint Processing of registration/login to the Platform via the Facebook button: https://www.facebook.com/legal/controller_addendum .

It is qualified as a joint Data Controller with company X (ex-Twitter), the X button inserted on the Site allowing access to Skeepers’ X account. For more information on data processing and data protection at X (formerly Twitter): https://x.com/fr/privacy.

It is qualified as a joint Data Controller with Google, the Youtube button inserted on the Site allowing access to the Youtube account of Skeepers. For more information on data processing and data protection at Youtube: https://www.youtube.com/intl/ALL_fr/howyoutubeworks/user-settings/privacy/

He is qualified as a Joint Data Controller with the company LinkedIn, the LinkedIn button inserted on the Site allowing access to Skeepers’ LinkedIn account. For more information on data processing and data protection at LinkedIn : https://fr.linkedin.com/legal/privacy-policy? .

4: The processing of Personal Data by the Skeepers Group (origin of your data)

Skeepers receives, collects and processes your Personal Data from a variety of sources, which are set out below:

A) The processing of Personal Data carried out by Skeepers (Data Controller) on its website

1. Request a demo

For any demo request made via the form available on the https://skeepers.io/fr/demo/ page , the User gives his/her consent to Skeepers, via a checkbox, for it to process the following Personal Data:

Name and surname;
Email address;
Phone number;
Hierarchical level;
Department;
Country.

They must be filled in in order to be able to contact you again to respond to your request for a demo, but also to send you personalized communications and offer you our other Services that may be of interest to you, given your needs (Verified Reviews, FeedBack Management, Customer Data Activation, Influencer Marketing, Live Shopping, Consumer Videos and Brand Communities). Otherwise, the demo request form will not be sent.

Skeepers will also be able to process any other personal data that the User has deliberately chosen to communicate to it, in the form, in the body of the message and during their exchanges.

Your information will be kept for three years from the last contact, before being deleted.

2. Subscribe to the Newsletter

For any subscription to the Newsletter made via the “Subscribe to our newsletter” insert on the Website https://skeepers.io// the User gives his consent to Skeepers, by entering his email address, to send him his newsletter.

The User can unsubscribe at any time via the unsubscribe link at the bottom of each email.

Your information will be kept until you exercise your rights of objection and/or deletion.

3. Request Support

For any support request made via the form available on the Help center https://help.tw.skeepers.com/hc/fr/requests/new?ticket_form_id=15445028072732 page or from the “help” or “Widget” button, as well as via Zoé, Skeepers’ help chatbot (Web widget), The User is informed that Skeepers will process their email address and any other personal data that the User has chosen to deliberately provide to Skeepers in the form, in the body of the message, in attachments, and during their exchanges within the framework of their commercial relationship. The Zoé Help Chatbot also collects your usage data (user ID, country code, campaign ID, useful yes/no article) to respond to your query and deposits cookies and other trackers to carry out statistical analyses in order to improve Skeepers’ products and services. For more information on the cookies deposited: https://support.zendesk.com/hc/en-us/articles/4408824378650-Zendesk-In-Product-Cookie-Policy

The email address must be provided in order to be able to contact you again to process your request. Otherwise, the support request will not be processed.

You can add as many people (email addresses) as you want to your support ticket. You may be asked for your Community ID to facilitate the processing of your request.

4. Download the e-book

For any download of e-books, white papers and guides present on the link https://skeepers.io/ebook/ the User gives consent to Skeepers, via a checkbox, to process the following Personal Data:

Name and surname;
Professional email address;
Company name.

They must be filled in order to be able to download the e-book, to contact you to better understand your needs, but also to send you personalized communications and offer you our additional solutions (Verified Reviews, Feedback Management, Customer Data Activation, Influencer Marketing, Live Shopping and Consumer Videos). Otherwise, the e-book will not be downloaded.

Skeepers will also be able to process any other personal data that the User has chosen to communicate to it in a deliberate manner, in the body of the message and during their exchanges.

Your information will be kept for three years from the last contact, before deletion.

5. Registration for our Webinars / Events and Replay

For any registration for one of our Webinars on page https://skeepers.io/fr/webinars/ or their replays, for one of our events (exhibitions/trade shows) present on the page https://skeepers.io/fr/evenements/ the User consents to the following Personal Data being collected by Skeepers and/or its partners, and shared with them.

Name and surname;
Email address;
Position Level:
Job title.

For events, particularly face-to-face events (exhibitions/trade shows), additional data such as telephone number and information related to badging may be collected.

For a list of partners, please write to privacy@skeepers.io.

This Personal Data must be provided in order to be able to register for the Webinar / event, watch the replay, but also to send you personalized communications and offer you our additional solutions (Rating&Reviews, Feedback Management, Customer Data Activation, Influencer Marketing, Live Shopping, Consumer Videos and Brand Communities) that may be of interest to you. Otherwise, access to the Webinar / event, to the replay, will be impossible.

Skeepers will also be able to process any other personal data that the User has deliberately chosen to communicate to it in the body of the message and during their exchanges.

Your information will be kept for three years from the last contact, before being deleted.

6. Management of applications and interviews (constitution of a CV library)

Any application received, spontaneously or in response to one of our job offers within the Skeepers Group, in particular from page https://careers.skeepers.com/, will be treated with the greatest care and attention by our Human Resources.

If, unfortunately, your profile has not been retained, we will keep your information (CV and cover letter) for 2 years, before deleting it, unless you exercise your right to object or delete it before the end of the period or you authorise us to keep it for a longer period of time.

The processing of your data is justified by the legitimate interest of the Skeepers Group to recruit and build up a CV library. The legal basis is pre-contractual when the candidate’s profile has been selected to join the Skeepers Group.

Your consent is sought when we have found your profile on the internet or to keep your data for a period longer than those mentioned above.

You have various rights over your information, including the right to access, update, oppose and delete, the terms of which are presented to you in the section “10: Rights relating to Personal Data and its management” and can be exercised at any time from the links available from Skeepers’ emails and this link: https://careers.skeepers.com/data-privacy .

For more information on data processing for recruitment: https://careers.skeepers.com/privacy-policy

LinkedIn’s privacy policy can be found at the following link: https://fr.linkedin.com/legal/privacy-policy

7. Cookies

Access to and browsing on the Site https://www.Skeepers.io/ triggers the processing of data collected through cookies, pixels and other similar technologies, trackers (collectively referred to as “Cookies” in this “Privacy and Cookie Policy”) necessary for the Site to function, in order to make your visit to the Site as simple, reliable and useful as possible.

Non-essential cookies are subject to the User’s prior consent before they are deposited.

· What is a cookie?

Cookies are basic digital information (text files) about how Internet users use the Internet; They do not identify you personally, but they do identify the computer you are using, based on data from your hardware and software. This data may include: your IP address and browser settings (type of browser used, browser language, time zone, referring website, domain names of sites visited, and information about your online activity: dates and times of access and the addresses of the website from which you accessed the Site).

Thus, during your various visits to the Skeepers Site, Cookies make it possible to recognize your computer or mobile device and thus personalize and improve your navigation. Cookies and other Trackers contain information that the Site uses to make communication with your browser more efficient.

To learn more about cookies, including how to block them on Chrome, Firefox and Internet Explorer browsers: https://allaboutcookies.org/

However, you are advised not to disable so-called “essential” Cookies from your browser as you may no longer have access to the Site and will no longer be able to browse it.

Where applicable, Skeepers declines all responsibility for the consequences related to the degraded behavior of the Site resulting from the impossibility of using the Cookies necessary for its operation.

Why does Skeepers use cookies?

1/ Skeepers uses so-called “essential” Cookies (“necessary” is the term used by specialized sites, in particular on that of the CNIL) whose function is to facilitate your access to the Site, while helping you to navigate and use all the features of the Site.

