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ZARPO ARTIFICIAL INTELLIGENCE POLICY

Owner: ZarpoApps S.L.

Trade name: Zarpo

Registered address: Rec Comtal 12, 3-3, 08003 Barcelona, Spain

Tax ID (C.I.F.): B21857602

General contact: legal@zarpo.io

1. Purpose of this Policy

The purpose of this Artificial Intelligence Policy is to inform Zarpo’s Users about the use of artificial intelligence systems in the provision of the Services.

This Policy forms part of the Website Legal Terms and supplements Zarpo’s Privacy Policy, Legal Notice, Terms and Conditions and Cookie Policy, which can be accessed at any time through Zarpo’s Site (zarpo.io).

For the purposes of this Policy, capitalised terms not defined in the rest of the Legal Terms shall be understood as having, and have, the meaning given in Regulation (EU) 2024/1689 of the European Parliament and of the Council, of 13 June 2024, laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (the “Artificial Intelligence Regulation” or “AI Act”)

2. Guiding principles

Zarpo’s use of artificial intelligence systems will be governed, in addition to the specific provisions of this Policy, by the following principles:

  1. i. Proportionality and risk management. Zarpo will apply controls proportionate to the level of risk of each AI system used, taking a risk-based approach throughout the life cycle of the systems.
  2. ii. Privacy by design and by default. Zarpo will build the protection of privacy and the security of personal data in from the initial stages of design and integration of any AI system, ensuring data minimisation, purpose limitation and protection by default.
  3. iii. Robustness, accuracy and cybersecurity. Zarpo will endeavour to ensure that the AI systems used in the Service are accurate, robust and resilient, taking reasonable measures against AI-specific threats within the scope of its technical and contractual capabilities.
  4. iv. Responsibility and accountability. The User assumes full responsibility for the inputs they provide to the AI system, as well as for the outputs generated from them in the Product creation process. Zarpo, directly or through its technology and printing providers, may apply automated filters and technical controls aimed at detecting and blocking certain manifestly inappropriate Content before it is generated, as well as automated quality controls on the final result before it is printed or exported. These mechanisms have an exclusively technical purpose, operate in an automated and non-exhaustive way, and are in no case equivalent to a human, individual or complete review of the instructions provided by the User or of the Content generated, nor do they imply that Zarpo assumes a general obligation of supervision. Zarpo does not guarantee that these filters or controls will detect, correct or prevent the generation of all Content that is inappropriate, incorrect or not in line with the User’s instructions. Consequently, Zarpo assumes no liability for the Content entered or generated, or for the consequences that may arise from it as to its suitability, lawfulness or appropriateness for the purpose pursued by the User, without prejudice to the automated mechanisms described, which are applied as an additional measure of diligence and not as a guarantee of result.
  5. v. Continuous improvement. We will endeavour to promote the continuous improvement of our AI practices by monitoring performance, incorporating lessons learned and updating the applicable controls, taking into account technological developments, the regulatory framework in force and industry best practice.

3. Artificial intelligence technology used

Zarpo currently uses third-party artificial intelligence systems for the different stages of the creative process. The use of these technologies is governed by each provider’s standard terms, including, where appropriate, data protection agreements and the specific conditions applicable to generative artificial intelligence services. It is for each User to review those conditions before using the Service, since Zarpo only provides an interface that facilitates access to these technologies and the composition of the Product, without intervening in the functionalities or configuration of each provider’s artificial intelligence systems.

Zarpo may modify, replace or add other artificial intelligence providers, models, services or tools when necessary to improve the Service, guarantee its security, adapt it to technical, operational or legal changes, or ensure the continuity of the Site. Zarpo does not guarantee the permanent availability of any particular provider, model or tool, and may replace or withdraw them at any time and without prior notice. In any case, it is for the User to verify that the generated Content meets their expectations and requirements before proceeding to print or export it.

Where such a modification materially affects the processing of personal data, the essential conditions of the Service or the User’s rights, Zarpo will update the corresponding information in this Policy, in the Privacy Policy or in the Terms and Conditions, as appropriate.

4. Zarpo’s position with regard to artificial intelligence

Zarpo does not develop, train or place on the market the artificial intelligence models it uses, and acts as a deployer for the purposes of the AI Act.

