Artificial Intelligence Disclosure and Disclaimer Policy

1. Introduction and Scope

This Artificial Intelligence Disclosure and Disclaimer Policy (“Policy”) is published by Ainoa Brands Ltd (“Ainoa”, “we”, “us”, or “our”), a company incorporated in England and Wales under Company No. 14070598, with its principal place of business in Newcastle upon Tyne, United Kingdom.

Ainoa might use artificial intelligence (“AI”) tools and technologies in the creation, drafting, research, editing, and production of content across its website and all other content and marketing channels. This Policy is intended to provide full transparency about how AI is used at Ainoa, across all publishing and communications contexts, and to satisfy applicable disclosure, transparency, and consumer protection obligations across the jurisdictions in which Ainoa operates and publishes content.

This Policy applies to:

• The Ainoa website and all associated web pages, subdomains, and digital content at www.ainoa.agency

• All social media channels operated by or on behalf of Ainoa, including but not limited to LinkedIn, Instagram, TikTok, Facebook, Threads, Pinterest, YouTube, and any other platforms on which Ainoa publishes content

• All email marketing, newsletters, and direct digital communications sent by or on behalf of Ainoa

• All paid advertising and sponsored content produced and distributed by or on behalf of Ainoa, across any channel or medium

• All direct mail, print, and physical marketing materials produced by or on behalf of Ainoa

• All blog articles, thought leadership pieces, case studies, and editorial content published under the Ainoa or Salla Västilä name

• Any other content published, distributed, or communicated publicly by Ainoa or its representatives

By accessing this website or engaging with any Ainoa content, you acknowledge that you have read and understood this Policy.

2. Definitions

For the purposes of this Policy, the following terms have the meanings given below:

• “AI” or “Artificial Intelligence” means computational systems that perform tasks that typically require human intelligence, including but not limited to understanding language, generating text, creating images, summarising information, and conducting research.

• “AI-Generated Content” means any content, in whole or in part, that has been created, drafted, researched, edited, translated, summarised, or otherwise produced or materially assisted by AI Tools, whether or not it has subsequently been reviewed or modified by a human.

• “AI Tools” means artificial intelligence applications, platforms, large language models (LLMs), generative AI systems, machine learning tools, and any AI-powered features embedded in software platforms used by Ainoa in its operations.

• “Published Content” means all text, images, graphics, infographics, video, audio, social media posts, blog articles, email campaigns, advertisements, direct mail, case studies, marketing materials, templates, guides, and any other material published, broadcast, or distributed by Ainoa through any channel or medium.

• “Client Deliverables” means any documents, strategies, reports, designs, frameworks, presentations, or other materials produced by Ainoa for or on behalf of clients in the course of professional engagement.

• “Human Review” means the process by which at least one member of the Ainoa team reads, assesses, edits, and approves content before publication or delivery, with Ainoa holding editorial responsibility for the final output.

• “Deepfake” has the meaning given to it in Regulation (EU) 2024/1689 (the EU AI Act): AI-generated or AI-manipulated image, audio, or video content that depicts persons, objects, places, or events in a way that falsely appears authentic.

• “Deployer” means, for the purposes of EU AI Act obligations, a legal or natural person who uses an AI system within the scope of their professional activities, which Ainoa is in relation to AI Tools it uses but does not develop.

3. AI Tools Used by Ainoa

Ainoa uses a range of AI Tools in its operations. These include, but are not limited to:

• Claude (Anthropic) — used for content drafting, research support, strategic thinking, and internal operations. Claude (among with other LLMs) also forms the foundation of Aino, Ainoa’s internal AI system. Anthropic’s privacy policy and terms of service apply: www.anthropic.com

• Gemini (Google DeepMind) — used for research support, content drafting, and image generation. Google’s privacy policy applies: policies.google.com

• Canva AI — used for design assistance, image generation, and AI-powered visual content features. Canva’s terms apply: www.canva.com

• Perplexity — used for web-connected research and information synthesis. Perplexity’s privacy policy applies: www.perplexity.ai

• AI-powered features embedded in Google Workspace, Squarespace, Adobe and any other platforms and similar tools used in Ainoa’s operations

This list reflects current usage at the time of the last review date shown on this Policy. Ainoa reserves the right to introduce, change, or discontinue use of any AI Tool at any time and will update this Policy at each review date to reflect material changes. The absence of a tool from this list does not imply that no AI features are embedded in the platforms or workflows that Ainoa uses.