These cookies are also used to detect and prevent fraud.

These cookies do not require your consent as they are strictly necessary for the Site to function.

In order to find out more, you can consult them when you first visit the https://skeepers.io// website and at any time from the Cookies banner button, in the “Customize” section, then “Strictly necessary cookies”, and finally “Cookie details”.

2/ Skeepers also uses functionality and performance cookies that provide it with information about the use made of its Site, and allow it to better understand how it can improve its Site.

These Cookies are used by Skeepers:

– for marketing purposes to generate different statistics such as demographic statistics;

– in order to measure the performance and traffic of its Website;

– in order to optimize the experience on its Website.

[Data Sharing / “DO NOT SHARE/SELL MY PERSONAL DATA”]

In order to find out more, refuse or accept all or some of these functionality and performance Cookies, you can go to the “Customize” section, then “Functionality cookies”, “Performance cookies”, and finally “Cookie details” when you first visit the https://skeepers.io// website and at any time from the Cookies banner button. Thanks to the buttons at your disposal, you can accept all of them, reject them all, or accept some and reject others.

3/ By visiting the Skeepers https://skeepers.io// Site, “Third-Party Cookies” may be installed: these are Cookies placed on a User’s computer by the server of a domain separate from the Skeepers Site . Thus, a Third-Party Cookie “collected” on the Skeepers Site has not been placed by it but by its advertising partners, by social networks. They may be used by these companies to build a profile of your interests and provide you with relevant advertisements on other websites. They do not directly store personal data, but are based on the unique identification of your browser and internet device. If you do not allow these cookies, your advertising will be less targeted.

[Data Sharing / “DO NOT SHARE/SELL MY PERSONAL DATA”]

In order to find out more, refuse or accept all or some of these Third-Party Cookies (called “Social Network Cookies” and “Cookies for targeted advertising”), you can go to the “Customize” section when you first visit the https://skeepers.io/ website and at any time from the Cookies banner button, then “Social Network Cookies”, “Cookies for targeted advertising”, and finally “Cookie details”. Thanks to the buttons at your disposal, you can accept all of them, reject them all, or accept some and reject others.

B) The processing of Personal Data carried out by Skeepers (Data Processor) as part of its Verified Reviews, FeedBack Management, Customer Data Activation, Live Shopping and Brand Communities solutions

Skeepers is required to process Personal Data under its Verified Reviews, FeedBack Management, Customer Data Activation, Live Shopping and Brand Communities solutions as a Data Processor on behalf of its Customers.

Its Clients, as Data Controllers, ensure compliance with the Principles relating to the processing of Personal Data (Article 5 of the GDPR), i.e. the lawfulness, fairness and transparency of the collection of Personal Data that they carry out from their consumers, end customers, prospects and more generally all “Data Subjects”, which they then pass on to the Skeepers Group. Skeepers undertakes to comply with its obligations as a Data Processor under Article 28 of the GDPR and to apply the principle of Privacy by Design to all of its Solutions.

Skeepers’ Clients must comply with the GDPR: to do so, they must inform, prior to any collection of their data and in accordance with articles 12 et seq. of the Regulation, their consumers, end customers, prospects and more generally all “Data Subjects” of the processing of their Personal Data by the SKEEPERS Group. They collect their prior consent if necessary.

The Personal Data that is communicated to the Skeepers Group must be accurate, adequate, relevant and limited to what is necessary for explicit and legitimate purposes determined by the Data Controllers and which Skeepers respects. Skeepers, as part of its Verified Reviews , FeedBack Management, Customer Data Activation, Live Shopping and Brand Communities solutions, stores them securely for no longer than is necessary for the purposes for which they are processed.

The Clients of the Skeepers Group remain solely liable to the Data Subjects for any lack of information, inaccuracy, error or omission relating to their Data.

The Skeepers Group therefore declines all responsibility in the event of a violation of these fundamental principles by its Customers, and invites Data Subjects who believe that their rights have been violated to contact them directly.

The table below details the data processing(s) implemented by SKEEPERS as part of the Verified Reviews solution on behalf of its Clients

Nature of the operations carried out on personal data

■ Reception

■ Collection

■ Check in

■ Conservation

■ Modification

■ Consultation/Access

■ Usage

■ Effacement / anonymisation

■ Organization

■ Extraction

■ Communication

■ Diffusion

■ Provision

■ Destruction

Purposes some

Operations processing of personal data carried out by SKEEPERS on behalf of Customer

Main purpose: Collection, management and dissemination of Consumer Reviews.

Sub-purposes:

· Receipt of information held by the Client on its consumers (via API, SFTP, CMS connector) where applicable from the order history file and Reviews previously collected by the Client or from Third-Party Platforms;

· Sending of email/SMS campaigns (according to a rule pre-established by the Client: Purchase event);

· Reception and management/moderation of customer reviews (with the help of an Artificial Intelligence that suggests responses to the Customer with regard to the review left by the consumer “AI Review response”);

· Extraction and analysis of verbatims, keywords and verbatim polarity;

· Monitoring of the performance of Customer Reviews using analytical dashboards allowing decision-making by the Customer (with the help of an Artificial Intelligence that displays on a dashboard what sentiment is attached to the verbatim: positive, negative, category etc. “AI Review insights dashboards”);

· Publication and distribution of Customer Reviews: on the Customer’s websites, the product page, the Verified Reviews attestation page, the badge, the Verified Reviews directory, at the Customer’s choice: partner commercial sites (Brands and distributors), Third-Party Platforms, search engines, social networks, etc.;

· Useful notice: Prospects’ vote on relevant reviews counted thanks to their IP address;

· Q&A: to allow the Client to respond to the questions/needs of prospects and its consumers;

· Dissemination of a review carousel using a Widget implemented on the Client’s website (summary of reviews by Artificial Intelligence, only on the “AI reviews Summary” Product Reviews Widget);

· Deposit of a “Skeepers performance tracker” tracker for the purpose of producing performance metrics in order to demonstrate the impact of the presence of a Review Widget on the purchasing behavior of prospects on the Client’s e-commerce site (optional);

· Management of the accounts of the Solution Users designated by the Customer (assignment of access rights).

Categories of personal data processed

· Name of the consumer;

· Consumer’s first name;

· Consumer email;

· Consumer’s phone number if sending SMS;

· Order number / reference;

· Order date;

· Country code;

· Product purchased;

· Image (if applicable);

· Place of In-Store Purchase (if applicable);

· IP address (retrieved at the time the consumer validates his review);

· Email opening tracker (date, time, email delivery status, IP address, type of device used);

· Skeepers performance tracker (optional)

· Ratings given by the consumer to their customer experience;

· Content of the Review (personal opinion on customer experience);

· Date and time of publication of the Notice ;

· Consumer’s response(s) to the Merchant Partner’s comment(s) regarding a Review;

· Consumers’ response(s) to questions asked by Internet users on the Client’s website;

Username and password of the Solution Users designated by the Customer

Categories of persons concerned by the processing (hereinafter referred to as “the Persons

concerned”)

■ Consumers

■ Prospects

■ Employees and similar of the Client who use the Solution

Legal basis

■ Legitimate interest of the Client or consent of consumers (at the Client’s choice)

Recipients

At the Client’s choice:

– E-commerce connectors;

– Third-Party Providers;

– Third-Party Platforms;

– Social networks;

■ Brands and distributors.

Duration(s) from

conservation

Personal data is kept for 3 months from the sending of the AVIS VERIFIES e-mail, before being anonymised if no review has been filed.

If a consumer has posted a Review, the personal data attached to the Review is deleted by automated anonymization after eighteen (18) months. The consumer can have the anonymisation option ticked as soon as he submits his Review (a random pseudonym is attached next to his Review).

