PRIVACY POLICY

Last updated: June 2026

1. Scope

This Policy applies notably to:

• visitors to our website ;
• persons who communicate with us ;
• representatives of our clients, prospects, partners, and suppliers ;
• administrators and authorized users of client accounts ;
• persons whose personal information may be included in Client Content processed in the Service.

2. Role of Planivore and the Client

Depending on the context, Planivore may act:

• as a company or organization responsible for its own personal information, for example when managing client relationships, marketing, billing, or legal compliance ;
• as a service provider or technology subcontractor on behalf of a Client who determines the purposes and means of processing personal information stored in the Service.

When the Client uses the platform to manage its plans, projects, notes, assessments, reports, authorized user data, or any other content, the Client acts as the controller responsible for that data. Planivore processes this data on the Client’s behalf and in accordance with its instructions.

Planivore is operated by Mediavore Interactif inc., a corporation incorporated under the laws of Québec, Canada. References to “Planivore,” “we,” “our,” or “us” throughout this Policy refer to Mediavore Interactif inc. in its capacity as operator of the Planivore platform.

3. Categories of Personal Information Collected

Depending on the context, we may collect the following categories of personal information:

• identification and contact information, such as name, first name, title, organization, email address, telephone number, or any other information voluntarily provided ;
• account information, such as username, internal identifier, role, preferences, language, and notification settings ;
• transactional and billing information, such as billing address, transaction history, selected plan, and payment method (processed by our payment processor) ;
• technical and usage information, such as IP address, device type, operating system, browser, pages visited, features used, session duration, and access logs ;
• information contained in communications you send us, notably by email, form, survey, support chat, or any other channel ;
• information included in Client Content when the Client or its Authorized Users choose to enter personal information in the platform (strategic plans, objectives, actions, indicators, etc.) ;
• information related to the AI Feature when activated, including text excerpts submitted for translation, correction, rephrasing, improvement, or other writing assistance, as well as the outputs generated ;
• documents uploaded to the AI Compliance Module when activated, indexed and stored within Planivore’s secure infrastructure for the purpose of vector-search querying ;
• content of messages submitted via the online support channel (support chat or ticketing system) when communicating with Planivore’s support team — this data does not include Client Content or account-specific data.

We do not need you to communicate sensitive personal information to us, unless required by specific circumstances or applicable law.

4. Modes of Collection

We collect personal information:

• directly from you, when you fill out a form, request a demonstration, create an account, or contact us ;
• automatically, through cookies, logs, pixels, similar technologies, and analytics tools ;
• from our Clients, partners, integrators, resellers, payment providers, or subcontractors in the context of contractual relationships ;
• indirectly, when an authorized user or administrator enters information into the platform on your behalf.

5. Purposes of Use

We use personal information, as applicable, to:

• provide, operate, administer, support, and improve our services ;
• create and manage accounts, authorizations, settings, and access ;
• process orders, subscriptions, payments, renewals, and invoices ;
• respond to requests, comments, incidents, audits, support, or training needs ;
• ensure security, integrity, availability, fraud prevention, and compliance with our terms of use ;
• communicate with you about the service, updates, changes, news, and events related to Planivore ;
• produce aggregated, anonymized, or de-identified statistics, where permitted ;
• comply with our legal, regulatory, contractual, or governance obligations ;
• enable use of the AI Feature when it has been activated by the Primary Administrator.

6. AI Features and Processing by Third-Party Providers

6.1  Writing Assistance (AI Feature)

When the AI Feature is activated for a Client account, certain text excerpts voluntarily entered in compatible fields may be transmitted to a third-party artificial intelligence service provider, notably OpenAI, in order to perform the requested function (for example: translate, correct, rephrase, or improve a text).

In this context:

• we seek to limit the data transmitted to what is reasonably necessary to perform the requested function ;
• transmitted data is processed in accordance with our technical architecture and our agreements with the relevant provider ;
• generated results may be stored in the platform depending on how the user saves or uses the feature output ;
• the Client remains responsible for determining whether the use of this feature is appropriate for its context, the data entered, and the applicable legal framework.

