Content Usage & Copyright Compliance Policy

NewsWave Effective Date: 21 March 2026 Last Updated: 21 March 2026 Version: 1.0

EU DSM Copyright Directive (2019/790/EU) Compliant | Swedish Upphovsrättslagen (1960:729) Compliant

1. Introduction and Scope

This Content Usage and Copyright Compliance Policy ("Content Policy") sets out the legal framework under which NewsWave — a sole trader business (Swedish enskild firma) operated by Sadashiv Gour ("NewsWave", "we", "us", "our") — collects, processes, and displays third-party news content through the NewsWave Service.

This Policy applies to all content ingested from:

• RSS and Atom feeds provided by publishers;
• Publicly accessible web pages from which we extract metadata or summaries;
• Licensed content partnerships where applicable;
• Open data sources and public domain content.

This Policy is designed to comply with:

• Directive (EU) 2019/790 on Copyright in the Digital Single Market (DSM Directive), as implemented in Sweden through amendments to the Swedish Copyright Act (Upphovsrättslagen 1960:729) in force from 1 January 2023;
• Swedish Upphovsrättslagen (URL, 1960:729);
• Berne Convention for the Protection of Literary and Artistic Works;
• TRIPS Agreement (WTO);
• Applicable EU and Swedish database rights law.

2. Use of RSS and Atom Feeds

2.1 Legal Basis

RSS (Really Simple Syndication) and Atom feeds are a standard mechanism by which publishers intentionally syndicate their content to aggregators and readers. By publishing a feed, a website owner signals their intent for the feed to be consumed and displayed by third-party applications.

Our legal basis for consuming RSS feeds is:

1. Express or implied licence: Publishers who make RSS feeds publicly available without access restrictions, paywalls, or robots.txt exclusions implicitly license aggregators to consume and display those feeds for the purpose of directing users to the original content;
2. Contractual licence: Where we have entered into explicit syndication agreements with publishers;
3. Right of quotation and press publication right (Article 15 DSM Directive): We display only headlines, abstracts, and hyperlinks to the original article — which is expressly permitted under Article 15 and does not require a licence fee from the publisher.

2.2 Display Limitations for RSS Content

To comply with Article 15 of the DSM Directive (the "press publishers' right"):

• We display only the title, brief excerpt (maximum ~160 characters / 2 sentences), publication date, and byline from feed items, accompanied by a hyperlink to the full original article;
• We do not display the full text of articles, even where the full text is included in the feed;
• All content is clearly attributed to its original source with a visible link to the publisher's website;
• We do not display content in a manner designed to substitute for visiting the original publication.

2.3 Publisher Opt-Out

Publishers who do not wish their RSS feeds to be aggregated by the NewsWave Service may:

1. Configure robots.txt to disallow NewsWave's user agent (NewsWaveBot/1.0);
2. Contact us at copyright@thenewswave.app to request removal;
3. Restrict feed access via authentication or feed-specific blocks.

We will honor all such requests promptly and remove the feed from our Service within 5 business days of a valid request.

3. HTML Content Extraction and Web Scraping

3.1 Overview

In addition to RSS feeds, NewsWave may extract metadata, titles, summaries, and structured information from publicly accessible web pages using automated HTTP requests and HTML parsing ("web scraping" or "web harvesting") to enrich article listings where RSS feeds are unavailable or incomplete.

⚠ LEGAL RISK FLAG — Web Scraping: Web scraping is a legally complex area under EU law. While scraping publicly accessible information is not uniformly prohibited, it may give rise to legal risk under: (i) copyright law, (ii) database rights (Directive 96/9/EC), (iii) terms of service of the scraped website, and (iv) computer misuse laws. NewsWave operates its scraping activities within a carefully defined compliance framework as set out below.

3.2 Compliance Framework for Web Scraping

NewsWave applies the following principles to all web scraping activities:

(a) Respect for robots.txt

We maintain a robots.txt compliance policy as a baseline standard:

• Before scraping any domain, our crawler checks and parses that domain's robots.txt file;
• We fully respect all Disallow directives applicable to our user agent (NewsWaveBot/1.0) and the general * wildcard;
• We respect Crawl-delay directives and implement appropriate rate limiting to avoid overloading servers;
• We do not circumvent robots.txt restrictions via spoofed user agents or indirect access methods.

Important caveat: Compliance with robots.txt is a best practice and industry standard, but robots.txt does not have direct legal force. Legal compliance is assessed separately under the frameworks below.

(b) Respect for Website Terms of Service

We review the Terms of Service (ToS) of websites we intend to scrape:

• Where a website's ToS explicitly prohibits automated access, data scraping, or harvesting, we do not scrape that website;
• Where a website is behind a login, paywall, or other access control mechanism, we do not attempt to scrape it;
• Where ToS is ambiguous, we apply the precautionary principle and either seek express permission or refrain from scraping.

(c) Minimal Extraction

We extract the minimum necessary data:

• Article title, author, publication date, URL, and a brief summary (maximum ~160 characters);
• Open Graph or structured data metadata (og:title, og:description, og:image, article:published_time) as these are specifically published by websites for this purpose;
• We do not extract full article bodies, full images, or proprietary databases.

(d) Attribution and Hyperlinking

All extracted content is:

• Attributed to the original source with the publisher's name and article URL;
• Accompanied by a direct hyperlink to the original article;
• Displayed in a manner that drives traffic to, rather than substituting for, the original publication.