The anonymized Reviews will no longer be displayed 5 years from the date of their publication on the Verified Reviews attestation page and the UGC Widget.

The data relating to the order is used for 2 years from its integration into the Skeepers database in order to generate deliverability reports and dashboards and Avis deposit rates (optimization and daily aggregation).

Skeepers performance tracker (optional): 13 months

The table below details the data processing(s) implemented by SKEEPERS as part of the Feedback Management solution on behalf of its Clients

Nature of the operations carried out on personal data	■ Reception ■ Collection ■ Registration ■ Conservation ■ Modification ■ Consultation/Access ■ Usage ■ Effacement / anonymisation ■ Organization ■ Structuring ■ Adaptation ■ Extraction ■ Communication ■ Dissemination ■ Provision ■ Interconnection ■ Destruction
Purposes of the personal data processing operations carried out by SKEEPERS on behalf of the Customer	Main purposes: o Collect and manage customer insight by sending questionnaires at all stages of the buying journey to continuously optimize the experience and engagement of prospects and customers. Sub-purposes: o Receipt of the Client’s data (including manual, API or FTP import of the Client’s contact mailing list); o Where applicable, manual or FTP import into the Platform, of Customer experience data, reviews present on Third-Party Platforms, data from questionnaires already completed by the Customer, in order to continuously enrich the Customer’s database, by completing the information present in the Customer’s CRM tool; o Distribution of customizable questionnaires to the Client’s contacts according to a behavior previously determined by the Client, in particular with regard to the analysis of the Internet user’s journey on the sites published by the Client. The questionnaire can be sent via an API, and/or by displaying a pop-up/button on the Client’s websites and mobile phones, by email, by SMS, on social networks, containing a clickable URL link and/or a QR Code redirecting to the questionnaire; o Collection of information relating to the experience of Internet users, customers, prospects, partners, employees, etc. of the Client, or “customer insights”, consisting of the following elements: responses to surveys, opinions, information on lived experiences, attributes, etc. o Artificial Intelligence helps respond to respondents’ comments o ‘Segmentation’ of the responding population through personal and contextual information (attributes); o Analysis of the insights collected to improve the customer experience (customer irritants), develop customer centricity in their organization, etc. o Restitution to the Client of the results of the summary of the insights analyses, and/or the associated raw data in the form of reports as well as dashboards and performance analyses in terms of Customer experience; o Enable the Client to react and manage an action plan, to create scenarios according to the insights collected, in order to address the risks/opportunities and expectations of its customers, prospects, partners, employees, etc. ; o Improvement of the usability of customer insights by applying enrichments, transformations and analyses determined by the CLIENT: data recoding, transcription, translation, semantic analysis, etc. ; o Alerting and managing customer recontacts, re-engaging the Customer’s contacts based on the insights collected; o Where applicable, dissemination of the reviews collected on search engines and other Third-Party Platforms; o Management of the Solution Users designated by the Client (assignment of access rights as well as document sharing rules and results); o Where applicable, allow the Client to evaluate its teams and staff, internal or external to the Client’s organisation, thanks to the insights attached to the Users.
Categories of personal data processed;	Non-exhaustive list, according to the needs of the Data Controller, which it must determine below (“attributes”): o Name of the Referee (optional); o Respondent’s first name (optional); o Gender of the Respondent (optional); o Respondent’s email (optional); o Client ID (assigned by the Client); o Country (optional); o order number, purchase reference, etc. (optional); o date of purchase/order/subscription (optional); o date of the solicitation/sending of the email or SMS; o Image (if applicable); o “Raw insights”, i.e. the personal opinions of the Respondents (level of satisfaction, comments, etc.); o Insights triggering the re-engagement actions determined by the CLIENT; o Email opening tracker; o Cookies (if applicable); o Etc. (according to the Client’s needs). In the event that only the Customer ID is processed by the Solution, it is considered that there is no processing of personal data. In the context of the use of the Solution, the following information will be processed: o CUSTOMER account name; o Logs: • User login, • Time when the action was performed, • Page on which the action was performed, • Result of the action.
Categories of data subjects (hereinafter referred to as “Data Subjects”)	■ Respondents (determined according to the Client’s needs: employees, Client’s clients, prospects, partners, etc.) ■ S of the Client users of the Solution
Legal basis	Legitimate interest of the Client or consent (at the Client’s choice)
Recipients	At the Client’s choice: – E-commerce connectors; – Third-Party Providers; – Third-Party Platforms; – Social media
Retention period(s)	The answers to the questionnaires and the personal data attached to them are active and available on the customer’s account for a period of 24 months. This retention period is justified in order to carry out relevant statistical studies for the Client. It is possible to configure a shorter period at the Client’s request, however, our recommendation is not to lower the retention period of responses and data on the platform below 6 months. At the end of the chosen retention period, the answers to the questionnaires and the personal data attached to them are kept for a further period of 12 months. They may not be consulted by the Client, their retention is only justified by the activation of the reversibility clause that may occur during this period and will allow their extraction. Beyond these additional 12 months, personal data may be anonymized or deleted at the Customer’s request.

The table below details the data processing(s) implemented by SKEEPERS as part of the Customer Data Activation solution on behalf of Customer

Nature of the operations carried out on personal data

■ Reception

■ Collection

■ Registration

■ Conservation

■ Modification

■ Consultation/Access

■ Usage

■ Erasure

■ Organization

■ Structuring

■ Extraction

■ Communication

■ Dissemination

■ Provision

■ Reconciliation

■ Interconnection

■ Destruction

Purposes of the personal data processing operations carried out by SKEEPERS

Main purposes:

· Measurement of site traffic;

· Customer behavior monitoring for online and offline journey reconciliation;

· Commercial prospecting operations.

Sub-purposes:

· Collect and clean the data of a brand’s consumers;

· Have a complete view of all a consumer’s interactions in a single unified database (PULSE);

· Reconcile web data with data from transactional systems to reconcile identities;

· Facilitate customer knowledge by enriching customer data with qualifications;

· Facilitate customer knowledge by enriching customer data with segmentation;

· Facilitate customer knowledge by enriching customer data with product recommendations;

· Determine the consumers most interested in receiving a communication based on an objective (statistical or probabilistic models) and/or their interests (targeted advertising)

· Execute a personalized marketing campaign targeting a qualified audience with criteria pre-established by the Client “segmentation” (purchasing behavior, age, etc.) through different channels (email, SMS, voicemail, third-party provider, social networks, website);

· Measure the performance/impact of online/offline marketing campaigns (behavioral measure: volume of converts, conversion rate, Campaign turnover, Revenue per individual) and adapt them as necessary;

· Automate the sending of marketing campaigns to a targeted audience;

· Tracking the opening of marketing emails (use of a pixel, deposit of a cookie);

· Transfer campaign data to partners;

· Manage the accounts of the Solution Users designated by the Customer (assignment of access rights)

Categories of personal data processed

This is a non-exhaustive list, depending on the needs of the Data Controller, which it must determine below:

· Personal data identifying individuals (surname, first name, date of birth);

· Personal data relating to personal life (postal address, e-mail, telephone number, number of children);

· Personal data related to the transactions of the products and services purchased;

· Personal data related to browsing;

· Location-related personal data;

· Cookies (tag inserted on the site made available to the Client) they allow the Client:

o To establish statistics and volumes of traffic and use of the various sections of the site (audience measurement cookies);

o To reconcile the online and offline behavior of consumers (when connecting to the account on the Customer’s Site, when opening “email opening pixel” marketing emails, while browsing the Customer’s Site);

o To personalise the offers of goods and services offered to the Internet user.

· Username and password of the Users of the Solution designated by the Customer.