The AI systems deployed have the sole purpose of creating synthetic Content for the making of Products intended for leisure and private use. They are not designed for educational purposes, nor for uses that could coincide with prohibited or high-risk uses under the Artificial Intelligence Regulation. The User must in all cases refrain from using them for such purposes.

If in the future Zarpo were to develop, train, substantially fine-tune, market or put into service its own AI system under its name or trade mark with a scope different from that described in this Policy, it will review its legal position and update this Policy where appropriate.

5. Processing of personal data in AI processes

Where the use of artificial intelligence involves the processing of personal data, that processing will be carried out in accordance with Zarpo’s Privacy Policy and the applicable data protection legislation.

The User should consult the Privacy Policy before using Zarpo or contracting its Services.

6. No disclosure of Content for third parties’ own purposes

Zarpo will not sell, rent or disclose to third parties the photographs, images, names, instructions, stories or Content provided by the User for those third parties to use them for their own purposes of training, advertising, profiling, independent commercial exploitation or the creation of databases unrelated to the contracted Service.

However, in order to provide the Service, such Content may be processed by Zarpo’s technology providers, including providers of artificial intelligence, hosting, security, technical support, payment, printing or logistics, on the terms provided for in the Privacy Policy and under the appropriate contractual, technical and organisational safeguards.

This involvement of technology providers does not constitute an authorisation for those providers to use the User’s Content for their own purposes unrelated to the provision of the Service contracted from Zarpo.

7. Retention of AI-generated Content

For the purposes of these Terms and Conditions, a distinction is drawn between User Content (such as the photographs, images, texts and other Content provided directly by the User for the creation of the Product) and Generated Content (such as the stories, illustrations and other elements of the Product produced by the artificial intelligence systems from that Content). The retention and deletion regime applicable to each category is set out below and is governed, in all cases, by the provisions of the Privacy Policy and the Terms and Conditions.

As a general rule, Zarpo will keep data and Content for the time necessary to provide the Service, allow the User to access the Product, manage orders, process printing and delivery where applicable, deal with incidents, comply with legal obligations and defend itself against possible claims.

The original photographs provided by the User will be processed only for the time necessary to generate or personalise the contracted Product, in accordance with the periods and conditions indicated in the Privacy Policy.

Generated Content may be kept in the User’s account or in Zarpo’s systems for the time necessary to allow access, review, download, printing, reprinting, support, legal compliance or defence against claims, in accordance with the provisions of the Privacy Policy and the Terms and Conditions.

8. Transparency about Content generated or manipulated by AI

The User is informed that Generated Content may be created, modified or assisted by artificial intelligence systems.

Whenever the User interacts with features based on artificial intelligence, we will endeavour to make this clearly identifiable, so that the User can know at each stage of the process that they are interacting with an automated system and not with a natural person.

Where required under the applicable legislation, Zarpo will disclose that the relevant Content has been artificially generated or manipulated.

Where the Content generated by artificial intelligence forms part of the personalised Product as a creative, narrative, artistic, fictional or analogous work, Zarpo will include in the resulting Product a statement about the involvement of artificial intelligence systems. That statement will be considered mandatory content of the Product and will be included by Zarpo automatically or in a predefined way in the structure of the book, without the User having to add it manually. As a general rule, the statement will be included in the final part of the Product or in another equivalent location, worded clearly and appropriately, and placed so that it does not hinder the reading, display or enjoyment of the work.

The specific wording of the statement may be adapted depending on the format of the Product, the characteristics of the content generated and the legal or technical requirements applicable at any given time.

Zarpo does not guarantee that all Content generated by AI will be detectable by any external AI detection tool, nor that such tools will give accurate, complete or infallible results.

Where technical marking depends on features provided by external providers, Zarpo will act within the technical and contractual capabilities available at any given time.

9. Limitations inherent to generative artificial intelligence

The User is informed that generative artificial intelligence systems are emerging technologies that may produce results that are incorrect, imprecise, incomplete, unexpected, offensive, repetitive, similar to those generated for other Users or not fully in line with their subjective expectations.