Depending on the technical configuration, the nature of the provider used, and the applicable contractual parameters, additional restrictions may apply for the monitoring of abuse.

6.2  AI Compliance Module

The AI Compliance Module is an optional, paid module enabling the Client to upload documents (policies, regulations, reports, contracts, or others) into a dedicated environment in order to query them using natural-language requests.

In this context:

• uploaded documents are indexed and stored within Planivore’s secure infrastructure ;
• queries are processed using a vector-search (RAG) architecture hosted within Planivore’s environment ;
• uploaded documents are not transmitted in their entirety to an external third-party AI service provider ;
• the Client remains solely responsible for the content of uploaded documents and compliance with applicable third-party rights.

6.3  Online Support Channel and AI Support Assistant

Planivore provides all its clients with an online support channel (support chat or ticketing system) for submitting help requests to the support team. This channel uses an AI assistant to process requests and generate responses based on Planivore’s internal knowledge base.

In this context:

• messages submitted via the support channel may be transmitted to a third-party artificial intelligence service provider (Planivore uses Anthropic’s models for this purpose) in order to generate a contextual response based on the knowledge base ;
• the support assistant does not access Client Content, account data, documents uploaded to the platform, or personal information in the strategic plan ;
• support chat exchanges may be temporarily retained for service quality and knowledge base improvement purposes ;
• Anthropic states in its official documentation that data submitted via API is not used by default to train its models ;
• at the start of each support chat session, users receive a notification indicating that responses may be generated with the assistance of artificial intelligence.

7. Legal Basis for Processing

Where required by applicable law, we rely on one or more of the following legal bases:

• your consent ;
• the performance of a contract or pre-contractual measures ;
• compliance with a legal obligation ;
• our legitimate interests, to the extent they do not override your rights ;
• any other basis recognized by applicable law.

8. Disclosure to Third Parties

We may disclose personal information to the following categories of recipients, where necessary to provide the Service or comply with our obligations:

• hosting, infrastructure, authentication, security, analytics, and support providers ;
• payment processors and billing tools ;
• communication, messaging, CRM, marketing, or automation providers ;
• artificial intelligence service providers when the AI Feature (writing assistance) is activated or when the support channel is used ; the AI Compliance Module does not involve the transmission of full documents to such providers ;
• professional advisors, auditors, insurers, and financial institutions ;
• public authorities, regulatory bodies, or courts when required or permitted by law.

We do not sell your personal information.

9. Cookies and Similar Technologies

We use browser cookies, logs, pixels, and similar technologies in order to:

• operate the website and service ;
• remember certain preferences ;
• measure audience and usage ;
• improve performance, security, and user experience ;
• support certain communication or analytics campaigns.

You may manage certain cookies through your browser settings or, where available, via our cookie preference tool. Note that disabling certain cookies may affect the functionality of the Service.

10. Retention

We retain personal information only for as long as necessary for the purposes described in this Policy, taking into account:

• our legal, accounting, tax, regulatory, or contractual obligations ;
• security, fraud prevention, evidence, audit, continuity, or dispute resolution needs ;
• the retention settings agreed upon with our Clients.

Certain information related to billing, the contractual relationship, security, or legal obligations may be retained beyond the termination of the Service subscription, in accordance with applicable law.

11. Hosting, Transfers, and Cross-Border Access

The primary environment for our service and client data is organized to prioritize hosting within Canada (Québec), or within the European Union for clients who have opted for this configuration.

For clients located in the United States or within the European Union, Planivore also offers infrastructure configurations adapted to their applicable regulatory requirements.

Where such cross-border transfers or access are necessary, we seek to implement appropriate measures to ensure an equivalent level of protection, in particular through contractual clauses or specific agreements with our subcontractors.

For transfers to countries not providing an adequate level of protection recognized by the applicable authorities, we rely on standard contractual clauses or other appropriate transfer mechanisms recognized by law.