4. Scope of AI Use in Published Content

AI-Generated Content may be present, in whole or in part, across any Ainoa Published Content. Content types in which AI assistance may be involved include, but are not limited to:

4.1 Website and Digital Content

• Website pages, including homepage copy, service pages, about pages, and policy pages

• Blog articles and thought leadership content

• SEO metadata, page descriptions, and search-optimised content

• Infographics, data visualisations, and image descriptions

• Website imagery and visual assets, where AI generation tools are used

4.2 Social Media

• Posts, captions, threads, and stories on all social media platforms operated by Ainoa or any team member of Ainoa

• Images and visual assets published on social media, where AI generation tools are used

• Video scripts and short-form video content

• Comment responses and community management communications, where AI is used to draft initial responses for human review

4.3 Email and Direct Marketing

• Email newsletters and marketing campaigns

• Automated email sequences and follow-up communications

• Direct mail copy, where AI is used in drafting

4.4 Paid Advertising

• Ad copy and creative briefs for paid digital advertising across all platforms

• Display ad copy and promotional materials

• Sponsored content and paid partnerships, where AI is used in content creation

4.5 Client-Facing and Professional Content

• Proposals, strategy documents, and briefing notes

• Research summaries and information synthesis outputs

• Brand strategy frameworks and positioning documents

• Case studies and client testimonial summaries

4.6 Internal and Operational Content

• Templates, operational documents, and internal frameworks

• Training materials and internal guides

The level of AI involvement varies across content types. Not all content in the above categories is AI-generated or AI-assisted; the list describes categories in which AI may be used, not categories in which AI is always used.

5. Human Oversight and Editorial Responsibility

Ainoa maintains consistent human oversight over all AI-assisted content. The following applies to all Published Content produced by Ainoa:

• All content published under the Ainoa or any team member of Ainoa name has been reviewed, edited, and approved by at least one member of the Ainoa team prior to publication.

• Ainoa Brands Ltd holds editorial responsibility for all Published Content. AI Tools are used to assist in the production of content; Ainoa does not transfer editorial control or responsibility to any AI Tool or third-party AI provider.

• AI-Generated Content is used as a drafting, research, or creative support tool. Final editorial decisions — including decisions about accuracy, appropriateness, tone, and publication — are made by human team members.

• The strategic thinking, consumer psychology analysis, brand positioning frameworks, and professional recommendations published by Ainoa are the product of human expertise and professional experience. AI Tools may assist in the articulation, structuring, or drafting of such content; they do not generate the underlying strategic or psychological thinking.

• Ainoa does not publish content solely on the basis of AI output, without human review and editorial approval, as a matter of standard operating practice.

Human review does not guarantee that AI-assisted content is free from inaccuracy, error, bias, or omission. Please see Section 7 for accuracy and reliability disclaimers.

For the purposes of compliance with applicable legislation including Article 50 of Regulation (EU) 2024/1689 (the EU AI Act): Ainoa asserts that all Published Content has undergone a process of human editorial review, and that Ainoa Brands Ltd holds editorial responsibility for such content. This reflects Ainoa’s standard operating practice and is not a jurisdiction-specific claim.

6. Regulatory Compliance: Jurisdiction-Specific Provisions

Ainoa’s content is published and distributed globally. This section sets out the regulatory frameworks that apply or are anticipated to apply to Ainoa’s AI disclosure obligations across key jurisdictions. Ainoa monitors developments in applicable law and updates this Policy accordingly. This Policy does not constitute legal advice.

6.1 European Union — EU AI Act (Regulation (EU) 2024/1689)

The EU AI Act (Regulation (EU) 2024/1689), which entered into force on 1 August 2024, is the world’s first comprehensive legal framework for artificial intelligence. Article 50 transparency obligations apply from 2 August 2026.

Ainoa operates as a Deployer of AI Tools for the purposes of the EU AI Act. Ainoa does not develop or place AI systems on the market; it uses AI systems developed by third parties (Anthropic, Google DeepMind, Canva, and others) within its professional operations.

