AI Policy

This AI Policy explains how CampaignsLive.com (operated by North Fjord LLC) designs, deploys, and governs the artificial-intelligence features of the Service. It is a companion document to our Privacy Policy, Terms of Service (including the Business Customer Addendum in Schedule A), and Subprocessors page. In case of conflict, the Terms of Service control.

This Policy is written with the EU Artificial Intelligence Act (Regulation (EU) 2024/1689, the "AI Act") in mind, alongside applicable US and UK frameworks. Our customers are primarily based in the European Union, the United Kingdom, and the United States.

The Service is offered to business customers only — companies, agencies, organisations, and other legal entities acting in the course of a commercial or professional activity. It is not offered to, marketed to, or available for consumers. EU and UK consumer-protection rights (including the consumer right of withdrawal under Directive 2011/83/EU and consumer-jurisdiction carve-outs) and similar consumer-only protections do not apply to your use of the Service. References in this Policy to "you" mean the business customer.

1. Our Role Under the AI Act

CampaignsLive.com is an AI system that we develop and place on the market under our own brand. With respect to the AI features of the Service, we are a "provider" of an AI system within the meaning of Article 3(3) of the AI Act. We are not a provider of general-purpose AI models; we integrate GPAI models supplied by third parties (see Section 3 and our Subprocessors page).

When a customer uses the Service in the course of their business — for example, to produce a campaign, image, video, or written asset that they then publish — that customer acts as a "deployer" under Article 3(4) of the AI Act and assumes the deployer obligations described in Section 11.

2. Risk Classification

We have assessed the Service against Articles 6 and 7 and Annex III of the AI Act. The Service is not a high-risk AI system. It is not used as a safety component of a regulated product, and it does not fall within any of the Annex III high-risk categories (biometric identification, critical infrastructure, education, employment, access to essential services, law enforcement, migration and border control, or administration of justice and democratic processes).

The Service is subject to the transparency obligations of Article 50 of the AI Act because it generates synthetic image, audio, video, and text content. Those obligations are described in Section 4.

The Service does not implement any of the practices prohibited by Article 5 of the AI Act (manipulative or exploitative AI causing significant harm; social scoring; untargeted scraping of facial images; emotion recognition in workplaces or educational institutions; biometric categorization based on special-category attributes; real-time remote biometric identification in public spaces by law-enforcement authorities; or predictive policing based solely on profiling). Customer use of the Service for any such purpose is prohibited under Section 5 of our Terms of Service and Section 5 of this Policy.

3. AI Components We Use

The Service integrates third-party GPAI models and AI services for the following purposes:

The authoritative, current list of all third-party processors is on the Subprocessors page. We may add, remove, or substitute upstream providers; we give business customers at least 30 days' notice of changes that affect processing of their Personal Data.

AI Outputs are produced by these upstream models. We integrate them but do not own, operate, train, or control them. The technical behaviour, content policies, training data, model weights, accuracy, biases, output distribution, safety filters, and version changes of upstream models are determined by their respective providers, not by us. To the maximum extent permitted by applicable law, we disclaim all liability for the behaviour, availability, lawfulness, accuracy, originality, or non-infringement of upstream models or the Outputs they produce. Any claim relating to an upstream model or its Outputs is, where legally possible, a matter between you and the relevant upstream provider under that provider's own terms. The disclaimers in Section 12 and the liability cap in Section 13 of our Terms of Service apply in full.

4. Transparency & Labelling (Article 50)

4.1 You always know when AI is involved

Every mini-app that uses AI is labelled as such in the user interface, and every output produced by an AI model is presented as AI-generated. The Service is, by design, an AI product; we do not present AI Outputs as if they were produced by a human.

4.2 Machine-readable markings on synthetic content

Where an upstream model supplies machine-readable provenance signals — for example, C2PA metadata or invisible watermarks on images or video — we will not actively strip those signals from the assets we deliver. Where an upstream model does not supply such signals, the asset will be delivered without machine-readable provenance metadata. We make no representation that any particular Output will contain provenance metadata and we make no commitment to add, generate, or backfill such metadata ourselves. Any visible labelling, watermark, or written disclosure required on a published asset is the responsibility of the deployer (see Section 4.3).

