AI Transparency Statement

Regulatory Framework

The United Kingdom does not, at the date of this Statement, have a single overarching statute equivalent to the EU Artificial Intelligence Act (Regulation (EU) 2024/1689). Instead, our use of artificial intelligence (“AI”) is governed by a combination of: (a) UK data protection law, including the automated decision-making regime set out in Articles 22A to 22D of the UK GDPR as inserted by the Data (Use and Access) Act 2025; (b) the five cross-sector AI principles published by the Department for Science, Innovation and Technology (safety, security and robustness; appropriate transparency and explainability; fairness; accountability and governance; and contestability and redress), as applied by the Information Commissioner's Office and other relevant regulators; (c) general consumer protection law, including the Digital Markets, Competition and Consumers Act 2024; and (d) where our Services are provided to, or affect, individuals in the European Union, the transparency obligations of Article 50 of the EU Artificial Intelligence Act, which apply from 2 August 2026. This Statement is drafted to meet the requirements of each of these frameworks to the extent they apply to our use of AI, and we will update it as further statutory or regulatory AI transparency requirements come into force in the United Kingdom or elsewhere.

Use of AI in Captivation Hub

We use AI functionality within Captivation Hub to assist with direct message responses, email automation, and funnel or chat interactions with Users. Where you interact with an automated messaging or chat feature that is wholly or substantially driven by AI, we design that feature so that it is made clear to you, at or near the point of interaction, that you may be communicating with an automated or AI-assisted system rather than a human being, consistent with Article 50(1) of the EU Artificial Intelligence Act and the transparency expectations of the Information Commissioner's Office. You may request to speak with a human at any time by contacting us as set out in our Privacy Policy.

AI-Assisted Content Drafting

We may use AI tools to assist with drafting marketing, educational, or other content. All AI-assisted content is subject to human review and editorial control before publication, and we retain responsibility for content published under any of our brands.

No Wellbeing Diagnosis

AI tools used in connection with The Sanctuary System, including any AI-assisted messaging within Captivation Hub, do not diagnose, treat, or provide a clinical or psychological assessment of any wellbeing issue, condition, or symptom. Our Sanctuary Wellbeing Disclaimer and Sanctuary Crisis Disclaimer apply to all AI-assisted interactions within The Sanctuary System.

Automated Decision Making

We do not use AI or other automated means to make a decision about you that produces a legal effect or a similarly significant effect on you without meaningful human involvement. Where, in the future, we rely on the wider scope for solely automated decision-making permitted under Articles 22A to 22D of the UK GDPR, we will provide meaningful information about the logic involved, a means of obtaining human review, and a means of contesting the decision.

No Profiling Without Consent

We do not use AI to profile Users, in the sense of evaluating personal aspects to analyse or predict behaviour, preferences, or characteristics, other than on the basis of an appropriate legal basis under UK data protection law and, where profiling is not necessary for the performance of a contract or a legal obligation, your consent.

AI-Generated Media

We may in the future use AI-generated or AI-assisted media, including images, video, avatars, and synthetic voices, including a synthetic voice for audiobook narration. Where we do so, and where required by Article 50(2) or Article 50(4) of the EU Artificial Intelligence Act or by other applicable law, we will mark or label such AI-generated media as artificially generated or manipulated, in a manner appropriate to the medium. Consistent with current regulatory practice, this Statement discloses our use of AI in general terms; a specific, item-level disclosure is applied to AI-generated media (such as images, video, avatars, and synthetic voice) rather than to routine AI-assisted text such as drafting support or template messaging, save where item-level disclosure of text content is separately required by law, for example in relation to synthetic text on matters of public interest.

Human Oversight

A human remains responsible for reviewing and approving AI-assisted content and messaging strategies used across our Services, and for monitoring the performance and appropriateness of AI tools used within Captivation Hub.

Updates to This Statement

We will review and, where necessary, update this Statement as the UK's AI regulatory framework develops, including in response to further guidance from the Information Commissioner's Office, sector regulators, or new legislation, and as the EU Artificial Intelligence Act's phased obligations, including those applicable from 2 August 2026, come into effect.