Categories of data subjects (hereinafter referred to as “Data Subjects”)

■ Prospects

■ Consumers

■ S of the Client users of the Solution

Legal basis

Consent

Recipients

At the Client’s choice:

– E-commerce connectors;

– Third-Party Providers;

– Third-Party Platforms;

– Social media

Retention period(s)

Each customer determines within the framework of its internal policy the appropriate retention period of its data.

Unless otherwise instructed by the Customer, the data is kept by Skeepers for the duration of the contractual relationship.

The table below details the data processing(s) implemented by SKEEPERS as part of the Live Shopping solution on behalf of the Customer

Nature of the operations carried out on personal data	■ Reception ■ Collection ■ Registration ■ Conservation ■ Consultation/Access ■ Usage ■ Erasure ■ Communication ■ Dissemination ■ Provision ■ Destruction
Purposes of the personal data processing operations carried out by SKEEPERS on behalf of the Customer	Main purpose: To put prospects in touch with salespeople, the Client’s advisors, or other stakeholders, through the broadcasting of a Live Shopping on the Client’s online sales platform, with the aim of triggering purchases. Sub-purposes: · Management of the registrations of prospects who wish to be notified of the Client’s Live Shopping via its form; · Automated sending of SMS and/or emails to the people concerned as a reminder of upcoming Live Shopping; · Upon participation/opening of a Live Shopping or access to its replay, assignment of a “Customer ID” Session ID number for the purposes of managing the flow of Shopping Party broadcasts and producing service performance metrics and statistics for the Client via the Tag; · Broadcasting of Live Shopping on the Client’s website, third-party platforms, and/or social networks (Simulcast); · Creation of a virtual shopping cart, known as the “pre-purchase process”, to allow the completion of the purchase on the Customer’s online sales platform, according to the purchase process proposed by the Customer; · Provision of a feature allowing the Client’s employees to moderate the chat; · Provision of a feature allowing the Client’s employees to broadcast a survey previously created during Live shopping; · Rating of Live Shopping by prospects; · Recording, hosting and storage of videos in order to allow replay; · Broadcasting of live and replays on the channels chosen by the Client (websites, third-party platforms, social networks, search engines, etc.) ; · Management of the accounts of the Solution Users designated by the Customer (assignment of access rights). Specific processing of the “Contests” add-on: Main purpose: Development and distribution of attractive content encouraging prospects to participate in competitions using a Widget implemented on the Skeepers Customers’ shopping party player. Sub-purposes: § Registration of entries via a registration form integrated into the content; § Random draw by algorithm of participants who have filled in the form, triggered by the administrators from the back office; § Display of winners to Skeepers administrators on the back office. § Dissemination of the winners by depositing a CSV file with a limited lifespan of 2 weeks on a secure FTP. Specific treatments for the Shoppable content add-on (UGC widget): · Broadcasting on the Client’s website of a carousel of UGC videos using a Widget allowing prospects to view the brands’ products with a view to acquiring them; · Video sharing and add-to-cart features of the product; · Deposit of a “Skeepers performance tracker” tracker for the purpose of producing performance metrics in order to demonstrate the impact of the presence of videos or live performances on the purchasing behavior of prospects on the customers’ e-commerce site.
Categories of personal data processed	· “Customer ID” session ID: assigned to each user on each Live Shopping session, whether live or replay (number of viewers, type of audience, number of product views, number of cart posts, number of messages (sent, average messages, engagement), number of hearts (sent, average hearts, engagement), average watch time per viewer, event duration, browser, mobile/computer, operating system and brand of the login tool, replay, UserAgent etc.). ; · Video: image and voice of the Client’s employees; · The telephone numbers OR email addresses of potential buyers who wish to be notified of the Client’s Live Shopping via the Client’s form; · Link opening tracking implemented in the SMS notification of the start of Live shopping; · Number of voters in the survey distributed by the Client; · Username and password of the Users of the Solution designated by the Customer. Specific processing of the “Contests” add-on: · Navigation : o Number of page views o Time per page o Current status · number of registrations, · number of options, · Number of partner options · Identification of the participant: o Auto-generated customer identity o Email o First name o Last Name o Telephone o Physical address (in case of physical gift distribution) Specific treatments for the Shoppable content add-on (UGC widget): · Image and voice; · Skeepers performance tracker : o Performance measurement cookie (1rst Party); o Data collected: Full IP, Customer ID, Content ID & Media ID (internal identifiers), number of views, average viewing time, number of viewers, type of audience, duration of the event, clicks, impressions, UserAgent (browser, OS, brand of the login tool and operating system), shopping cart, product ID in the cart, cart amount content of transactions, display, live playback or replay.
Categories of data subjects (hereinafter referred to as “Data Subjects”)	· The Client’s salespeople and/or advisors (the Client’s employees) or other stakeholders; · les prospects ; · participants in competitions (end customers or prospects); · Employees and similar of the Client who use the Solution
Legal basis	· Legitimate interest of the Client or consent (at the Client’s choice)
Recipients	At the Client’s choice: – E-commerce connectors; – Third-Party Providers; – Third-Party Platforms; – Social media
Retention period(s)	· Session ID “Customer ID”: kept for the duration of the Session; · Javascript Tag: Duration of the Contract (used to display product videos (Shoppable content) and live shopping; · Application logs: 6 months; · Skeepers stores and retains the videos in order to allow them to be replayed on the sites and pages identified by the Client for the entire Term of the Agreement. The videos are kept for an additional 12 months at the end of the term in order to allow the Client to exercise its reversibility clause; · The information collected to notify potential buyers of the Live Shopping for which they have registered is deleted 24 hours after the date and time of the Live Shopping. Processing specific to the “Competitions” service : · 12 months by default, destruction on demand Specificfeatures for the Shoppable content add-on (UGC Widget): § Image and voice: duration of the contract § Skeepers performance tracker : 13 mois

The table below details the data processing(s) implemented by SKEEPERS as part of the Brand Communities solution on behalf of the Client

Nature of the operations carried out on personal data	■ Reception ■ Collection ■ Registration ■ Conservation ■ Modification ■ Consultation/Access ■ Usage ■ Extraction ■ Provision ■ Erasure ■ Destruction
Purposes of the personal data processing operations carried out by SKEEPERS on behalf of the Customer	Main purpose: Community platform bringing together the Client’s active consumers to discuss the products and/or services provided by the Client, interact with each other through different means and, finally, be recognised and rewarded for their contributions. Sub-purposes: · Receiving emails from the Client’s consumers to create an account for them on the Client’s Community Platform (Client’s SSO login); OR Collecting personal information from Customer’s consumers in order to create an account for them on the Community Platform from Customer’s landing page; · Consumer account management; · Community chat; · Forum page (post, comment, like); · Photo/video gallery page (post, comment, like); · Routine page (post, comment, like); · Product pairing page (post, comment, like); · Blog page (post, comment, like); · Chat page (post, like); · One-to-one or group messaging (post, like); · Events forum (post, comment, like); · Contest forum (post, comment, like); · Moderation; · Ability to send surveys/studies/polls to the community to obtain customer insights (personal opinions); · Community gamification. ; · Possibility of sending products as rewards and/or to be tested by the community; · Editing community performance reports based on community benchmarking, site performance analysis, and agreed KPIs for each community (Community Health, Community Growth, Community Member Analysis, Website Performance Analysis, FAQ Analysis, Community Discussion Topic Analysis (Public Chat Groups), , measurement of retention, measurement of conversion impact, measurement of mission completion). · Management of the accounts of the Solution Users designated by the Customer (assignment of access rights).
Categories of personal data processed	Mandatory for registration and use of the Platform: · Nickname · email · USER ID/referral code · Performance metrics · Username and password of the Users of the Solution designated by the Customer. Optional for the use of the Platform: · Name · forename · gender · Date of birth · Location: city, country (full address if shipping products) · social media data, · biography · response to the Client’s surveys/studies/polls (personal opinions), · profile picture, · Cookies · IP address (allows to block a user of the chat widget who is not registered on the Customer’s site); · image · video Then according to the Client’s needs (e.g. skin type, skin problems/sensitivity, age range etc.)
Categories of data subjects (hereinafter referred to as “Data Subjects”)	■ Customer’s consumers ■ Employees and assimilated of the Client using the Solution
Recipients	At the Client’s choice: – E-commerce connectors; – Third-Party Providers; – Third-Party Platforms; – Social media
Retention periods	Duration of the contract Deletion of consumer data at their request and after 36 months of inactivity on their user account Community Chat: – IP address: 3 weeks for all Users of the Platform, 13 months for banned Users – Cookies: 13 months

Users are informed that the above information is provided for information purposes only and is subject to change or modification according to the needs of Skeepers’ Clients.