4.3 Deepfakes and public-interest text

Under Article 50(4) of the AI Act, a deployer who publishes AI-generated content that constitutes a "deepfake" must disclose that the content is artificially generated, and a deployer who publishes AI-generated text intended to inform the public on matters of public interest must disclose the same. When you use the Service to produce such content for publication, that disclosure obligation falls on you as the deployer. We recommend keeping the AI-generated provenance metadata intact and adding a visible disclosure ("AI-generated", "Generated with AI", or equivalent) on the published asset itself.

5. Prohibited and Restricted Uses

In addition to the prohibitions in Section 5 of our Terms of Service, you must not use the Service to:

• Deploy any AI practice prohibited by Article 5 of the AI Act, including subliminal, manipulative, or deceptive techniques causing significant harm; exploitation of vulnerabilities based on age, disability, or socio-economic situation; social scoring of natural persons; emotion inference in workplaces or educational institutions; biometric categorisation inferring special-category attributes; or real-time remote biometric identification.
• Generate content depicting an identifiable real person without that person's documented consent or another lawful basis (this includes deepfakes, voice clones, and face-swap outputs).
• Create AI-generated content designed to be passed off as human-generated where doing so would mislead the audience (academic submissions, regulated disclosures, news-style content without disclosure, fake reviews or testimonials).
• Use Outputs to produce illegal hate speech, harassment, or content that sexualises minors.
• Use the Service to make decisions producing legal or similarly significant effects on individuals (employment, credit, insurance, housing, education, public benefits, law enforcement, immigration, or access to essential services) without independent human review — the Service is not designed or validated for these use cases.
• Submit special-category Personal Data (Article 9 GDPR — racial or ethnic origin, political opinions, religion, trade-union membership, genetic or biometric data, health data, sex life or sexual orientation) into prompts or assets without a documented lawful basis and prior written agreement with us.
• Use the Service in a domain that classifies it as high-risk under Annex III of the AI Act (e.g. employment, education, essential services, law enforcement) without prior written agreement with us, since we have not validated the Service for those domains.

We may block, suspend, or terminate access for any actual or suspected violation and may report serious violations to competent authorities.

6. Training, Retention & Customer Data

• We do not train our own AI models on your prompts, files, or AI Outputs.
• Where an upstream provider offers a "do not train" or "zero retention" option, we make commercially reasonable efforts to use it. Provider settings, defaults, and capabilities evolve over time; we cannot guarantee uniform behaviour across all providers.
• Upstream providers may temporarily retain inputs and outputs for safety, abuse-prevention, and operational reasons under their own terms.
• Within our systems, we retain prompts, AI Outputs, and call-level metadata (model, provider, token counts, status, latency, cost) as described in Sections 3, 6, and 10 of our Privacy Policy.

7. Human Oversight

The Service is designed to keep a human in the loop: you submit a task, you review the Output, and you decide whether and how to use it. We do not make decisions producing legal or similarly significant effects on you or anyone else based solely on automated processing (see Section 15 of our Privacy Policy and Section 8.4 of our Terms of Service).

You are responsible for the human review, fact-checking, rights clearance, and editorial judgement applied to AI Outputs before any external use.

8. Accuracy, Bias & Limitations

AI Outputs are produced by probabilistic third-party models trained on large datasets. They may be inaccurate, incomplete, out-of-date, biased, culturally insensitive, or offensive; they may fabricate facts, names, citations, prices, or attributes; and they may resemble or reproduce third-party works. Different users may receive similar or identical Outputs from similar prompts.

AI Outputs are provided "as is" and "as available". To the maximum extent permitted by applicable law, we disclaim all express and implied warranties about AI Outputs, including warranties of accuracy, completeness, originality, non-infringement, title, merchantability, satisfactory quality, and fitness for any particular purpose. You are solely responsible for reviewing AI Outputs, verifying facts, clearing third-party rights (including image, likeness, trademark, and copyright), applying editorial judgement, and deciding whether and how any Output is fit for any intended commercial, regulated, or public use. The disclaimers in Section 12 and the liability cap in Section 13 of our Terms of Service apply in full to AI Outputs.

