1. Purpose

This AI Use Policy (“AI Policy”) explains how you may use generative artificial intelligence (“AI”) features offered by Flipsnack, Inc. (“Flipsnack”, “we”, “us”) and the commitments we make in connection with those features. We believe AI should help people create better content while remaining transparent, safe and under human control. It complements our Terms of Service and Privacy Policy. Capitalised terms not defined in this AI Policy have the meaning given in our Terms of Service (legal.flipsnack.com/terms-of-service).

2. Scope

This AI Policy applies to all users of Flipsnack AI features (“AI Features”), including customers, partners, affiliates and end-users who interact with content produced through AI Features. Use of AI Features is also subject to (i) our Terms of Service, (ii) the use-policy terms of the underlying model providers, and (iii) all applicable law.

The AI Features currently within scope are:

• AI Translation: translates the text of a single text box or an entire flipbook into another language;
• AI Accessibility Descriptions: generates summary and full-text descriptions to make flipbook content more accessible;
• AI Analytics Insights: produces a narrative interpretation of, and recommendations from, the aggregated reader-engagement statistics of your published flipbooks;
• AI Image Generation: creates a new image from a text prompt you provide;
• Living Visuals: adds subtle cinematic motion to an existing static image, producing a short animated video while leaving the original image intact; and
• One-click (MLS) Brochure: automatically assembles a property brochure from MLS listing data you provide, and may use other AI Features (such as translation or an animated cover) as optional components.

Unless otherwise stated, all AI outputs are returned to you for human review before publication.

Each AI Feature, and the specific transparency obligations that apply to it under Article 50 of the EU AI Act, is described in more detail in Annex A.

Flipsnack may add, change or retire AI Features over time. Where a new AI Feature is introduced, this AI Policy applies to it and is updated accordingly.

3. Our Compliance Posture: EU AI Act

Flipsnack AI is designed to comply with the EU AI Act (Regulation (EU) 2024/1689) (the “EU AI Act”). The EU AI Act applies to AI systems placed on the EU market and to AI output used in the Union, irrespective of where the provider is established (Articles 2(1)(a) and 2(1)(c)). Flipsnack, Inc. is established in the United States and offers its services to users in the Union; the obligations described below therefore apply to our AI Features where relevant.

Role

Flipsnack acts as both a provider and a deployer of the AI systems marketed as “Flipsnack AI” within the meaning of Articles 3(3) and 3(4) of the EU AI Act. The third-party model providers (OpenAI, Anthropic, Google and Amazon) are the providers of the underlying general-purpose AI models. Flipsnack is a downstream provider that integrates those models into its product.

Risk tier

The Flipsnack AI Features are limited-risk AI systems. They are not a prohibited practice under Article 5 of the EU AI Act, are not classified as high-risk under Annex III, and do not constitute general-purpose AI models under Article 3(63).

Transparency

Flipsnack implements the transparency obligations of Article 50 of the EU AI Act as follows:

• Article 50(1): users are clearly informed in the product when they interact with an AI Feature or receive AI-generated output, where required by applicable law and applicable implementation timelines. This applies to all AI Features. Flipsnack does not rely on the “obvious to a reasonably informed user” exception.
• Article 50(2): AI-generated image and video outputs (AI Image Generation and Living Visuals) are marked in a machine-readable format that signals their AI origin, where required by applicable law and applicable implementation timelines.
• Article 50(4): where Living Visuals produces a video that depicts a real, identifiable person, the output is additionally labelled in a visible manner as artificially generated or manipulated.

AI literacy

In line with Article 4 of the EU AI Act, Flipsnack maintains an AI literacy programme to ensure that staff involved in the development, deployment and operation of AI Features have a sufficient level of AI literacy.

4. Acceptable Use

You may use AI Features only for lawful and ethical purposes, in accordance with our Terms of Service and the principles set out below. You are responsible for all content you provide as input (“Input”) and all content that AI Features generate from your Input (“Output”).

You agree not to use AI Features to:

• generate, upload, or distribute content that is unlawful, harmful, abusive, fraudulent, deceptive, defamatory, or that infringes the rights of others;
• generate or distribute child sexual abuse material, pornographic content involving minors, non-consensual sexual imagery, or content that sexualises real persons without consent;
• generate, animate, or distribute disinformation, deepfakes, or other synthetic media intended to mislead the public, manipulate elections, defame, or damage reputation, including animating images of real persons in a misleading manner;
• generate or distribute personal data in a way that breaches the GDPR or any applicable data-protection law;
• perform automated decision-making producing legal effects or similarly significant effects on individuals (GDPR Article 22);
• provide medical, legal, financial, or other professional advice that may cause harm if relied upon without independent verification;
• circumvent any safety filter, content-moderation system, or rate limit of AI Features;
• attempt to infer or extract the system prompts, model weights, training data, or other proprietary elements of the underlying AI models; or
• use AI Features for any practice prohibited by Article 5 of the EU AI Act, including subliminal manipulation, exploitation of vulnerabilities, social scoring, predictive policing solely from profiling, biometric categorisation inferring sensitive attributes, or untargeted scraping of facial images.