Personal data is processed by the competent departments of Skeepers, who need to know information for the proper performance of their missions. They are subject to a Confidentiality Agreement.

C) The processing of Personal Data carried out by Skeepers and its Clients (Separate Data Controllers) under its Influencer Marketing and Consumer Videos solutions

Clients subscribing to Skeepers’ Influencer Marketing and/or Consumer Video Solutions acknowledge that they are acting with Skeepers as separate Data Controllers: they must comply with their legal obligations and maintain the confidentiality and security of the Data they share with Skeepers (“Shared Data”).

The Separate Data Controllers have formalized an Agreement on the specific conditions under which each of them will act as a separate Data Controller on the Shared Data. The outline of this agreement must be made available to data subjects within, for example, the privacy policies or any other appropriate document of the separate controllers, in order to comply with their duty to inform, which they undertake to do.

In this Privacy and Cookies Policy of Skeepers, it is stated that the Separate Data Controllers undertake in particular, to:

collect and process Personal Data in accordance with the regulations in force, in compliance with the Principles relating to the processing of Personal Data (Article 5 of the GDPR). The legal basis for the processing of data of data subjects by Skeepers under its Influencer Marketing and Consumer Videos solutions is the contractual basis (Article 6 §1 b) of the GDPR), with Users subscribing to its Services;

comply, prior to and throughout the duration of the processing, with the laws and regulations applicable to the protection of Personal Data, and in particular the GDPR;

implement organizational, technical, software and physical measures to protect the Data against alteration, destruction and unauthorized access;

ensure that the persons authorised to process the Data undertake to respect confidentiality or are subject to an obligation of confidentiality;

guarantee Users the effective exercise of all the rights they have under the GDPR;

not to use the Shared Data for purposes other than those expressly determined between them;

never transfer or make available the Shared Data and files to third parties for any purpose whatsoever and in particular for commercial prospecting purposes without the prior consent of the User;

retain Shared Data only for as long as is strictly necessary.

For a full list of Customers with whom the Skeepers Group is a separate Data Controller, please write to privacy@skeepers.io .

The table below details the data processing(s) implemented by SKEEPERS as part of the Consumer Videos solution :

Nature of the operations carried out on personal data

■ Reception

■ Collection

■ Registration

■ Conservation

■ Modification

■ Consultation/Access

■ Usage

■ Erasure

■ Extraction

■ Communication

■ Dissemination

■ Provision

■ Interconnection

■ Destruction

Purposes of the personal data processing operations carried out by Skeepers

Main purpose:

Creation, processing and distribution of promotional videos on the Internet.

Sub-purposes:

· Where applicable, tracking of links integrated into the distribution media of the Client’s Campaigns in order to assess their impact;

· Receiving personal information from Customer’s employees participating in the Campaigns to provide access to the Consumer Videos Platform (creation of an employee Platform);

· Collection of registration information from Platform Users (via email, social networks or other Third-Party Platforms) in order to create an account for them from the Client’s landing page;

· Receipt and sharing with the Client the completed forms and/or videos presenting the candidates to the Campaign;

· Access to candidates’ information according to the authorisation of the Client’s employee;

· Moderation of applications by Customer or Skeepers;

· Management of the order and distribution of the Products sent to the Testers (unless otherwise requested by the Client who wishes to deliver its products himself, in which case the Testers’ contact details will be communicated to the Client);

· Reminder of Testers who have not made Videos by any means (email, telephone, post);

· Receiving and sharing with the Client the promotional videos of the Testers;

· Moderation of Videos by Skeepers or Customer;

· Automatic generation of subtitles and translation by Artificial Intelligence;

· Internal Notes;

· Separate messaging with Testers and with Skeepers;

· Channels for broadcasting/sharing the Videos on the Internet by the Client (websites, Third-party platforms, partner commercial sites (Brands and distributors), social networks, QR code, etc.);

· Voting, participation and online video sharing features on product pages;

· Management of Users’ / Testers’ accounts by Skeepers;

· Proposal of campaigns similar to those in which the Tester participated and/or according to his preferences entered in his profile (opt-in) by Skeepers;

· Export of the personal information of users of the Consumer Videos platform related to the Customer;

· Image rights management;

· Data analysis, performance metrics (registration rate, number of applications, complete, validated or rejected applications, number of video projects, impacted product sales rate, number of video views, video playback rate, average number of video plays, number of visitors, distribution of visitors by sources, distribution of visits by devices, number of connections, distribution of sales of products impacted by devices, number of product sales, number of impacted product sales, impacted sales rate, distribution of videos by device, number of views on product sheets, number of video plays, observation rate, product page views/number of video plays, average viewing percentage (completion rate), number of flashes and QR code views, etc.);

· Ratings of the Videos with the best ratings, the most views, the most votes, the most shared, the most to the purchase etc.

· Marketing analytics and statistics.

· Gallery of videos validated by the Client;

· Management of the accounts of the Client’s employees and assimilated persons.

Specific treatments for the Shoppable content add-on (UGC widget):

· Broadcasting on the Client’s website of a carousel of UGC videos using a Widget allowing prospects to view the brands’ products with a view to acquiring them;

· Video sharing and add-to-cart features of the product;

· Deposit of a “Skeepers performance tracker” tracker for the purpose of producing performance metrics to demonstrate the impact of the presence of videos on the purchasing behavior of prospects on the customers’ e-commerce site.

Categories of personal data processed (“Shared Data”)

· Name;

· Forename;

· Photo;

· Video;

· Date of birth;

· Email;

· Phone number;

· Postal address;

· Interests;

· Information published on social networks;

· IP address;

· Tracers;

· Performance metrics;

· History and details of participation in the Campaigns;

· Number and dates of Videos and Content published on the Platform;

· Opinions, votes, shares on Videos;

· Attachments attached to Internal Notes/Messaging Messages, which may contain Personal Data;

· Username and password.

· Shoppable content add-on data (UGC widget): Image and voice;

· Skeepers performance tracker :

o Performance measurement cookie (1rst Party);

o Data collected: Full IP, Customer ID, Content ID & Media ID (internal identifiers), number of views, average viewing time, number of viewers, type of audience, duration of the event, clicks, impressions, UserAgent (browser, OS, brand of the login tool and operating system), shopping cart, product ID in the cart, cart amount content of transactions, video display, playback, pause.

Categories of data subjects (hereinafter referred to as “Data Subjects”)

■ Employees and assimilated of the Client users of the Consumer Videos platform;

■ End customers / consumers or prospects of the Customer;

■ Testers;

■ Customer’s contacts and business partners;

■ Employees or external employees hired by the Client.

Legal basis

Contractual: registration on the Platform

Recipients

At the option of the Parties:

– E-commerce connectors;

– Social networks;

– Third-Party Providers;

– Third-Party Platforms;

– Brands and distributors;

– Distributors of Products sent to Testers.

Retention period(s)

After 90 days, the following are deleted:

· Videos of cancelled applications;

· Rushes/application videos accepted. Only the final video is used for broadcasting.