We may, at our sole discretion, adjust prompts, providers, or safeguards from time to time, but we do not pre-screen Outputs and we are not obliged to review, remove, modify, or remedy any particular Output. If you encounter Outputs you consider biased, harmful, or systematically wrong, you may report them under Section 10; we may, but are not required to, act on the report.

9. AI Literacy (Article 4)

Article 4 of the AI Act, in force since 2 February 2025, requires providers and deployers of AI systems to take measures to ensure a sufficient level of AI literacy among staff and others operating the system on their behalf.

On our side, we maintain internal documentation on how each mini-app uses AI, what the known limitations are, and how Outputs should be reviewed. On your side, if you operate the Service inside a team or organisation, we recommend briefing your staff on (a) which features are AI-driven, (b) the disclosure obligations in Section 4.3, and (c) the prohibited uses in Section 5. We are happy to share customer-facing training materials on request.

10. Incident Reporting

If you believe an AI Output produced by the Service is unlawful, biased, harmful, or misused, or if you encounter behaviour you suspect may violate the AI Act or another applicable law, contact us at northfjordllc@gmail.com with the subject line "AI Incident". Please include the relevant request or asset ID, a short description, and any supporting screenshots.

We will use reasonable efforts to acknowledge AI-incident reports within 30 days of receipt. Acknowledgement is not an admission of fault, agreement that an incident occurred, or any commitment to investigate, refund, remedy, modify the Service, or take any other action; we may, at our sole discretion, decline to act on a report. Where notification of a competent authority or affected natural person is required by mandatory law, we will make that notification within the timeframe the applicable law requires.

11. Customer Responsibilities as a Deployer

You access the Service as a business customer and as a deployer under Article 3(4) of the AI Act. You are solely responsible for your use of the Service and for the AI Outputs you generate, store, distribute, publish, or otherwise rely on, including for compliance with all laws applicable to that use in every jurisdiction in which you operate or publish. Without limiting the generality of the foregoing, your responsibilities include:

• Using the Service in line with our Terms of Service, this AI Policy, the instructions surfaced inside each mini-app, and the terms of the relevant upstream AI providers.
• Ensuring you have a lawful basis (consent, licence, or other) for any Personal Data, likeness, brand, trademark, or copyrighted work you submit as part of a prompt or reference asset.
• Reviewing AI Outputs before any external use, fact-checking them, clearing third-party rights, and adding any visible disclosure, watermark, or labelling required by Article 50 of the AI Act or other applicable law (Section 4.3 above).
• Maintaining AI literacy across the team operating the Service on your behalf (Section 9).
• Not using the Service for any prohibited or restricted purpose (Section 5).
• Performing your own fitness-for-purpose, accuracy, and risk assessment before relying on an AI Output for any commercial, regulated, or public-facing use.
• Cooperating with reasonable requests we make to investigate suspected misuse.

You agree to defend, indemnify, and hold harmless North Fjord LLC and its officers, directors, employees, and agents from and against any claims, damages, losses, liabilities, and expenses (including reasonable attorneys' fees) arising out of or relating to (a) your breach of this AI Policy, (b) your use of the Service or any AI Output, (c) your failure to comply with any Article 50 or other AI-disclosure, labelling, or transparency obligation applicable to you as a deployer, or (d) any third-party claim that an AI Output you used, modified, or distributed infringes a third-party right or violates applicable law. This is in addition to, and does not replace, the indemnity in Section 14 of our Terms of Service.

12. Children

The Service is intended for users aged 18 or older. We do not knowingly direct the Service to minors, and you must not use the Service to target minors in a way restricted by applicable law (including COPPA in the United States and the GDPR in the EEA / UK).

13. Relationship to Other Policies

This AI Policy supplements but does not replace our Privacy Policy (data protection, including the AI-processing details in Section 6), Terms of Service (acceptable use in Section 5, Outputs and IP in Section 8, Schedule A Data Processing Agreement for business customers), and Subprocessors page. In the event of conflict, the Terms of Service govern.

14. Changes to this Policy

We may update this AI Policy from time to time, in particular as the AI Act and related guidance evolve. For material changes, we will give at least 30 days' notice by email or in-product notice. The "Last updated" date at the top of this page reflects the most recent revision.