Under Article 50 of the EU AI Act, the following obligations apply to Deployers in relation to content accessible to individuals in the EU:

• Deepfake disclosure: Any AI-generated or AI-manipulated image, audio, or video content constituting a deepfake (i.e. content that falsely appears to depict real persons, objects, places, or events) must be disclosed as artificially generated or manipulated. This obligation applies to Ainoa’s published visual and audio content where applicable. Ainoa will label such content clearly at the point of first exposure in accordance with this obligation.

• AI-generated text on matters of public interest: The obligation to disclose AI-generated text published for the purpose of informing the public on matters of public interest does not apply where such content has undergone a process of human review and where a natural or legal person holds editorial responsibility for the publication. Ainoa asserts, as its standard operating practice, that all Published Content undergoes human editorial review and that Ainoa Brands Ltd holds editorial responsibility for all published material. Ainoa therefore relies on this exception in relation to text content.

• Machine-readable marking: To the extent technically feasible and required, Ainoa supports and will implement machine-readable marking of AI-generated content in line with applicable guidance from the EU AI Office and relevant industry standards (including the C2PA Content Credentials standard where available and proportionate to Ainoa’s content production).

This Policy will be updated to reflect final guidelines from the European Commission and any Code of Practice adopted under Article 50 prior to the August 2026 compliance deadline.

6.2 United Kingdom

As of the date of this Policy, the United Kingdom has no standalone AI legislation in force. AI regulation in the UK is conducted through a principles-based framework applied by existing sector-specific regulators. The following UK regulatory frameworks apply to Ainoa’s AI use:

• UK GDPR and the Data Protection Act 2018: Where AI Tools process personal data, the UK GDPR and Data Protection Act 2018 apply. Ainoa’s use of AI Tools is subject to its Privacy Policy and Data Protection commitments, which are maintained separately from this AI Policy.

• Data (Use and Access) Act 2025 (Royal Assent 19 June 2025): The provisions of this Act, including updated automated decision-making rules under Articles 22A–22D (effective February 2026), apply to Ainoa’s use of AI in any context involving significant automated decisions affecting individuals.

• Advertising Standards Authority (ASA) and Committee of Advertising Practice (CAP): The CAP and BCAP Codes apply to all advertising content produced by Ainoa, regardless of how that content was created or modified. CAP confirmed in May 2025 that there is no blanket requirement under UK advertising law to disclose the use of AI in advertising. However, Ainoa is required to ensure that any AI-assisted advertising content does not materially mislead consumers. Disclosure of AI use will be made in advertising contexts where the absence of such disclosure could constitute a misleading impression.

• Competition and Markets Authority (CMA): The CMA’s consumer protection powers, extended under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act, in force April 2025), apply to any misleading practices in Ainoa’s commercial communications, including AI-related misrepresentation.

• Information Commissioner’s Office (ICO): The ICO’s guidance on AI and data use applies to Ainoa’s processing of personal data through AI Tools. Ainoa does not input client personal data into AI Tools without prior disclosure and, where required, consent.

• EU AI Act (extraterritorial application): UK businesses are within scope of the EU AI Act where their AI content or systems are accessible to individuals in the EU, or where their outputs are used within the EU. Ainoa’s website and social media content is accessible in the EU. The EU AI Act obligations described in Section 6.1 above therefore apply to Ainoa in addition to UK-specific requirements.

6.3 United States

The United States has no dedicated federal AI law in force at the date of this Policy. The following US regulatory frameworks apply or are anticipated to apply to Ainoa’s AI use in relation to US audiences:

• Federal Trade Commission (FTC) Act, Section 5 (15 U.S.C. § 45): The FTC prohibits unfair or deceptive acts or practices in or affecting commerce. The FTC has explicitly confirmed that its existing consumer protection authority applies to AI systems. Undisclosed or misleading use of AI in advertising, marketing content, testimonials, reviews, and consumer communications may constitute a deceptive practice under Section 5. The FTC’s AI enforcement unit (established January 2026) is actively enforcing these standards.

