1. Introduction and Glossary
This Artificial Intelligence Policy (“AI Policy”) describes how E-goi uses artificial intelligence technologies, machine learning, generative models, predictive models, intelligent agents and other automated technologies within the scope of the E-goi Platform and the respective Services.

This Policy explains, in particular:

what types of AI Features may be available on the E-goi Platform;
how data entered into or used by those features is processed;
who is responsible for validating results generated by AI;
what security, privacy and governance controls are applied;
under what conditions Third-Party AI Providers may be used;
how this Policy interacts with E-goi’s other legal terms.
The AI Policy supplements E-goi’s Terms of Use and any other applicable contractual documents. In the event of any conflict between this AI Policy and a specific agreement entered into between E-goi and the Client, the specific agreement shall prevail, except where otherwise required by mandatory law

The main terms used in this document are defined and explained in detail in the Glossary (attached to this Agreement). You are advised to consult the Glossary for a better understanding of the concepts and definitions used herein.

2. Types of AI Features
E-goi may provide different types of AI Features, including, without limitation:

Generative AI for content: Features that assist the Client in creating, improving, translating, summarising or adapting content, such as email subjects (titles), email message copy, SMS, SmartSMS, push, web push or equivalent messages, content for landing pages or forms, suggestions regarding tone of voice, structure, copy or personalisation, images, creative variations or visual elements, where applicable.
Predictive and analytical AI: Features that assist the Client in analysing data, identifying patterns, predicting behaviours or optimising campaigns, such as purchase propensity, churn risk, recommended best send time, engagement prediction, intelligent segmentation, RFM analysis, product recommendations, performance analysis, identification of optimisation opportunities, and aggregated or comparative benchmarks, where applicable.
AI for automation and workflow: Features that assist the Client in creating, configuring, suggesting or optimising workflows, automations, segments, journeys, triggers, integrations or operational rules. These features may support the creation of workflows and automations, but the Client remains responsible for their validation, final configuration and activation.
Intelligent Agents and OmniConnect: E-goi may provide intelligent agents, including features associated with E-goi OmniConnect or equivalent products, capable of interpreting natural language instructions, consulting authorised account data, proposing actions, campaigns, segments, integrations or automations, summarising relevant information, preparing configurations, interacting with integrated systems where authorised, and supporting marketing, sales, support, operations or product teams. Unless expressly stated otherwise, E-goi’s intelligent agents are designed as assistants and not as autonomous final decision-making systems. The Client must review, validate and approve proposed actions before execution, particularly where such actions may affect contacts, campaigns, integrations, billing, commercial communications or decisions relevant to data subjects.
AI for customer support, customer success and support services: E-goi may use AI technologies to support its internal support, customer success, product, operations or security teams, including to summarise tickets or interactions, analyse account information in the context of a support request, identify usage patterns, generate internal recommendations, prepare responses or documentation, support troubleshooting, identify possible causes of incidents or errors, or generate insights intended to improve the Client experience. These uses are intended to support E-goi personnel and do not replace human assessment where circumstances so require..
3. Client Control and Human Oversight
E-goi’s AI Features are provided to support the Client, increase productivity, facilitate analysis and accelerate the creation of content or configurations. The Client remains responsible at all times for:

reviewing Outputs before use and confirming the accuracy, suitability and legality of the Outputs;
validating that content is aligned with its brand, business activity, industry and legal obligations;
ensuring that commercial communications, campaigns, segmentations and automations comply with applicable law;
deciding whether to accept, edit, reject or use an Output;
ensuring that Outputs are not used in a discriminatory, abusive, misleading, unlawful manner or in a manner incompatible with E-goi’s Terms of Use and Acceptable Use Policy (attached to this Agreement).
No AI Feature shall be construed as a substitute for legal, financial, tax, medical, regulatory, professional or compliance advice.

4. Ownership of Inputs and Outputs
As between E-goi and the Client, the Client retains ownership of the Inputs it enters into or provides through the E-goi Platform. To the extent permitted by law, and unless otherwise provided by contract, the Client shall own any rights that E-goi may hold in Outputs generated for the Client through the AI Features. Inputs and Outputs are considered Client Data where they are processed, provided or generated in connection with the use of the E-goi Platform.

