Legal

AI transparency.AI Transparency Notice

Last updated: 13 March 2026 · v2.0.0

Introduction

Creativate Technologies GmbH ("Creativate") is committed to the responsible and transparent use of artificial intelligence (AI) across all its products and services. This AI Transparency Notice provides information about how we use AI, which providers we work with, and how we ensure compliance with the EU Artificial Intelligence Act (AI Act) and the General Data Protection Regulation (GDPR).

This notice applies to all Creativate products: cNode, AI Playbook, and Creativate AI Studio.

Data Controller

Creativate Technologies GmbH Lahnstraße 65, 60326 Frankfurt am Main, Germany Email: privacy@creativate.tech

AI Systems and Providers

Creativate integrates multiple AI systems into its platform. The following table provides an overview of the AI providers, their role, and data handling:

ProviderModel(s)RoleData LocationTransfer Safeguards
AnthropicClaude (Sonnet, Haiku, Opus)Primary AI language model — intelligent analysis, content generation, decision supportUSSCCs + DPA
OpenAIGPT-4o, GPT-4o-miniSecondary AI language model — text generation, business plan processingUSSCCs + DPA
Google AIGemini (Pro, Flash)Tertiary AI language model — supplementary AI capabilitiesUSSCCs + DPA
HuggingFaceVarious open modelsMachine learning model hosting and inference for specialized tasksEU/USSCCs + DPA

Important: None of these providers use your data to train their AI models. All interactions are API-based and subject to our Data Processing Agreements.

AI Risk Classification

Under the EU AI Act, AI systems are classified by risk level. Creativate's AI features are classified as follows:

FeatureRisk LevelJustification
Business plan generation (cNode)Limited riskAssistive tool; no legal effects; user retains full control
Strategic recommendationsLimited riskAdvisory only; requires human validation
Decision support and governance (cNode)Limited riskSupports but does not replace human decision-making
AI consulting analysis (Creativate AI Studio)Limited riskProfessional advisory; reviewed by qualified consultants
AI knowledge sessions (AI Playbook)Minimal riskEducational content; user validates applicability
Content generationMinimal riskCreative assistance; user reviews all output
Financial projectionsLimited riskEstimates only; explicitly labeled as AI-generated

No Creativate AI features currently qualify as high-risk under Annex III of the AI Act. Should our risk classification change, we will update this notice and implement additional safeguards accordingly.

Transparency Obligations (AI Act Article 50)

In accordance with Article 50 of the EU AI Act, we ensure that:

  • Users are clearly informed when they are interacting with an AI system
  • AI-generated content is clearly labeled or identifiable as such
  • Users understand the general capabilities and limitations of the AI features
  • Information about the logic of AI systems is available upon request

Human Oversight

Creativate implements meaningful human oversight in all AI-driven processes:

  • All AI outputs are presented as suggestions or recommendations, not final decisions
  • Users maintain full control over whether to accept, modify, or reject AI outputs
  • Critical business decisions require explicit user confirmation
  • AI systems do not autonomously execute actions with legal or financial effects

Fairness and Bias Mitigation

We actively work to ensure fairness in our AI systems:

  • Regular monitoring for bias in AI outputs across different user groups
  • Use of diverse and representative training data where applicable
  • Periodic audits of AI model performance and fairness metrics
  • Clear channels for users to report suspected bias or unfair outcomes

Explainability

Creativate provides explanations of AI-driven outputs where feasible:

  • AI-generated content includes information about the sources or reasoning behind recommendations
  • Users can request detailed explanations of how specific AI outputs were generated
  • Technical documentation of AI system behavior is maintained internally and available to regulators upon request

Data Processing for AI

When you interact with our AI features:

  • Input data (your prompts, business content, context) is sent to the relevant AI provider via encrypted API calls
  • Output data (AI-generated responses) is returned and stored on our infrastructure
  • Interaction logs (metadata about AI usage) are retained for up to 24 months for quality assurance and compliance
  • No personal data is used for AI model training without explicit consent and anonymization

For complete details on data processing, see our Privacy Policy.

Your Rights Regarding AI Processing

Under the GDPR and the AI Act, you have the right to:

  • Be informed when interacting with an AI system
  • Receive explanations of the logic and general functioning of AI features
  • Object to AI-based processing in certain circumstances
  • Request human review of AI-assisted decisions that significantly affect you
  • Contest AI-generated outcomes and request human intervention
  • Opt out of AI processing where non-essential and not required for service delivery

To exercise these rights, contact: privacy@creativate.tech

AI Governance and Ethics

Creativate's approach to AI governance is guided by:

  • The EU AI Act and its implementing regulations
  • The GDPR and its principles of data protection by design
  • The EU Ethics Guidelines for Trustworthy AI
  • ISO/IEC standards for AI governance and risk management
  • Internal AI ethics review processes

Incident Reporting

If you experience or suspect an AI-related incident (unexpected behavior, potential bias, data protection concern), please report it to:

Email: privacy@creativate.tech

We investigate all reported AI incidents and take corrective action as appropriate.

Updates to This Notice

We may update this AI Transparency Notice as our AI capabilities evolve or as regulatory requirements change. Material changes will be communicated through our platform or by email.


Effective Date: February 2026 Creativate Technologies GmbH

Additional information on Zulano

Zulano (www.zulano.io and its subdomains) is a service of Creativate Technologies GmbH. The text above applies; this section describes what is specific to Zulano.

Zulano uses AI for the following functions. Your input is sent to the provider named in each case and processed there to generate the response.

FunctionProviderModel (current)Location
Chat “Try it for free” on www.zulano.io/app (processed via app.zulano.io)Groq, Inc.; if unavailable OpenRouter, Inc.gpt-oss-120b (Groq); Qwen 2.5 72B / 7B (OpenRouter)US
Application assistants: chat, field suggestions, help with filling in, reading uploaded documents, ZFU checkGroq, Inc.; if unavailable OpenRouter, Inc.as aboveUS
Application assistants: generating drafts, filling gaps, quality check, assistant commands, analysing a web address you provideGoogle LLCGemini 2.0 FlashUS

gpt-oss-120b is an openly available model that runs at Groq; your input is not sent to OpenAI. Anthropic, OpenAI and HuggingFace, which are listed above, are currently not used for Zulano.

The statement above that none of these providers uses your data to train its AI models refers to the providers listed in the table there (Anthropic, OpenAI, Google AI, HuggingFace). For Groq and OpenRouter, whether data is used for training depends on the settings of the respective account.

Chat on /app: to enforce the free allowance of five questions per 24 hours, a random ID from your browser and your IP address are counted on our servers (Amazon DynamoDB, Frankfurt am Main); the counters expire after the 24-hour window plus one hour and are then deleted automatically.

Please do not enter personal data in the chat. Responses from the AI are suggestions. They do not replace legal or tax advice; check them before you use them in an application.