AI Usage Statement

Cognitiva Systems Inc.

Status. CognitivaOS launches in January 2027, in the UAE first, then India and the USA. The platform's AI features are in development and have not yet run on customer campaigns. The website chat assistant is live. This statement is general information about how we use AI and which AI laws we follow; it is not legal advice.

SUMMARY#

We use AI in two places: the chat assistant on this website, and four decision-support features inside CognitivaOS. In both, AI is labelled where you meet it, and a person makes every decision that matters. AI never signs a contract, releases a payment, publishes content or approves a creator on its own.

No AI system we run is high-risk under the EU AI Act, and we use none of the practices that law prohibits.

1.WHERE WE USE AI#

1.1 Website chat assistant#

The chat assistant on this website runs on a large language model provided by Anthropic, PBC, listed on our Sub-Processors page. Before you type, the chat window tells you that you are talking to an AI assistant and that its answers can be wrong.

• The model receives your chat messages. It does not receive the name or email address you enter.
• The assistant gives general information only. It does not give legal, tax or financial advice and cannot change your account, a contract or a payment.
• You can ask for a copy of the conversation or ask our team to follow up, and you can always reach a person through the contact page instead.

1.2 AI features in CognitivaOS#

CognitivaOS will include four AI features. Each produces a recommendation, a score or a flag, shown with a label that it comes from AI. Users can see the main factors behind an output and can override it.

1. Creator matching suggests creators who fit a campaign brief. It does not decide who is offered work.
2. Payment risk detection flags patterns that tend to come before payment disputes. It never blocks or releases money by itself.
3. Campaign success prediction estimates the likelihood that a campaign meets its goals.
4. Compliance monitoring checks posts for missing advertising disclosures and deviations from the brand brief. A person approves the final result.

How each system is classified, documented, tested and overseen is set out in our EU AI Act Compliance Statement.

1.3 Where we do not use AI to decide#

• Identity verification. The document and liveness checks behind Verified are carried out by our regulated identity-verification provider. We receive the result; we do not run face recognition ourselves.
• Contracts and payments. Contracts are signed by brands, agencies and creators. Payments are released by licensed payment partners on approval by a person. No AI step can sign, release or withhold either.
• Account decisions. We do not suspend, close or refuse an account on the strength of an AI output alone.
• Profiling for advertising. We do not use AI to build advertising profiles of visitors, customers or creators.

1.4 Content on this website#

Some text and translations on this website are drafted with the help of AI tools. A person reviews them before they are published, and we are responsible for them as for any other content. We do not publish synthetic images, audio or video of real people, or AI-generated testimonials.

The AI mark in the footer of every page links to this statement.

2.HOW WE USE AI#

• Transparency. We tell you when you are dealing with AI, what it is for and what it cannot do.
• Human oversight. AI outputs are inputs to a person's decision, never the decision itself.
• Fairness. We test matching and risk models for differences in outcomes between groups of creators before release and after changes, and we do not use sensitive characteristics such as ethnicity, religion, health or sexual orientation as inputs.
• Data minimisation. AI features use the data needed for the task. We do not give a third-party AI provider customer or creator data beyond what that task needs.
• Accountability. Every AI feature has a named owner, is recorded in our AI inventory, and is reviewed before release, after significant changes and at least once a year.
• AI literacy. Staff who build, operate or sell AI features are trained on what the features do, their limits and the rules in this statement.

3.NATIONAL AND REGIONAL AI LAWS#

AI is regulated differently in each country. Some have a dedicated AI law; most regulate AI through data protection, consumer protection and sector rules, backed by national AI principles. We follow the rules of each market we operate in, and where a market has no AI-specific law we apply the standards in section 2 anyway.

3.1 United States#

There is no general federal AI statute. The Federal Trade Commission applies Section 5 of the FTC Act to AI: claims about what an AI product can do must be true and evidenced, and AI must not be used to deceive. We describe our AI features without performance figures until they have been measured in production.

Texas. Cognitiva Systems Inc. is a Texas corporation. The Texas Responsible Artificial Intelligence Governance Act (HB 149, in force from 1 January 2026) prohibits developing or deploying AI with the intent to manipulate people into self-harm, harm to others or crime, to discriminate unlawfully against a protected class, to infringe constitutional rights, or to produce unlawful sexual content or deepfakes. We do none of these, and our AI documentation is available to the Texas Attorney General on request.

Colorado. The Colorado AI Act regulates high-risk AI systems that make, or are a substantial factor in making, consequential decisions about consumers, such as decisions on employment, lending, housing or insurance. Our AI features recommend; they do not decide whether anyone gets work, money or a service. We will review this assessment before we open to customers in the USA and again if a feature changes.

Utah. The Utah Artificial Intelligence Policy Act requires disclosure when a person interacts with generative AI. Our chat assistant discloses this before every conversation, not only when asked.