The Client acknowledges that:

Outputs may not be exclusive;
similar features may generate the same or similar results for different clients;
the Client is responsible for verifying whether Outputs may be used in its specific circumstances;
E-goi does not guarantee that Outputs are original, free from third-party rights or suitable for all of the Client’s commercial, legal or regulatory purposes.
5. Processing of Client Data in AI Features
E-goi processes Client Data in connection with AI Features only to the extent necessary to:

provide the requested feature;
generate the Output requested by the Client;
operate, maintain, protect and improve the E-goi Platform;
provide technical, operational or Client Success support;
comply with legal, contractual or security obligations;
prevent abuse, fraud, misuse or violations of the Terms of Use.
Where E-goi processes Client Personal Data on behalf of the Client, such processing shall be carried out in accordance with E-goi’s DPA (attached to this Agreement). E-goi shall apply the principles of data minimisation, purpose limitation, necessity, security and access control to the processing of data used in AI Features.

6. Use of Third-Party AI Providers
Certain AI Features may rely on Third-Party AI Providers to process Inputs and generate Outputs. Where this occurs, E-goi shall seek to limit the information sent to the third-party provider to that which is necessary to perform the requested feature. Where Third-Party AI Providers process Client Personal Data on behalf of E-goi, they shall be treated as subprocessors in accordance with E-goi’s DPA (attached to this Agreement) and E-goi’s subprocessor list, where applicable.

E-goi shall implement appropriate contractual measures to ensure that Third-Party AI Providers:

process data solely for the purpose of providing the contracted service;
do not use Client Data to train their own global models, unless expressly stated and permitted by contract or applicable law;
apply security measures consistent with E-goi’s commitments;
comply with confidentiality obligations;
comply with applicable data protection requirements..
7. Model Training and Service Improvement
E-goi does not use Client Data to enable other clients to replicate a Client's proprietary content, strategies, campaigns, segments, data, tone of voice or confidential information. E-goi may use aggregated, anonymised or appropriately de-identified data to:

improve the quality of the E-goi Platform;
develop analytical, predictive or statistical features;
improve the security, performance and reliability of the Services;
create aggregated benchmarks;
assess the quality, robustness and usefulness of AI Features.
Whenever aggregated or de-identified data is used, E-goi shall adopt reasonable measures to reduce the risk of identifying or re-identifying a Client, contact or data subject. E-goi does not sell Client Data to AI providers.

9. Personal Data, Sensitive Data and Special Categories
The Client is responsible for ensuring that Inputs used in AI Features are appropriate, necessary and lawful. Where the Client uses Client Personal Data in AI Features, the Client shall ensure that it has an appropriate lawful basis, provides the required information to data subjects, has appropriate contractual safeguards and risk assessments in place, and complies with any other requirements imposed by applicable law.

10. Automated Decision-Making and Significant Effects
The Client shall not use E-goi’s AI Features to make decisions based solely on automated processing that produce legal effects or similarly significant effects concerning natural persons, unless the Client ensures that such use is lawful and that all applicable legal requirements are met.

The Client is responsible for ensuring that any use of AI for segmentation, profiling, personalisation, scoring, eligibility, exclusion, prioritisation or differentiated treatment of data subjects complies with applicable data protection, marketing, consumer protection, telecommunications, e-commerce and other applicable laws.

Whenever a decision may materially affect a natural person, the Client shall ensure appropriate mechanisms for human oversight, challenge, review and transparency.

11. Accuracy, Bias and Limitations of AI
AI Features may generate useful Outputs, but they are not infallible. The Client acknowledges that Outputs may:

contain errors;
be incomplete;
be outdated;
reflect biases present in data or models;
produce recommendations that are unsuitable for a specific case;
generate plausible but incorrect information;
fail to comply with the Clients’s legal, industry-specific, linguistic, cultural or brand requirements.
E-goi may apply control mechanisms, testing, filters, validation, monitoring and quality review, but does not guarantee the complete elimination of errors, bias, hallucinations, inaccuracies or undesirable results. The Client must critically review all Outputs before using, publishing, sending or executing them.

12. Security of AI Features
AI Features are protected in accordance with E-goi’s Security Policy (attached to this Agreement), including, where applicable, access controls, authentication and authorisation, logical data segregation, encryption, monitoring, logging, vulnerability management, vendor management and abuse-prevention measures.

E-goi may retain technical records associated with the use of AI Features for the purposes of security, auditing, abuse prevention, support, troubleshooting, quality improvement, contractual or legal compliance and analysis of feature performance.

These records may include usage metadata, technical identifiers, system events, configurations, interactions with features, execution status and other information necessary to operate and protect the E-goi Platform.

Where records contain Client Personal Data, they shall be processed in accordance with E-goi’s DPA (attached to this Agreement).

