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:
| Provider | Model(s) | Role | Data Location | Transfer Safeguards |
|---|---|---|---|---|
| Anthropic | Claude (Sonnet, Haiku, Opus) | Primary AI language model — intelligent analysis, content generation, decision support | US | SCCs + DPA |
| OpenAI | GPT-4o, GPT-4o-mini | Secondary AI language model — text generation, business plan processing | US | SCCs + DPA |
| Google AI | Gemini (Pro, Flash) | Tertiary AI language model — supplementary AI capabilities | US | SCCs + DPA |
| HuggingFace | Various open models | Machine learning model hosting and inference for specialized tasks | EU/US | SCCs + 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:
| Feature | Risk Level | Justification |
|---|---|---|
| Business plan generation (cNode) | Limited risk | Assistive tool; no legal effects; user retains full control |
| Strategic recommendations | Limited risk | Advisory only; requires human validation |
| Decision support and governance (cNode) | Limited risk | Supports but does not replace human decision-making |
| AI consulting analysis (Creativate AI Studio) | Limited risk | Professional advisory; reviewed by qualified consultants |
| AI knowledge sessions (AI Playbook) | Minimal risk | Educational content; user validates applicability |
| Content generation | Minimal risk | Creative assistance; user reviews all output |
| Financial projections | Limited risk | Estimates 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