12. Security

We implement administrative, organizational, contractual, physical, and technical security measures designed to protect personal information against unauthorized access, use, disclosure, modification, or destruction.

No security measure, however, offers an absolute guarantee. In the event of a confidentiality incident, we undertake to:

• notify the incident to the competent supervisory authority within the required timeframes (no later than 72 hours after becoming aware of it, where applicable) ;
• notify affected persons when required by law and where the risk is high ;
• document the incident in accordance with our legal and regulatory obligations.

13. Your Rights

Subject to applicable law and permitted exceptions, you may request:

• access to your personal information ;
• correction of inaccurate or incomplete information ;
• withdrawal of your consent where processing is based on consent ;
• deletion or anonymization of certain information ;
• portability, where such a right exists ;
• restriction of or objection to certain processing ;
• not to be subject to a decision based solely on automated processing that has legal or similarly significant effects.

For information contained in a client account administered by an organization, we may need to redirect your request to the relevant Client, as the data controller.

14. Information About Third Parties and Minors

The Client and Authorized Users must only enter into the platform information about third parties or their own staff for which they hold the required legal basis, whether consent, a contractual or legal obligation, or a legitimate interest. The Service is not intended for persons under the age of majority, and Planivore does not knowingly collect personal information from minors.

15. Changes

We may modify this Policy from time to time to reflect changes in our practices, applicable laws, or the evolution of our services. In the case of material changes, we will notify you by email or via a prominent notice within the Service at least 30 days before the changes take effect. We encourage you to periodically review this Policy. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy.

16. Contact and Privacy Officer

For any question, request, or complaint regarding this Policy or the protection of your personal information, you may contact us using the following coordinates:

Company	Planivore (operated by Mediavore Interactif inc.)
Privacy Officer	Alexandre Jalbert
General email	info@planivore.app
Privacy email	privacy@planivore.app
Phone	+1 514-248-2228
Website	https://planivore.app/

17. Provisions for Persons Located in the European Union (GDPR)

Where the General Data Protection Regulation (GDPR) of the European Union applies to the processing, the following additional provisions apply.

17.1 Data Controller and Processor

Depending on the context, Planivore acts as data controller (for its own commercial activities) or data processor (when processing data on behalf of a Client). In the latter case, the processing is governed by a data processing agreement (DPA) in accordance with Article 28 of the GDPR.

17.2 Additional Rights Under the GDPR

In addition to the rights set out in section 13, persons whose data is processed under the GDPR also have the right to:

• lodge a complaint with the competent supervisory authority in their country ;
• object to processing based on legitimate interests ;
• not be subject to fully automated decision-making that significantly affects them, including profiling.

17.3 Data Protection Impact Assessment (DPIA)

Where a feature likely to create a high risk for the rights and freedoms of individuals is deployed, Planivore will conduct or assist the Client in conducting a Data Protection Impact Assessment (DPIA), in accordance with Article 35 of the GDPR.

18. Provisions for US Residents

Depending on your state of residence, local privacy laws may apply to you, including the California Consumer Privacy Act (CCPA) as amended by the CPRA, or equivalent state laws.

18.1 Categories of Personal Information Collected

In accordance with applicable laws, Planivore may collect the following categories of personal information: identifiers (name, email, IP address), commercial information (subscription history, billing), internet or electronic network activity information (access logs, features used), professional or employment-related information (organization, role), and inferences drawn from the above.

18.2 Rights of US Residents

Depending on the law applicable to your state of residence, you may have the following rights:

• right to know what categories of personal information have been collected and for what purposes ;
• right of access and to a copy of your personal information ;
• right to correction ;
• right to deletion, subject to legal exceptions ;
• right to portability in a structured, readable format ;
• right to object to profiling for targeted advertising purposes ;
• right not to be discriminated against for exercising these rights.

18.3 Sale and Sharing of Information

Planivore does not sell your personal information and does not share it for cross-context behavioral advertising purposes.

18.4 Children (COPPA)

Our service is not intended for children under 13 years of age, and we do not knowingly collect personal information from children without parental consent.