• FTC Endorsement Guides (revised October 2023, clarified March 2025): Where Ainoa’s advertising or sponsored content involves AI-generated elements and a commercial relationship (paid advertising, sponsored content, affiliate arrangements), the FTC requires dual disclosure: (1) disclosure of the commercial relationship, and (2) disclosure that AI was used to create or substantially modify the content. This applies to US-facing advertising and sponsored content across all channels.

• New York State AI Disclosure Law (effective June 2026): New York State requires conspicuous disclosure when an advertisement includes a “synthetic performer” — meaning an AI-generated or digitally modified asset intended to give the impression of a human performer. Where Ainoa uses AI-generated human likenesses or synthetic performers in advertising placed before US audiences including in New York, Ainoa will include conspicuous disclosure in accordance with this law.

• State-level AI laws: Additional state-level AI disclosure and data protection laws are in effect or anticipated across US states including California, Colorado, Illinois, Texas, and others. Requirements vary by state and are evolving rapidly. Ainoa monitors applicable state-level requirements and will update this Policy accordingly.

• CAN-SPAM Act: Ainoa’s email marketing to US recipients is subject to the requirements of the CAN-SPAM Act, including identification and opt-out requirements. AI-generated content in email marketing does not alter these obligations.

6.4 Global — Other Jurisdictions

Ainoa’s website and social media content is accessible globally. The following reflects Ainoa’s approach to jurisdictions not specifically addressed above:

• Canada: Canada’s proposed Artificial Intelligence and Data Act (AIDA), if enacted, may impose disclosure requirements on AI-generated content. In the interim, Ainoa’s AI disclosure obligations in Canada are governed by the Consumer Protection Act and applicable provincial consumer laws. Ainoa’s proactive disclosure in this Policy is intended to satisfy the transparency standards expected under Canadian consumer protection principles.

• Australia: Australia’s voluntary AI Safety Standards and Responsible AI Framework do not currently impose mandatory AI disclosure for content like Ainoa’s. Ainoa’s proactive disclosure approach is consistent with Australia’s consumer law prohibition on misleading conduct.

• Council of Europe Framework Convention on AI: The UK signed the Council of Europe Framework Convention on Artificial Intelligence and Human Rights, Democracy and the Rule of Law in September 2024. This convention establishes high-level AI safeguards consistent with Ainoa’s transparency approach.

• General principle: For jurisdictions not specifically addressed in this Policy, Ainoa applies the principle that AI use in Published Content should be disclosed proactively where non-disclosure could mislead a reasonable consumer. This Policy serves as Ainoa’s global disclosure notice.

7. Accuracy, Completeness, and Reliability

AI Tools may produce content that contains inaccuracies, errors, omissions, bias, hallucinations (plausible-sounding but factually incorrect statements), or outdated information. While Ainoa takes reasonable steps through human editorial review to identify and correct such issues before publication, Ainoa cannot guarantee the accuracy, completeness, timeliness, or reliability of any AI-assisted content published on its website or across its channels.

You are encouraged to independently verify any information obtained from Ainoa’s content before acting upon it, particularly where such information relates to professional, legal, financial, medical, technical, or regulatory matters.

Nothing published by Ainoa constitutes professional advice of any kind unless a formal professional engagement has been entered into. All publicly available content is provided for informational and general educational purposes only.

8. Intellectual Property

The intellectual property status of AI-generated content is an unsettled area of law across jurisdictions. Ainoa does not make definitive representations as to the copyright status of AI-assisted content under applicable law in any jurisdiction.

To the extent that intellectual property rights subsist in Published Content that includes AI-assisted elements, Ainoa asserts ownership of such content as a composite work, on the basis of the human creative contribution, selection, editing, arrangement, and editorial judgment applied to the final output. Ainoa’s ownership claims are asserted without prejudice to applicable law in any jurisdiction.

You must not reproduce, distribute, adapt, or otherwise use content published by Ainoa without prior written permission, regardless of the degree to which AI Tools were involved in its creation.

Ainoa cannot guarantee that outputs produced by AI Tools are wholly original or that they do not resemble content independently produced by third parties. The AI providers whose tools Ainoa uses have their own terms of service addressing intellectual property; Ainoa’s use of such tools is subject to those terms. If you have concerns about specific content, please contact Ainoa at the address given in Section 12.