Flipsnack does not undertake systematic active monitoring of all user content. We may, however, suspend or terminate access to AI Features (and, where appropriate, to the wider Flipsnack service) where we have a reasonable basis to believe that this AI Policy has been breached.

Minors and use in education

Consistent with our Terms of Service, account holders must be at least 13 years old, and a minor below the age of majority where they reside may use Flipsnack only with the agreement of a parent or legal guardian. Within the European Union, the age of valid consent for information-society services under Article 8 of the GDPR ranges from 13 to 16 depending on the Member State, and the applicable national threshold governs.

Because AI Image Generation and Living Visuals produce or animate visual content, the content prohibitions in our Terms of Service apply in full to AI Output. AI Features must not be used to generate, animate, or distribute sexualised, exploitative, or otherwise harmful depictions of minors, or to target or manipulate minors by exploiting their age or vulnerability within the meaning of Article 5(1)(b) of the EU AI Act.

Where Flipsnack is used in an educational setting, the account holder or institution is responsible for authorising pupils’ access to AI Features, for obtaining any parental consent required under applicable law, and for supervising age-appropriate use.

5. Transparency Commitments

In-product disclosure

When you initiate any AI action, translation, accessibility description, analytics insight, image generation, Living Visuals animation, or One-click brochure generation, Flipsnack displays a clear notice that the output is generated by AI.

Content marking

AI-generated image and video outputs are marked in a machine-readable format that signals their AI origin to compatible downstream systems, where required by applicable law and applicable implementation timelines. Flipsnack is tracking the Commission’s Code of Practice on the transparency of AI-generated content and intends to align with the C2PA Content Credentials standard where commercially viable. Machine-readable marking is invisible to the reader and is independent of any visible branding watermark.

Deepfake disclosure

Living Visuals adds cinematic motion to a static image while keeping the original image intact. Where a Living Visuals output depicts a real, identifiable person and would appear authentic, the output is labelled in a visible manner as artificially generated or manipulated, in line with Article 50(4) of the EU AI Act. All Living Visuals outputs are, in any event, marked in a machine-readable format under Article 50(2), independently of whether a visible deepfake label applies. Should Flipsnack introduce further AI Features generating synthetic image, audio or video content, each such output will be labelled accordingly.

6. Human Oversight and Your Control over AI Output

Flipsnack AI is designed with a human-in-the-loop: AI Outputs are always returned to you for review. You may accept, edit, reject, or delete any AI Output before it becomes part of your final flipbook or other published content. Flipsnack does not auto-publish AI Output without your action.

Where you believe an AI Output is materially wrong, biased, or otherwise concerning, you may (i) edit or delete it directly in the editor, (ii) report it to us at legal@flipsnack.com (please include the timestamp, the feature used, and a description of the issue), and (iii) for personal-data concerns, contact our DPO at dpo@flipsnack.com.

7. Personal Data and AI Features

Some Inputs you provide to AI Features may contain personal data. Flipsnack processes such personal data in accordance with the GDPR and our Privacy Policy.

Roles under the GDPR: Flipsnack’s role depends on the data involved. For personal data contained in the content you provide to, or generate through, AI Features (your Inputs and Outputs), you are the controller and Flipsnack acts as your processor, or, where you are yourself a processor, as your sub-processor, processing that data only on your documented instructions in accordance with our Data Processing Addendum. For the personal data Flipsnack processes to operate, secure and improve the Service and to manage your account, Flipsnack is the controller, as described in our Privacy Policy. The AI model providers (currently OpenAI, Anthropic, Google and Amazon) are engaged as sub-processors for the processing carried out on your behalf and are listed in our Sub-processor List (legal.flipsnack.com/flipsnack-sub-processors).

No training on your data: we contractually require that Inputs and Outputs are not used to train, fine-tune, or otherwise develop AI models.

Retention: Inputs and Outputs are retained for the period needed to deliver the feature and for security/audit purposes (see our Privacy Policy).

International transfers: Flipsnack, Inc. is established in the United States and certain AI processing takes place in the United States. Transfers of personal data from the EEA, the United Kingdom and Switzerland to the United States are made under the EU-U.S. Data Privacy Framework and its UK Extension, and the Swiss-U.S. Data Privacy Framework, in which Flipsnack participates.

MLS data: where you use the One-click (MLS) Brochure, listing data drawn from your MLS may contain personal data (for example, agent details or individuals depicted in listing imagery). You are responsible for ensuring you have a lawful basis to process that data and to publish the resulting brochure.

