AI Data Usage Policy

Effective date: July 8, 2026

This AI Data Usage Policy explains how InnovareAI uses AI systems and model providers in connection with the SAM platform and related services.

Summary

InnovareAI uses AI to help customers generate, personalize, analyze, and manage go-to-market outreach and engagement workflows. Customer Personal Data processed on behalf of customers is not used to train external or general-purpose AI models.

Model providers

Message generation may be performed using an EU-based model provider, currently Mistral AI SAS in France. Under this configuration, Customer Personal Data used for message generation is processed within the European Union.

Customers may choose an alternative model provider located in the United States, currently Anthropic PBC. Where a customer selects that option, the customer instructs InnovareAI to transfer relevant Customer Personal Data to the selected provider as necessary to provide the Services.

No third-party model training

InnovareAI does not use Customer Personal Data processed on behalf of customers to train external or general-purpose AI models.

InnovareAI does not permit third-party model providers to use Customer Personal Data to train their general-purpose models.

Customer control

Customers control the data they submit to the Services, the workflows they configure, the outreach they approve, and the model options made available in their account where applicable.

Human approval

The Services are designed to support human-in-the-loop review and approval of outreach. Where enabled or required by the Services, outreach is not sent without customer sign-off.

Sensitive data

Customers must not submit special categories of personal data, sensitive personal information, children's data, health data, financial account data, government identification numbers, criminal conviction data, or similar highly sensitive information unless expressly agreed in writing.

International transfers

Where AI processing involves a transfer of personal data outside the EEA, UK, or Switzerland to a country without an adequacy decision, InnovareAI uses appropriate safeguards such as Standard Contractual Clauses, the UK Addendum, Swiss adaptations, and supplementary measures where required.

Limitations

AI-generated outputs may be incomplete, inaccurate, or unsuitable for a particular use case. Customers are responsible for reviewing outputs before use, ensuring outreach is lawful and appropriate, and complying with applicable marketing, privacy, platform, and communications laws.

Contact

Questions about AI data usage may be sent to privacy (at) innovareai (dot) com or dpo (at) innovareai (dot) com.