9. No Warranties or Guarantees Regarding AI-Generated Content

To the fullest extent permitted by applicable law in each relevant jurisdiction, Ainoa makes no warranties, representations, or guarantees, whether express, implied, statutory, or otherwise, in relation to the AI-assisted elements of its Published Content, including but not limited to:

• Warranties of accuracy, completeness, fitness for purpose, or non-infringement

• Warranties that AI-assisted content is free from errors, bias, hallucination, or factual inaccuracy

• Warranties that AI-assisted content reflects current professional standards, best practices, or regulatory requirements

• Warranties that AI-assisted content is appropriate for any particular use, purpose, or audience

• Warranties that AI-assisted content does not infringe the intellectual property rights of any third party

• Warranties as to the availability, reliability, or continued provision of any AI Tool used by Ainoa

This section does not affect any rights you may have as a consumer under applicable UK consumer protection legislation, EU consumer protection legislation, US consumer protection law, or the consumer protection laws of any other jurisdiction in which you are located.

10. Limitation of Liability

To the fullest extent permitted by applicable law, Ainoa Brands Ltd, its directors, employees, contractors, agents, and representatives shall not be liable for any loss or damage of any kind arising out of or in connection with your reliance on AI-assisted Published Content, including but not limited to:

• Direct, indirect, incidental, special, consequential, or exemplary loss or damage

• Loss of profit, revenue, business opportunity, data, or goodwill

• Damage arising from inaccurate, incomplete, biased, or misleading AI-generated content

• Damage arising from reliance on AI-assisted content for professional, legal, medical, financial, technical, or other decisions

• Damage arising from intellectual property infringement by AI-generated content

Nothing in this section limits Ainoa’s liability for: (a) death or personal injury caused by Ainoa’s negligence; (b) fraud or fraudulent misrepresentation; (c) any other liability that cannot lawfully be excluded or limited under applicable law in the relevant jurisdiction; or (d) any liability arising under applicable consumer protection legislation that may not be excluded or limited.

11. AI Use in Client Deliverables and Professional Services

Where Ainoa uses AI Tools in the course of producing Client Deliverables, the following applies:

• AI Tools may be used to support research, drafting, information synthesis, and production tasks as part of Ainoa’s professional services workflow.

• All Client Deliverables are subject to human review, professional judgment, and editorial oversight by Ainoa team members before delivery to the client.

• Ainoa does not deliver AI output directly to clients as finished professional work without human review and the assumption of professional responsibility by the relevant Ainoa team member.

• Where a client has specific requirements regarding AI use in their engagement — including requirements to exclude AI from any part of the work, or to receive specific disclosure of AI involvement in deliverables — these requirements must be agreed in writing and documented in the relevant contract or statement of work prior to commencement of the engagement. Without such written agreement, Ainoa’s standard practice (as described in this Policy) applies.

• Personal data and confidential business information provided by clients to Ainoa will not be inputted into third-party AI Tools without the client’s prior knowledge and, where required by applicable data protection law, consent. Ainoa’s handling of personal data is governed by its Privacy Policy.

• Ainoa’s use of AI Tools in professional services engagements does not alter its professional duties of care, confidentiality, or the standard of service it is contracted to provide.

12. Third-Party AI Platforms

AI Tools used by Ainoa are operated by third-party providers. Ainoa’s use of these tools is governed by the applicable terms of service, acceptable use policies, and privacy policies of those providers. Ainoa is not responsible for the practices, data handling, content moderation decisions, or outputs of third-party AI platforms.

Where third-party AI providers update their terms of service, privacy practices, or data handling in ways that are material to this Policy, Ainoa will review and update this Policy accordingly.

Users of Ainoa’s website do not interact directly with third-party AI platforms through Ainoa’s website unless explicitly stated. Ainoa does not operate a public-facing AI chatbot or automated AI interaction system on its website at the date of this Policy.

13. AI Use in Advertising and Sponsored Content

Where AI is used in the production of paid advertising or sponsored content distributed by Ainoa, the following practices apply:

• Where required by applicable law (including FTC regulations for US-facing content, EU AI Act requirements for EU-facing content, and any applicable platform policies), Ainoa will include clear disclosure of AI involvement in advertising content.