The contact data and video data processed by the Platform are active and available on the customer’s account for 12 months.

After 12 months, the data related to the videos and videos are stored in this sense:

• The videos are kept for 20 years and may be made accessible when the Client subscribes to a new licence;

• The data related to the videos (contact data / video data) is made accessible at the customer’s request for 12 months. At the end of this period, this data is anonymised and saved for statistical purposes. Anonymization consists of substituting fake data for all personal data. Once anonymised, the data is no longer accessible to the Client.

The durations may be adjusted by the Client (with the exception of the retention period of the Videos)

Users’/Testers’ Data is kept for the duration of their activity on the Platform. They will be anonymized 6 months after the closure of their account;

Users/Testers’ Data is deleted within 2 years of their last activity on their account.

§ Shoppable content add-on specific durations (UGC widget):

§ Image and voice: 20 years

§ Skeepers performance tracker : 13 months

The table below details the data processing(s) implemented by SKEEPERS as part of the Influencer Marketing solution

Nature of the operations carried out on personal data

■ Reception

■ Collection

■ Inscription

■ Conservation

■ Modification

■ Consultation/Access

■ Usage

■ Erasure

■ Organization

■ Extraction

■ Communication

■ Dissemination

■ Provision

■ Reconciliation

■ Interconnection

■ Destruction

Purposes of the processing of personal data by SKEEPERS

Main purpose (Influencers):

· To put the Client in touch with the influencers, users of the platform, in order for the latter to create content presenting the Client’s products on social networks and/or on the Client’s websites, depending on the campaigns chosen by the latter.

Sub-purposes:

· Selection at registration of influencers who meet Skeepers’ prerequisites (eligibility criteria vary depending on the social network used) with the help of an Artificial Intelligence analyzing the content created by influencers on their social networks;

· Creation and management of Influencers’ accounts, connection to their social networks;

· Assistance to the Client in the creation and management of its Influencer review campaigns;

· Suggestion to the Client of Influencer profiles according to their interests, their social media settings, the campaigns already run, offering a high compatibility rate (in percentage) with the Client’s Campaigns (matching/scoring) using Artificial Intelligence (“AI influencers match”);

· Messaging;

· Delivery of the products by Skeepers OR Transmission to the Customer of the contact details of the persons concerned, in the event that the Customer is in charge of the delivery of the products;

· Publication of content presenting the Client’s products on the Influencers’ social networks;

· Overall Influencer Rating (scoring);

· Top 10 influencers according to the performance metrics generated by their posts (impression / interactions / reaches/ likes/comments/shares);

· Categorization of influencers according to their performance scores and metrics (silver, gold, platinum);

· Affixing ARPP badges to Influencers who have completed the training;

· Verification of the presence of the mention of commercial collaboration on the influencers’ posts, according to the laws in force, using Artificial Intelligence “AI compliance”;

· Proposal of new campaigns, campaigns similar to those in which the Influencer has participated and/or according to his preferences filled in his profile (opt-in) by Skeepers;

· Analysis of influencers’ performance metrics (followers, performance, likes, engagements, audience location, average age, etc.), their activities (average acceptance rate, production rate, etc.) and the latest content published;

· Dashboards: Reports (Number of interactions, engagement rate, Earned media value), Marketing (number of campaigns, number of interactions (likes and views), Earned Media Value, creator activation funnel, review publication graph, campaign and creator ranking), Reviews (all reviews posted by your influencers) and Traffic (clicks from product reviews) (export in CSV format);

· Integration and training session;

· Ongoing management of the Client’s employee and equivalent accounts:

○ Creation

○ Email and phone support

○ Assistance with campaign strategy and best practices.

Main purpose (Testers):

· To put the Client in touch with consumers, users of the platform, in order for the latter to write written reviews about the products offered by the Client on the Client’s websites.

Sub-purpose:

· Creation and management of registered consumer accounts;

· Assistance in the creation and management of consumer review campaigns;

· Delivery of the products by Skeepers OR Transmission to the Customer of the contact details of the persons concerned, in the event that the Customer is in charge of the delivery of the products;

· Publication of their “gifted reviews” by consumers : on the Client’s websites, partner commercial sites (Brands and distributors), Third-Party Platforms, search engines, social networks:

· Product rating and consumer recommendation of the Product.

Specific treatments for the Shoppable content add-on (UGC widget):

· Broadcasting on the Client’s website of a carousel of UGC videos using a Widget allowing prospects to view the brands’ products with a view to acquiring them;

· Video sharing and add-to-cart features of the product;

· Deposit of a “Skeepers performance tracker” tracker for the purpose of performing performance metrics to demonstrate the impact of the presence of videos on the purchasing behavior of prospects on the customers’ e-commerce site

Categories of personal data processed

Mandatory for registration on the Platform:

o Email;

o Location (country);

o Date of birth.

Mandatory for Consumer Campaigns:

o Name and surname;

o Gender;

o Full mailing address;

o Phone number.

Mandatory for Influencer Campaigns:

o Name and surname;

o Gender;

o Full mailing address;

o Telephone number;

o Public data accessible from the Influencer’s account on their social networks, retrieved via API

o Performance metrics.

The customer only has access to the contact details of the persons concerned in the event that he or she is in charge of the delivery of the products.

Otherwise, they will not have access to any personal data of consumers (Testers) on the Platform, only of Influencers if applicable.

Not Required to be Provided by Influencers:

o Image (and voice if Video);

o Skin color;

o Relationship status;

o Parenthood;

o Number of children;

o Animals;

o Shopping habits;

o Skin type and concerns;

o Beauty habits;

o Hair color/type;

o Household income;

o Diet;

o Eyebrow color;

o Glasses;

o Sizes;

o Lifestyle;

o Skin problems;

o Favorite brands;

o Interests;

o Cookies.

Not Mandatory provided by consumers:

o Facebook account

o Image

o Cookies

Data specific to the Shoppable content add-on (UGC Widget):

· Image and voice;

· Skeepers performance tracker :

o Performance measurement cookie (1rst Party);

Categories of data subjects (hereinafter referred to as “Data subjects”)

■ Influencers

■ Consumers

■S of the Client users of the Solution

For processing specific to the Shoppable content add-on (UGC Widget):

■ Prospects

Legal basis

Contractual: registration on the Platform

Recipients

At the option of the Parties:

– E-commerce connectors;

– Social networks;

– Third-Party Providers;

– Third-Party Platforms;

– Brands and distributors:

– Distributors of Products sent to Influencers/consumers.

Retention period(s)

Creators’ personal data is kept for the duration of their activity on their Creator Space. They will be anonymized 6 months after the closure of their account. Accounts are deleted 2 years from their last activity on their account.

Shoppable content add-on specific durations (UGC widget):

§ Image and voice: 20 years

§ Skeepers performance tracker : 13 mois

D) The processing of Personal Data by Skeepers (Data Controller) with respect to its Clients

As part of the subscription to one or more of the Skeepers Group’s solutions, and then as part of this collaboration, Skeepers processes the Personal Data of of representatives, employees, assimilated or external employees hired by its Clients.