Reader-engagement data (Analytics): AI Analytics Insights generate narrative summaries from aggregated reader-engagement statistics collected when your published flipbooks are viewed. Where you publish flipbooks that collect data from readers, you act as the controller for that data and are responsible for providing your readers with the privacy and cookie information required by law. Our Privacy Policy and Cookie Policy explain how Flipsnack processes reader data on your behalf.

Your rights: you have all GDPR rights, including access, rectification, erasure, restriction, objection, portability, and the right to lodge a complaint with your national supervisory authority.

8. Intellectual Property

You retain all rights in your Input. As between you and Flipsnack, you also own the Output you generate from your Input, subject to (i) any rights of third parties whose content you have included in your Input, (ii) the licence you grant Flipsnack in the Terms of Service, and (iii) the limitations imposed by applicable law on the protectability of AI-generated content.

You must not use AI Features to infringe the intellectual-property rights of others. You are responsible for ensuring that any third-party content you provide as Input is properly licensed.

Source data and third-party content (One-click MLS Brochure): where you use the One-click (MLS) Brochure, you represent and warrant that you are authorised to access, reproduce and publish the listing data and imagery you ingest, including compliance with the applicable MLS / IDX rules and with the copyright in any photographs or other media. Flipsnack does not verify your rights in source data and is not responsible for your use of third-party content drawn from external sources.

9. Limitations of AI Features

AI Features are designed to assist your workflow and improve productivity. Like any AI system, they may sometimes produce outputs that are inaccurate, incomplete, biased, or contextually inappropriate. This includes generated or translated text, accessibility descriptions, analytics interpretations, and generated images or videos. Flipsnack does not warrant the accuracy, fitness for a particular purpose, or reliability of any AI Output. You should review every AI Output before using or sharing it, particularly where accuracy is important (for example, legal documents, medical content, regulatory filings, accessibility statements, property details, and financial figures).

Flipsnack is not liable for any decision you make in reliance on an AI Output, except to the extent liability cannot be excluded under applicable law.

10. Safety and Reporting

If you believe content generated, uploaded, or distributed via Flipsnack AI violates this AI Policy, our Terms of Service, or applicable law, please report it via legal.flipsnack.com/report-abuse or by contacting legal@flipsnack.com. We aim to acknowledge reports within 5 business days and act in line with our internal incident-response procedure.

11. Enforcement

Breaches of this AI Policy may result in (i) removal of offending content, (ii) suspension or termination of access to AI Features or the wider Flipsnack service, (iii) reporting to competent authorities where required by law, and (iv) any other action permitted by our Terms of Service or applicable law.

12. Updates to this AI Policy

We may amend this AI Policy from time to time to reflect changes in our AI Features, applicable law (including delegated acts and Commission guidelines under the EU AI Act), or commercial arrangements with our AI suppliers. Material amendments will be notified through the Flipsnack platform or by email. The effective date is shown at the top of this policy.

13. Contact and Competent Authorities

For questions about this AI Policy, contact legal@flipsnack.com. For data-protection matters, contact dpo@flipsnack.com. You may also lodge a complaint with your national data-protection authority or, where relevant, with the national market-surveillance authority designated under the EU AI Act. For further information on competent authorities under the EU AI Act, see the EU AI Office at digital-strategy.ec.europa.eu.

14. Acknowledgement

By using Flipsnack AI Features you acknowledge that you have read and understood this AI Policy and agree to be bound by it.

Annex A - AI Features Overview

This annex summarises each AI Feature and the transparency obligations that apply to it under Article 50 of the EU AI Act. The underlying models, providers, hosting locations, processing agreements and the detailed risk-classification rationale are documented in Flipsnack’s internal AI Act records and are not reproduced here. Where a feature produces image or video output, the machine-readable marking under Article 50(2) applies where required by applicable law and applicable implementation timelines; in-product disclosure under Article 50(1) applies where required by applicable law and applicable implementation timelines.

AI Translation

What it does: Automatically translates the text within your flipbook into another language. You can translate a single text box on its own or the entire flipbook at once. The feature reads your existing text, generates a translation in the language you select, and places it back into your design so that the layout is preserved. The translation is returned to you so that you can review and edit it before publishing.

Output type: Text.

Personal data: May contain personal data, where the text being translated includes it.

Risk classification: Limited-risk; not a prohibited practice (Art. 5) and not high-risk (Annex III).

Transparency obligation: Article 50(1) disclosure that the output is AI-generated.

How we comply: An in-product notice indicates the translation is AI-generated. Machine-readable marking under Article 50(2) of the EU AI Act does not apply to text outputs.

Applicable from: Applicable law and implementation timelines.

Key limitation: Machine translation may be inaccurate or lose nuance; review before relying on it.