• For US-facing sponsored or paid content where AI has been used to create or substantially modify the content, Ainoa will include dual disclosure: (1) disclosure of any commercial or material connection, and (2) disclosure of AI involvement in content creation, in accordance with FTC requirements.

• For EU-facing content involving AI-generated deepfake elements (AI-generated or manipulated image, audio, or video that depicts real persons, objects, places, or events in a way that could mislead a reasonable observer), Ainoa will include clear disclosure in accordance with Article 50(4) of the EU AI Act.

• Where Ainoa uses AI-generated human likenesses or synthetic performers in advertising distributed to New York State audiences, Ainoa will include conspicuous disclosure in accordance with the New York State AI Disclosure Law (effective June 2026).

• Ainoa does not use AI Tools to generate fake endorsements, fabricated testimonials, false reviews, or any content designed to deceive consumers about the authentic experiences of real individuals.

• AI-generated imagery used in advertising will be labelled as ‘AI-generated’ or equivalent, at the point of publication, to the extent required by applicable law and Ainoa’s platform obligations.

Platform-specific disclosure obligations (including those imposed by Meta, LinkedIn, TikTok, YouTube, Google Ads, and other platforms) apply in addition to the legal requirements described above. Ainoa will comply with applicable platform policies regarding AI content disclosure.

14. Data Protection and AI

Where AI Tools process personal data, Ainoa’s obligations under the UK GDPR, the Data Protection Act 2018, and applicable international data protection laws apply. Ainoa’s full data protection practices are set out in its Privacy Policy.

Key data protection practices relevant to AI use include:

• Ainoa does not input the personal data of individuals — including clients, prospective clients, employees, or third parties — into third-party AI Tools without appropriate legal basis and, where required, informed consent.

• Where AI Tools are used in automated or semi-automated processing that produces decisions with legal or similarly significant effects on individuals, Ainoa will comply with the applicable automated decision-making requirements under the UK GDPR and the Data (Use and Access) Act 2025.

• Ainoa’s use of AI Tools for marketing purposes is subject to applicable electronic communications regulations, including the UK Privacy and Electronic Communications Regulations (PECR), with PECR fines having been raised to £17.5 million or 4% of global turnover under the Data (Use and Access) Act 2025.

15. Image and Visual Content Labelling

Where Ainoa publishes images, graphics, or other visual assets that have been generated or substantially modified by AI Tools:

• Ainoa will add ‘AI-generated’ or ‘Created with AI’ labels or equivalent text to the extent required by applicable law, platform requirements, or where the absence of such labelling could mislead a reasonable viewer.

• Where content credentials or machine-readable metadata (such as C2PA Content Credentials) are technically available within Ainoa’s production workflow, Ainoa will implement such marking proportionately.

• AI-generated imagery used in advertising is subject to the additional provisions in Section 13 above.

• Ainoa will not use AI to generate or modify imagery depicting real, identifiable individuals without their explicit consent, and will not use AI-generated imagery to create false impressions of real events, statements, or actions.

16. Changes to This Policy

The regulatory landscape governing AI disclosure is evolving rapidly across all jurisdictions in which Ainoa operates. Ainoa reserves the right to update this Policy at any time in response to changes in applicable law, regulatory guidance, platform requirements, or Ainoa’s own AI tool usage.

Material changes to this Policy will be indicated by an updated version number and review date at the top of this document. The most recent version of this Policy will be published on the Ainoa website.

Ainoa recommends reviewing this Policy on a six-monthly basis. The scheduled next review date is shown on the face of this document.

Your continued use of the Ainoa website or engagement with Ainoa’s content following any update to this Policy constitutes acknowledgement of the updated version.

17. Contact and Queries

If you have questions about AI use at Ainoa, about the content of this Policy, about AI use in a specific project or engagement, or about specific Published Content, please contact us:

Ainoa Brands Ltd

Email: hello@ainoa.agency

Website: www.ainoa.agency

Registered office: Collingwood Buildings, 38 Collingwood Street, NE1 1JF, Newcastle upon Tyne, United Kingdom

Company No. 14070598 (England and Wales)

For data protection queries specifically, please see our Privacy Policy.