The table below details the data processing carried out by the Skeepers Group in connection with its relations with its Clients:

Nature of the operations carried out on personal data

■ Reception

■ Collection

■ Registration

■ Conservation

■ Modification

■ Consultation/Access

■ Usage

■ Erasure

■ Extraction

■ Communication

■ Dissemination

■ Provision

■ Interconnection

■ Destruction

Purposes of the personal data processing operations carried out by Skeepers in connection with its relations with its Customers

· Commercial prospecting;

· Listening to and recording telephone and video conversations in the context of incoming and outgoing calls with prospects/customers in order to improve the quality of the service provided;

· Management of the pre-contractual, contractual/commercial relationship;

· To enable access to and use of the Platform and the services / Creation and management of the Client’s account to the Subscribed Solutions;

· Training and support on all media from the Client to the Subscribed Solutions;

· Carry out any operations related to the Services;

· Provision of a support service (ticketing, Chatbot, etc.);

· Sending transactional communications in the context of the performance of the Services or for information purposes , in particular in the event of changes to the General Terms and Conditions, change of password, etc.;

· Sending commercial communications (marketing newsletter) in relation to the subscribed or similar Services (UGC);

· Conducting Customer Satisfaction Surveys (CSAT) in all formats (e-mail, telephone, etc.) in order to improve our Products and Services;

· Carrying out analyses and statistics based on data on the use of the Solutions by Customers; in particular in order to improve the operation and optimize our Solutions;

· Carrying out anonymous analyses, statistics, processing, surveys and studies with the aim of improving our services and assessing consumption habits and trends among end customers:

· Maintaining the Platform in its proper functioning and in a secure environment;

· Resolution of any technical incidents encountered;

· Solicitation of payment for the Services subscribed to;

· Management of unpaid invoices, litigation and disputes;

· Detection, prevention and fight against fraud and cybercrime;

· Keeping general and auxiliary accounts;

· Responses to official requests from public or judicial authorities authorized for this purpose, transfer of data if necessary;

· Acquisition audit by potential buyers, data transfer if necessary.

Categories of personal data processed

· Last name;

· Forename;

· Professional email address;

· Business phone number;

· Image (if video interview) especially in the email signature;

· Voice (if video/audio interview);

· Identifier;

· Password;

· Logs;

· Cookies and other Trackers;

· Bank details.

Categories of data subjects (hereinafter referred to as “Data Subjects”)

· Prospects ;

· Employees, assimilated or external employees hired by the Client;

· End customers.

Legal bases (depending on the purpose)

· Pre-contractual / contractual

· Skeepers’ legitimate interest

· Consent (prior to video/audio interview recording)

· Legal obligation

Recipients

· For a complete list of recipients of your data, please contact: privacy@skeepers.io

Retention period(s)

Retention of identification and professional data: three (3) years from the last contact in the context of commercial prospecting.

Retention of identification and professional data: five (5) years from the end of the contractual relationship between the Skeepers Group and the Client (prescription under common law in civil and commercial matters).

Retention of video/audio data for a maximum of 6 months from the date of recording of the audio or video interview. Data from analysis documents (minutes and analysis grids) are kept for one (1) year from their collection.

Retention of bank data: throughout the tacit renewal, until the last payment due date, which corresponds to the date of termination by the Customer. The storage is then extended for a period of 13 months following the date of debit, or 15 months in the case of deferred debit payment cards, in order to be able to manage any complaints and dispute transactions, before complete deletion.

Retention for the duration of the dispute, deletion of the data once all appeals have been exhausted and the decision has become enforceable or the legal action is time-barred.

In the event of an amicable settlement of the dispute, deletion as soon as the dispute is settled.

Retention during the current accounting year, increased by ten (10) years from the closing date.

Personal data is processed in the Skeepers Group only by the competent departments, which need to know the information for the proper performance of their missions. They are subject to a Confidentiality Agreement.

5: “DO NOT USE MY SENSITIVE DATA” (CCPA/CPRA)

Sensitive data is a special category of personal data.

This is information that reveals the alleged racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, as well as the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Skeepers does not collect any sensitive data on https://skeepers.io/ (the “Site”).

Regarding the processing of sensitive data that takes place within the framework of our Solutions, we kindly ask you to consult the relevant Privacy Policies:

“Influencer Marketing”: https://community.skeepers.io/

6: Social Media Data

To find out which Social Media Data is processed by our Solutions, please consult the Privacy Policy of the Solution concerned:

“Influencer Marketing”: https://community.skeepers.io/privacy-policy/

“Consumer Videos”: https://legal.ugv.skeepers.io/PP/en/

“Verified Reviews”: https://www.verified-reviews.com/en/

« Brand Communities »:

Using YouTube API Services

Some features of Skeepers use YouTube API services to improve your experience. When you use these features, you agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and the YouTube Terms of Service (https://www.google.com/policies/privacy).

Data collected through the YouTube API

We may collect and process the following data through YouTube API services:

YouTube profile information (e.g., channel name, profile picture)

Video data and analytics

Publicly available content and engagement metrics

How we use and share your data

Data collected through the YouTube API is used to provide and improve our services, personalize your experience, and generate analytics.

Data may be shared internally within Skeepers and with trusted service providers, only to the extent necessary to provide our services.

We do not sell your personal data to third parties.

Cookies and Tracking Technologies

We do not store, access, or collect information on your device, through cookies or similar technologies, when you use features provided by YouTube API Services.

Data retention and deletion

The data collected via the YouTube API is only kept for as long as is necessary for the purposes described above.

You can revoke Skeepers’ access to your YouTube data through your https://myaccount.google.com/permissions .

7: Data Sharing / “DO NOT SHARE/SELL MY PERSONAL DATA” (CCPA/CPRA)

At Skeepers, your Personal Data has never been sold to third parties and never will be.

Skeepers undertakes to verify that all its subcontractors, suppliers and partners necessary for the performance of the services scrupulously comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and to enter into contracts with them including a Data Processing Agreement and a Non-Disclosure Agreement.

In this context, all SKEEPERS subcontractors, suppliers and partners are required to provide sufficient guarantees demonstrating that the applicable technical and organisational security measures for the protection of Personal Data have been taken (Article 32 of the GDPR).

In order to ensure the proper functioning of its Services, Skeepers uses IT and technical service providers (e.g. those in charge of maintaining the IS) such as IT service providers (e.g. the hosting provider), SaaS solutions that need to have access to Data to carry out the mission entrusted to them by Skeepers. Skeepers imposes strong obligations on these contracting parties in terms of processing, confidentiality and security of the Data to which these service providers have access.

Skeepers may also share your Data with its subcontractors in order to perform statistical analysis, editing, subtitling videos, manage video projects, send you an email, SMS, or mail, provide customer support, etc. These subcontractors may have limited access to some of your Personal Data in the strict context of the performance of their services. They have a contractual obligation to use it in accordance with the applicable provisions and regulations on the protection of Personal Data. They only use your Data to provide the services to which Skeepers has subscribed, and this is done with the guarantee of maintaining the strict confidentiality of the Data.

For a complete list of subcontractors, please write to privacy@skeepers.io .

Skeepers may also be required to communicate your Data to third parties in certain specific cases:

If Skeepers is obliged to follow up on claims made against it and to respond to administrative and judicial proceedings (right to defence);
If Skeepers intends to divest a business or assets (including by divesting the business carrying on that business or owning those assets), your Data may be disclosed to the acquirer and potential acquirers as part of an audit, including their advice. If all or a portion of Skeepers’ assets are acquired by a third party, Data will be one of the transferred assets. The Data will be processed by the acquirer who will act as the new data controller and its Data protection policy will then govern the processing of the Data (merger, acquisition, sale of assets);
If Skeepers is compelled to disclose or provide access to the Data to comply with a legal obligation or court order, or to enforce or apply the performance agreement or any other accepted circumstances, or to protect the rights, property, or safety of Skeepers, its customers, or its employees (legal obligation).

You have the right to object, at any time, to the Sharing of your data with Third Parties. We will then no longer transmit your data to these Third Parties, unless (i) these Service Providers are essential for the proper performance of the Services offered (you will then have to unsubscribe from these Services) (ii) can justify to you that we have legitimate and compelling reasons for the Sharing/Processing of your data that prevail over your interests and your rights and freedoms (iii) for the establishment, exercising or defending our legal rights.