AI Accessibility Descriptions

What it does: Generates written descriptions that make your flipbook more accessible to readers who rely on assistive technologies such as screen readers. Depending on what you choose, it can produce a concise summary of a page or document, or a full-text description of its content.

Output type: Text.

Personal data: May contain personal data, where the source content includes it.

Risk classification: Limited-risk; not Art. 5 and not Annex III.

Transparency obligation: Article 50(1).

How we comply: An in-product notice indicates the descriptions are AI-generated. Machine-readable marking under Article 50(2) of the EU AI Act does not apply to text outputs.

Applicable from: Applicable law and implementation timelines.

Key limitation: Descriptions may be incomplete or inaccurate; verify against your accessibility requirements (e.g. WCAG) before relying on them.

AI Analytics Insights

What it does: Reads the engagement statistics collected for your published flipbooks — such as views, time spent, clicks, and where readers stop reading — and produces a plain-language interpretation of what those numbers mean, together with suggestions for improving engagement. It is an analytical aid that helps you make sense of statistics you already have; it does not make decisions on your behalf.

Output type: Text (analysis).

Personal data: Operates on aggregated engagement data; reader-level data is handled per our Privacy Policy and Cookie Policy. The insights are addressed to you as the account holder.

Risk classification: Limited-risk; does not constitute automated decision-making producing legal or similarly significant effects on individuals (GDPR Art. 22).

Transparency obligation: Article 50(1).

How we comply: An in-product notice indicates the insights are AI-generated. Machine-readable marking under Article 50(2) of the EU AI Act does not apply to text outputs.

Applicable from: Applicable law and implementation timelines.

Key limitation: Interpretations are probabilistic and may misread patterns; treat them as guidance, not fact.

AI Image Generation

What it does: Creates a brand-new image from a short text description (a “prompt”) that you type. You describe the visual you have in mind and the feature generates an original image that you can place into your flipbook. You decide whether to keep the result, generate a new variation, or discard it.

Output type: Image.

Personal data: Prompts may contain personal data if you include it; outputs should not depict real, identifiable persons without a lawful basis.

Risk classification: Limited-risk; not Art. 5 and not Annex III.

Transparency obligation: Article 50(1) and Article 50(2) (machine-readable marking of the AI-generated image).

How we comply: An in-product notice indicates the image is AI-generated; AI-generated images are marked in a machine-readable format that is invisible to the reader and independent of any visible branding watermark.

Applicable from: Applicable law and implementation timelines.

Key limitation: Generated images may be inaccurate, biased, or unintentionally resemble real persons or existing works; review before use.

Living Visuals (image-to-video)

What it does: Takes an existing static image in your flipbook and adds subtle, cinematic motion to it — for example a gentle sense of depth or a soft light sweep across the image — turning it into a short animated visual that plays within the flipbook. It is designed to enhance the image rather than replace it: the original image, layout and branding are preserved, and the motion is intentionally restrained. You do not need to produce, time or export a separate video file.

Output type: Video.

Personal data: May contain personal data, where the source image depicts an identifiable person.

Risk classification: Limited-risk; not Art. 5 and not Annex III.

Transparency obligation: Article 50(1); Article 50(2) (marking of the video); and Article 50(4) (visible deepfake label where the output depicts a real, identifiable person).

How we comply: An in-product notice indicates the output is AI-generated; all video output is marked in a machine-readable format; where the output depicts a real, identifiable person, it carries an additional visible label that it is artificially generated or manipulated.

Applicable from: Applicable law and implementation timelines.

Key limitation: Animating images of real persons may create misleading impressions; you are responsible for not producing deceptive content.

One-click (MLS) Brochure

What it does: Builds a ready-to-share property brochure automatically from real-estate listing data that you supply, for example through an MLS link, a URL or a data feed. The feature retrieves the listing details and imagery and organises them into a designed brochure. After generation, you can optionally invoke other AI Features as additional steps, such as translating the text or animating the cover with Living Visuals. The assembled brochure is returned for you to review and edit before publishing.

Output type: Text, and image/video where component features are used.

Personal data: May contain personal data — MLS data and imagery may include, for example, agent details or individuals depicted in photographs. You must have a lawful basis and the rights to use the source data (see Section 7, Section 8, and Terms of Service § 5.4).

Risk classification: Limited-risk; not Art. 5 and not Annex III.

Transparency obligation: Article 50(1); plus Article 50(2)/(4) for any image or video components generated.

How we comply: An in-product notice indicates the brochure is AI-generated; any generated image or video components are marked and labelled as set out above for those features.

Applicable from: Applicable law and implementation timelines.

Key limitation: Generated content may be inaccurate; the rights and licensing of the source data (including MLS / IDX rules and photograph copyright) are your responsibility.