California. Rules under the CCPA/CPRA give consumers rights where a business uses automated decision-making technology to make significant decisions about them. We do not make such decisions by automated means. California residents can also opt out of the sale or sharing of personal information on our Do Not Sell page.

New York City. Local Law 144 requires a bias audit and notice before an automated employment decision tool is used on candidates. If we use such a tool in our own hiring, we will audit it and give notice first.

3.2 United Arab Emirates#

The UAE, our first market, has no AI-specific statute. AI is governed by the UAE Charter for the Development and Use of Artificial Intelligence, the Dubai AI Ethics Principles and Guidelines, and the Personal Data Protection Law (Federal Decree-Law No. 45 of 2021). We follow the Charter's principles of human oversight, safety, fairness, transparency and accountability.

Under the PDPL you can object to decisions based solely on automated processing that have legal or similarly significant effects on you. We do not make such decisions, and a request for human review under section 4 will always be honoured. Our Dubai office is in Emirates Towers on Sheikh Zayed Road, outside the Dubai International Financial Centre, so the onshore UAE rules above apply to it rather than the DIFC Data Protection Law and its Regulation 10 on autonomous and semi-autonomous systems. If we ever process personal data in or from the DIFC, we will meet Regulation 10 as well, including its notice and certification requirements.

3.3 India#

India has no AI-specific statute. AI is governed by the Digital Personal Data Protection Act 2023 and its Rules, the Information Technology Act 2000 and the IT Rules 2021, guided by the India AI Governance Guidelines issued by the Ministry of Electronics and Information Technology.

• Personal data used by our AI features is processed on a lawful basis under the DPDP Act, and you can exercise your rights to access, correction and erasure as set out in our Privacy Policy.
• We do not publish synthetically generated audio, images or video of people. If we ever publish synthetic content, we will label it as the IT Rules require.
• Our AI features are labelled, may be wrong, and do not decide on their own, consistent with MeitY's advisories on AI use.

3.4 European Union#

The EU AI Act is the most detailed AI law in our markets. Its bans on prohibited practices and its AI literacy duty have applied since 2 February 2025; its transparency duties under Article 50 apply from 2 August 2026. The EU is not a launch market, but we build to the Act now. Our EU AI Act Compliance Statement sets out the classification of each system, the transparency measures and human oversight. Under Article 22 of the GDPR, decisions with legal or similarly significant effects are not made about you solely by automated means.

3.5 United Kingdom#

The UK has no AI-specific statute. Regulators apply five principles: safety, transparency, fairness, accountability and contestability. UK GDPR, as amended by the Data (Use and Access) Act 2025, requires safeguards, including the right to human intervention, for significant decisions based solely on automated processing. We apply those safeguards to any such decision, and make none today.

3.6 Singapore#

Singapore has no AI-specific statute. We apply the Model AI Governance Framework, including its framework for generative AI, and the PDPC's Advisory Guidelines on the Use of Personal Data in AI Recommendation and Decision Systems, which call for notice and explanation when personal data is used in AI recommendations.

3.7 Bosnia and Herzegovina#

Bosnia and Herzegovina has no AI-specific statute. Personal data is protected under national data protection law, which is being aligned with the GDPR as part of the country's EU accession path. Work carried out from our Sarajevo office follows the EU AI Act standards described in this statement.

3.8 International frameworks#

Beyond national law, our approach follows the OECD AI Principles, the Council of Europe Framework Convention on Artificial Intelligence, ISO/IEC 42001 (AI management systems), ISO/IEC 23894 (AI risk management) and the NIST AI Risk Management Framework.

4.YOUR RIGHTS AND CHOICES#

Wherever you are, you can:

• Ask whether AI was used in a recommendation, flag or score that concerns you, and what the main factors were.
• Ask for human review of any AI output that affects you. A person who can change the outcome will look at it.
• Challenge an output you think is wrong and give your side.
• Avoid the chat assistant and contact our team directly through the contact page.
• Exercise your data rights, including access, correction, deletion and objection, as described in our Privacy Policy.

We answer AI requests within 30 days, or sooner where local law requires.

5.INCIDENTS AND REPORTING#

If an AI feature produces a harmful, discriminatory or seriously wrong result, we withdraw or restrict it, investigate, tell the people affected, and notify regulators where the law requires. You can report a concern about our AI to the address below. We will publish our first AI transparency report within twelve months of launch.

6.CHANGES TO THIS STATEMENT#

AI law is changing quickly in all our markets. We review this statement at least every six months, and whenever we add an AI feature, enter a new market or a relevant law changes. The version number and date at the top show the current version.

7.CONTACT#

AI questions, human review and complaints:
Email: ai-compliance@cognitiva.systems
Phone: +1 212-220-8418

Cognitiva Systems Inc., 801 Travis Street, Suite 2101, Houston, TX, United States