For the sharing of data with social networks and ways to object to it, please refer to point 6: Social media data.

For the deposit of cookies and how to object to them, please refer to sub-point 8. Cookies.

It is possible, through certain Skeepers Solutions (Influencer Marketing and Consumer Videos) to connect your account on our Platforms to other third-party accounts. By connecting your account to other third-party accounts, you acknowledge and agree to the ongoing sharing of information about you with other parties (in accordance with the privacy settings you have set on those third-party sites). If you do not want your Data to be shared in this way, do not use this feature.

You can disconnect your account from a third-party account at any time. You can learn how to disconnect your accounts from any third-party site by visiting your Account information page.

For more information on the processing of your Personal Data on the Consumer Videos Platform, the privacy policy can be found at the following link: https://legal.ugv.skeepers.io/PP/en/

For more information on the processing of your Personal Data on the Influencer Marketing Platform, the privacy policy can be found at the following link: https://community.skeepers.io/

For more information on the processing of your Personal Data on Rating & Reviews, the privacy policy can be found at the following link: https://en.verified-reviews.com/privacy-policy/

8. Duration of data retention

Your Data is only kept for the time strictly necessary for the purposes established in the previous articles of the Privacy Policy (article 4. The processing of Personal Data by the Skeepers Group (origin of your data)), in accordance with the recommendations of the CNIL, and in compliance with legal obligations, in particular accounting and tax obligations.

Beyond the defined retention periods, the Data will be anonymized and only kept for statistical and archival purposes, after which it will be destroyed.

9. Data storage and security measures in place

Skeepers ensures the security of your Data and takes all necessary measures to ensure its confidentiality and prevent access, use, alteration, corruption, disclosure, and/or destruction by unauthorized persons.

To this end, Skeepers has implemented organizational, technical, software and physical measures in accordance with Article 32 of the GDPR listed in its Security Assurance Plan and Information Systems Security Policy. These include:

– Data anonymization techniques upon request;

– Regular backup of Personal Data with regularly validated restoration processes, in technically and physically separate backups;

– Secure hosting (Amazon Web Services hosting company ISO 27001 certified for technical measures, ISO 27017 for cloud security, ISO 27018 for cloud privacy, SOC 1, SOC 2 and SOC 3, PCI DSS Level 1, BSI Common Cloud Computing Controls Catalogue (C5), ENS High.);

– Protection in terms of access control (authentication and authorization control), processing, storage or exchange (encryption) to ensure confidentiality: access to your Data is limited and restricted only to the people/services that need to access it, who have signed a Confidentiality Agreement, this Data is stored on secure servers, Your Data is encrypted in transit and at rest (KMS encrypt). Access to your Data requires the use of a strong username and password.

– Skeepers’ information system includes centralized and protected logging of the use of the services to detect any intrusion or fraudulent use, to try to identify the causes and origins, to avoid any contamination of other sites by bounce and finally to re-establish the system.

– An in-depth security analysis to assess its level. It should be noted that if the required level is not reached, a new design phase is opened in order to reach the level required by the Skeepers Group;

– Ongoing audits (Bug Bounty) and one-off audits (Pentest) carried out by accredited Third Parties.

Despite all these measures, your attention is drawn to the fact that the Internet is not a completely secure environment, so it is not possible to guarantee the absolute security of the transmission and storage of your Data.

In accordance with Article 33 of the GDPR, Skeepers undertakes to notify the CNIL, as soon as possible, of any Data breach likely to cause a risk to the rights and freedoms of the Users of its Solutions (in cases where it is the Data Controller), and to inform them if the risk is high.

Skeepers is committed to ensuring that your data is hosted within the European Union and the European Economic Area. However, some specific services of Skeepers are operated outside the territory of the European Union and the European Economic Area, so a limited amount of your Personal Data will be shared with these service providers in countries outside the European Union.

Skeepers then ensures that Standard Contractual Clauses are signed in their latest version in force with the said third-country service providers, and that additional technical measures are implemented in order to be able to ensure a sufficient level of protection for the Sharing of your Data, according to the recommendations of the supervisory authorities, including the European Data Protection Board in its “Recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the EU level of protection of personal data”.

10. Your rights

In the context of the Data processing carried out by Skeepers, you have the right to:

To obtain access to/copy of your Processed Data;
To obtain the rectification of your Data;
To obtain the deletion of all or part of your Data when the Data, (i) is no longer necessary for the purposes for which it was collected, (ii) is based exclusively on consent, (iii) is the subject of an objection request;
To object to the processing of your Data due to your particular situation;
To obtain the restriction of processing, temporarily, when the accuracy of the Data is contested, when you have objected to the processing, when your Data is no longer necessary for Skeepers but is still necessary for the establishment, exercise or defence of legal claims;
To unsubscribe or object to the receipt of commercial prospecting messages at any time by following the unsubscribe instructions indicated in the promotional emails you receive;
Withdraw your consent at any time in the case of consent-based processing;
To obtain the portability of your Data when the processing is based on consent and the processing is carried out using automated processes;
Provide guidance on the fate of your Post-Mortem Data.

To exercise your right to delete your Data, your account, or to object, you can send your request to the following address: datadeletion@skeepers.io

To exercise any of your other rights or have any questions about this Privacy Policy, you may send a request to the following address: privacy@skeepers.io .

You can write to us at the address listed below:

SKEEPERS

Legal Department – Data Protection Officer

18-20 Avenue Robert Schuman

CS 40494

13002 Marseille

For any request to exercise your rights, you must, in your message:

Specify the address (email or postal) where you would like to receive a response from Skeepers. Otherwise, we will choose the same method you used to contact us;
Include a means by which you can be identified (order number, customer ID, etc. if the means provided does not seem sufficient to prove your identity, a copy of your identity document may be required);
Specify, if possible:

– the context in which your data was collected,

– as well as the Relevant Solution

– In any case, please attach the email received from us.

This information is valuable so that the Data Protection Officer can respond to you as quickly as possible.

Skeepers informs you that no requests will be processed over the phone.

A response will be sent to you as soon as possible, which may not exceed one (1) month from the date of receipt of your request.

A two (2) month extension is possible, in the event of a complex application, or if a large number of applications have been received.

Your request, as well as any data relevant to the processing of your request, will be kept for a period of five (5) years from receipt of your request. If you have been asked for a supporting document, or if you have sent it spontaneously, it will be kept for a period of one (1) year.

If, after contacting the Data Protection Officer, and a period of one (1) month has elapsed, you believe that your GDPR rights are not respected, file a complaint with the CNIL.

Privacy & Cookie Policy

1: Definitions

2: General Information

3: Data Controllers and Data Subjects covered by this Privacy Policy

4: The processing of Personal Data by the Skeepers Group (origin of your data)

A) The processing of Personal Data carried out by Skeepers (Data Controller) on its website

1. Request a demo

2. Subscribe to the Newsletter

3. Request Support

4. Download the e-book

5. Registration for our Webinars / Events and Replay

6. Management of applications and interviews (constitution of a CV library)

7. Cookies

· What is a cookie?

Why does Skeepers use cookies?

B) The processing of Personal Data carried out by Skeepers (Data Processor) as part of its Verified Reviews, FeedBack Management, Customer Data Activation, Live Shopping and Brand Communities solutions

C) The processing of Personal Data carried out by Skeepers and its Clients (Separate Data Controllers) under its Influencer Marketing and Consumer Videos solutions

D) The processing of Personal Data by Skeepers (Data Controller) with respect to its Clients

5: “DO NOT USE MY SENSITIVE DATA” (CCPA/CPRA)

6: Social Media Data

7: Data Sharing / “DO NOT SHARE/SELL MY PERSONAL DATA” (CCPA/CPRA)

8. Duration of data retention

9. Data storage and security measures in place

10. Your rights