13. Model Context Protocol, Integrations and Contextual Access
E-goi may use contextual access mechanisms, including the Model Context Protocol (“MCP”) or equivalent technologies, to enable AI Features to access, in a structured and controlled manner, relevant information from the account, the E-goi Platform or integrated systems. Where used, MCP or equivalent technology shall comply with the following principles:

access limited to the information necessary for the intended purpose;
compliance with configured permissions, credentials and authorisations;
application of security and authentication controls;
traceability of relevant actions or queries;
separation between querying, suggestion and execution;
human oversight where an action may produce material effects.
The use of MCP or equivalent technologies may allow AI to query authorised account information in order to better understand the context of a request. Such access constitutes a read-only or contextual support capability. By default, AI does not have permission to modify data, send campaigns, delete information, change settings, create integrations, activate automations or execute actions in external systems. Such actions may only take place where supported by the relevant feature, covered by the permissions granted by the Client and confirmed by the Client whenever they may have a material impact.

14. Agentic Features and Execution of Actions
Whenever E-goi provides agentic features capable of executing actions or preparing operations on behalf of the Client, such features shall be subject to the technical limits, permissions, configurations, controls and confirmations defined within the E-goi Platform.

The Client is responsible for:

correctly configuring permissions and access rights;
determining which users may use agentic features;
reviewing proposed actions;
approving material executions;
monitoring results;
ensuring that external integrations are properly authorised;
ensuring that any action performed complies with legal and contractual obligations.
E-goi may implement limits, additional confirmations, blocks, validations or review mechanisms to reduce operational, legal, reputational or security risks.

15. Transparency Towards End Recipients
The Client is responsible for determining whether contacts, end users, customers, leads or other data subjects must be informed about the use of AI in the Client’s communications, campaigns, automations, personalisations, segmentations, recommendations or interactions.

Where applicable law requires transparency, identification of AI-generated content, information concerning profiling, explanations regarding automated decisions or objection mechanisms, the Client shall ensure compliance with such obligations.

E-goi may provide tools, fields, templates or documentation to support the Client, but such assistance does not replace the Client’s own legal assessment.

16. Opt-in, Opt-out and Usage Controls
Certain AI Features may be available by default, in beta, subject to activation, subject to subscription or only for certain plans, modules, channels or accounts within the E-goi Service.

Where technically available, E-goi may allow the Client to:

enable or disable certain AI Features;
limit access by user, team or profile;
choose whether to use AI-generated suggestions;
reject, edit or ignore Outputs;
configure permissions associated with intelligent agents or integrations.
The availability of specific controls may vary depending on the feature, plan, agreement, language, channel, region or release stage.

17. Subprocessors and International Transfers
Where Third-Party AI Providers process Client Personal Data on behalf of E-goi, they shall be reflected, where applicable, in E-goi’s subprocessor list.

The processing of Client Personal Data by subprocessors, including any international transfers, shall be governed by E-goi’s DPA (attached to this Agreement) or other legally recognised mechanisms, where required.

18. Disclaimer of Warranties
AI Features are provided as support tools. Except where otherwise required by law or contract, E-goi does not warrant that Outputs:

will always be accurate;
will be complete;
will be exclusive;
will be error-free;
will be suitable for a particular purpose;
will be up to date;
will automatically comply with applicable law;
will replace human review;
will eliminate the need for technical, legal, commercial or operational validation.
The use of AI Features is subject to the limitations of liability set out in E-goi’s Terms of Use (attached to this Agreement) and E-goi’s other contractual documents.

19. Suspension, Limitation or Discontinuation
E-goi may, at any time, suspend, limit, modify or discontinue an AI Feature where necessary to:

comply with the law;
protect the security of the E-goi Platform;
prevent abuse;
mitigate operational, legal, regulatory or reputational risk;
comply with provider requirements;
respond to incidents;
improve the feature;
adapt to technological or regulatory changes.
Where reasonably possible, E-goi shall seek to communicate material changes that materially affect the Client’s use of the Service.

20. Reviews and Updates

E-goi may amend this Policy at any time by publishing the most recent version on the E-goi Website. E-goi shall notify the Client via RSS of any changes to this Policy as soon as reasonably practicable. In the event of an objection, the Client shall be entitled to terminate the Agreement within thirty (30) days following such notification. Unless the Client terminates the Service, the new Policy shall take effect immediately after the publication date stated in the new Policy, as applicable, and shall apply upon the Client’s continued or renewed use of the Service.

E-goi’s Artificial Intelligence Policy is reviewed regularly to reflect:

Changes in applicable law.

New technical or operational requirements.

Developments in AI Features

21. Contact
For any questions or enquiries regarding this Policy, the Client may contact E-goi through:

https://www.e-goi.com/contacts/

E-goi Platform Help Area

DPO Email (Data Privacy): dpo@e-goi.com

CISO Email (Information Security): ciso@e-goi.com

Other enquiries relating to the Artificial Intelligence Policy:  privacy@e-goi.com