In particular, AI systems may:

  1. a. interpret an instruction imperfectly;
  2. b. generate unforeseen creative variations;
  3. c. produce narrative or visual inconsistencies;
  4. d. fail to reproduce a photograph, description, style or preference exactly;
  5. e. generate similar results for different Users when similar instructions are entered;
  6. f. reflect biases, errors or patterns arising from the data, models or methods used;
  7. g. require subsequent review, adjustment or correction.

Zarpo will take reasonable measures to reduce these risks in the context of the Service, notwithstanding that certain variations are inherent to a creative process assisted by artificial intelligence.

It is in all cases for the User to check and supervise the generated Content before proceeding to print or export it. The User is responsible for reviewing the output obtained, making the adjustments they consider necessary and, ultimately, accepting the result before its use, printing or distribution. Use of the Service implies acceptance of the inherent limitations of generative artificial intelligence technologies described in this section.

10. Human oversight and quality control

Without prejudice to the automated filters and technical quality controls that Zarpo or its technology and printing providers may apply as indicated in section 2, these mechanisms do not replace or reduce the User’s responsibility.

In carrying out these quality controls, Zarpo may access the content of your Product before it is printed or delivered, for the sole purpose of checking that it has been generated correctly and its editorial quality, without this implying a review of the substance, suitability or appropriateness of the content for the purpose pursued by the User.

It is the sole responsibility of the User to carry out the review, filtering, moderation, editing or quality control of the instructions provided by the User and of the Content generated by artificial intelligence, including:

  1. I. review of narrative consistency;
  2. II. review of whether the Content matches the instructions provided;
  3. III. controls to avoid Content that is unlawful, offensive, discriminatory, sexual, violent, harmful to minors or contrary to the rights of third parties;
  4. IV. handling of incidents or complaints reported by the User.

Zarpo will endeavour to ensure that the tools used in the Service are suitable for the intended purpose of creating Products, and that the printed and exported Products have the appropriate visual and editorial quality, entering into the necessary agreements with its printing and export providers for that purpose.

11. No biometric identification, biometric categorisation or emotion recognition

Zarpo does not use the AI systems of the Service for the purpose of uniquely identifying a natural person, carrying out biometric categorisation, inferring emotions, assessing psychological traits or taking decisions based on biometric data.

Where the User provides photographs or images, these will be used for the creative and personalised purpose of the contracted Product, on the terms indicated in this Policy and in the Privacy Policy.

The generation of illustrations or characters from photographs provided by the User is not intended to biometrically identify the person depicted or to compare them against reference databases.

12. No automated decisions with legal effects

Zarpo does not use artificial intelligence systems to take automated decisions that produce legal effects concerning the User or that similarly significantly affect them.

The use of AI at Zarpo is directed at the creative and personalised generation of the contracted Product.

AI security and governance

Zarpo will take reasonable measures to promote the safe, responsible and proportionate use of the artificial intelligence systems used in the Service.

These measures may include, as appropriate:

  1. I. limiting access to the information provided by the User;
  2. II. configuring permissions and controls in the artificial intelligence services used;
  3. III. periodically reviewing the conditions applicable to the relevant technology providers;
  4. IV. implementing procedures to handle incidents or complaints;
  5. V. any others that may be appropriate to guarantee the quality of the Service in accordance with the applicable legislation.

13. Recommendations to the User before uploading information or images

Before providing information, photographs or images to Zarpo, the User is advised to:

  1. a. not provide images of third parties without sufficient authorisation to do so;
  2. b. avoid including information that is especially sensitive or not necessary for the creation of the Product; avoid providing official documents, financial data, medical data, full addresses, geolocation information or any other confidential Content that is not necessary for the provision of the Service;
  3. c. check that the images do not contain unwanted visible data, such as number plates, addresses, documents, screens, uniforms, schools, identifiable locations or third parties in the background;
  4. d. use only Content over which they have sufficient rights or authorisations;
  5. e. provide images of sufficient quality and complete, detailed descriptions, following at all times the instructions provided on the Site and the guidance in the frequently asked questions available on it.

These recommendations do not replace the User’s legal obligations or the responsibility that corresponds to the User for the Content provided.

14. Updates to this Policy

Zarpo may update this Artificial Intelligence Policy to adapt it to regulatory, technical, operational or contractual changes or changes in the operation of the Service. It is for the User to review its Content before contracting the Service.

Last updated: October 2026