(e) Copyright and Database Rights

We take the following legal positions:

• Brief factual metadata (titles, dates, authors, short descriptive summaries) generally does not qualify for copyright protection as it lacks the required originality under EU law (Case C-604/10 Football Dataco v. Yahoo);
• We do not reproduce substantial parts of any database within the meaning of Directive 96/9/EC on the Legal Protection of Databases;
• We apply the quotation exception (Article 5(3)(d) of the Copyright Directive, Article 22 Swedish URL) where displaying brief excerpts is justified for the purpose of commentary, reference, or reporting;
• We monitor the evolution of EU case law on web scraping and update our practices accordingly.

(f) Rate Limiting and Server Courtesy

Our crawler:

• Identifies itself with the user agent string NewsWaveBot/1.0 (+https://thenewswave.app/bot);
• Limits requests to a polite crawl rate (maximum 1 request per 10 seconds per domain by default);
• Scrapes during off-peak hours where feasible to minimize server load;
• Immediately ceases scraping upon receipt of HTTP 429 (Too Many Requests) or similar signals.

3.3 Ongoing Legal Risk Management

NewsWave acknowledges the following ongoing risks associated with web scraping and takes proactive steps to mitigate them:

4. Copyright Compliance Under the DSM Directive

4.1 Article 15 — Press Publishers' Right

Article 15 of the DSM Directive grants press publishers an ancillary copyright (a sui generis right) in their online press publications for a period of two years from publication.

NewsWave's compliance approach:

• We display only headlines and very short extracts (a few words to a short sentence) as expressly permitted under Article 15(1);
• We do not display full articles, paragraphs, or lengthy excerpts;
• We ensure that hyperlinks to the original publication are always provided;
• We do not use content in a manner designed to replace reading the original article;
• Where we have licensing arrangements with publishers, these supersede the minimum requirements of Article 15.

4.2 Article 17 — Upload Filters (Platform Liability)

Article 17 of the DSM Directive applies to Online Content Sharing Service Providers (OCSSPs) — platforms that store and give public access to large amounts of user-uploaded copyrighted works.

NewsWave is primarily an aggregation service that does not host user-uploaded content at scale. However, where our Service permits any user content uploads, we will:

• Implement appropriate content moderation mechanisms;
• Provide a complaint and redress mechanism for rights holders;
• Respond promptly to valid takedown requests.

4.3 Linking vs. Reproduction

5. Image Use

• We display article thumbnail images only where they are provided directly by the publisher in the RSS feed or via Open Graph metadata, indicating the publisher's intent for these images to be used in content previews;
• We do not independently scrape, copy, or store article images on our servers beyond what is strictly necessary for caching purposes;
• Cached images are stored for a maximum of 24 hours before being re-fetched from the original source;
• Where a publisher requests removal of image content, we will comply within 48 hours.

6. Notice and Takedown Procedure

NewsWave operates a Notice and Takedown (NTD) procedure compliant with the Digital Services Act (DSA) and applicable copyright law.

6.1 How to Submit a Takedown Notice

If you are a rights holder or their authorized agent and believe that content displayed through the Service infringes your copyright or other intellectual property rights, please submit a formal written notice to:

Email: copyright@thenewswave.app Subject: [COPYRIGHT NOTICE — Takedown Request] Response Time: Within 5 business days

6.2 Notice Requirements

Your notice must include:

1. Identification of the rights holder: Your full legal name, address, telephone number, and email address, and your relationship to the rights holder (if acting as agent);
2. Description of the work: A description of the copyrighted work or other protected right you claim has been infringed;
3. Identification of the infringing content: URL(s) or precise description of the content on our Service that you claim is infringing;
4. Good faith statement: A statement that you have a good faith belief that use of the material in the manner complained of is not authorized by the rights holder, its agent, or the law;
5. Accuracy statement: A statement that the information in your notice is accurate and, under penalty of perjury, that you are the rights holder or authorized to act on their behalf;
6. Signature: Your electronic or physical signature.

Notices that do not meet these requirements may not be actioned. We reserve the right to forward takedown notices to the party responsible for the content.

6.3 Counter-Notice

If you believe that content was removed in error or as a result of misidentification, you may submit a counter-notice to copyright@thenewswave.app within 10 business days of receiving notification of removal. We will review counter-notices and restore content where appropriate.

6.4 Repeat Infringers

NewsWave operates a repeat infringer policy consistent with Article 17 of the DSM Directive. Sources that are subject to multiple valid copyright infringement notices will be removed from our Service.

7. Publisher Partnership Programme

We actively encourage publishers to partner with us under formal content licensing agreements that provide:

• Agreed display parameters and excerpt lengths;
• Revenue-sharing or referral arrangements where applicable;
• Priority content placement;
• Mutual technical integrations (e.g., enhanced RSS feeds).

To enquire about a publisher partnership: Email: partnerships@thenewswave.app

8. Contact

For all copyright and content-related enquiries:

NewsWave — Sadashiv Gour (sole trader, Sweden) Email: copyright@thenewswave.app General Enquiries: legal@thenewswave.app

This Content Usage & Copyright Compliance Policy was prepared in consultation with EU copyright counsel and is intended to be consistent with the DSM Directive (2019/790/EU), Swedish Upphovsrättslagen (1960:729), and the Digital Services Act (EU 2022/2065), as of the effective date stated above.