ACCEPTABLE USE POLICY

Last Updated: 18/May/2025 19:57

1. INTRODUCTION

1.1 Purpose and Scope. This Acceptable Use Policy (“Policy”) governs your use of Innovatica Technologies FZ-LLC’s (“Innovatica,” “we,” “our,” or “us”) Brilio platform, including all related services, features, applications, and content (collectively, the “Platform”). The Brilio platform is a multi-functional data and AI platform that enables users to create, maintain, host, and monetize AI Agents.

This Policy is incorporated by reference into the Brilio Master Terms of Service (“ToS”) and forms a binding legal agreement between you and Innovatica. Capitalized terms used but not defined in this Policy have the meanings given to them in the ToS.

1.2 Changes to this Policy. We may update this Policy from time to time. If we make material changes, we will provide notice in accordance with Section 16.2 of the ToS. Your continued use of the Platform after such notice constitutes your acceptance of the revised Policy.

1.3 Related Policies. This Policy should be read in conjunction with our other policies and agreements, including but not limited to:

1. Master Terms of Service
2. Privacy Policy
3. Agent Content Guidelines
4. Data Processing Agreement
5. AI Ethics and Responsible Use Policy

2. USER CONDUCT REQUIREMENTS

2.1 General Standards of Conduct. When using the Platform, you must:

1. Comply with all applicable laws, regulations, and third-party rights;
2. Use the Platform only for lawful purposes and in accordance with this Policy and our ToS;
3. Provide accurate information when creating your account and maintain the security of your account credentials;
4. Respect the intellectual property, privacy, and other rights of Innovatica and third parties;
5. Act with integrity and respect toward other users, Innovatica’s staff, and third parties;
6. Ensure that all data you upload to the Platform is lawfully obtained and that you have all necessary rights, licenses, and permissions to use, process, and share such data with us and through the Platform;
7. Implement reasonable and appropriate measures to secure your account, AI Agents, and any data you process through the Platform; and
8. Report any security vulnerabilities, violations of this Policy, or other issues in accordance with Section 7 of this Policy.

2.2 Platform Agent Creator Responsibilities. If you create AI Agents on the Platform, you must:

1. Ensure your Agent complies with the Agent Content Guidelines;
2. Take responsibility for your Agent’s name, description, and knowledge base;
3. Set appropriate age restrictions for your Agent;
4. Verify you have necessary permissions to use any data fed into your Agent;
5. Monitor your Agent’s performance and user feedback;
6. Maintain your Agent to ensure it functions properly and remains compliant with Platform policies;
7. Accept full responsibility for any content created by your Agent, as outlined in the Master Terms of Service and Agent Creator Agreement;
8. Implement appropriate measures to prevent misuse of your Agent;
9. Implement appropriate technical and organizational measures to ensure your Agent complies with applicable data protection laws when processing personal data.

3. PROHIBITED USES

3.1 Illegal Activities. You must not use the Platform to:

1. Violate any applicable laws, regulations, or third-party rights;
2. Engage in, promote, or facilitate criminal activity;
3. Circumvent or violate sanctions, export control laws, or trade restrictions;
4. Engage in tax evasion, fraud, or other financial crimes;
5. Access, use, or distribute child sexual abuse material (CSAM), or create Agents that sexualize, groom, abuse, or otherwise harm children;
6. Infringe upon intellectual property rights, including copyright, trademark, patent, trade secret, or other proprietary rights;
7. Violate privacy or data protection laws; or
8. Engage in activities that would breach your agreements with us or with third parties.

3.2 Harmful or Prohibited Content. You must not create, upload, store, or distribute through the Platform:

1. Content that promotes or glorifies terrorism, violent extremism, or hate groups;
2. Content that promotes self-harm, suicide, or eating disorders;
3. Content containing non-consensual intimate imagery or deep fake pornography;
4. Content that harasses, bullies, or threatens others;
5. Content that promotes discrimination, hatred, or violence based on race, ethnicity, gender, gender identity, religion, sexual orientation, disability, age, nationality, or any other legally protected characteristic;
6. Content containing excessive violence or cruelty;
7. Content that includes malware, viruses, or harmful code;
8. Spam, scams, or phishing content;
9. Content that misrepresents your identity or affiliation; or
10. False or misleading information that could cause public harm, including health or election misinformation.

3.3 Security and Integrity Violations. You must not:

1. Attempt to gain unauthorized access to the Platform, other user accounts, or related systems or networks;
2. Conduct security testing, vulnerability scanning, or penetration testing on the Platform without explicit written permission from Innovatica;
3. Interfere with, disrupt, or place an unreasonable load on the Platform or its connected networks;
4. Circumvent any rate-limiting systems, access controls, or security features;
5. Use any automated process or service to access or use the Platform (such as bots, scrapers, or spiders) except as permitted through our official API documentation;
6. Distribute login credentials or access tokens for the Platform;
7. Manipulate identifiers or headers to disguise the origin of content submitted to the Platform;
8. Submit false reports of abuse or misconduct;
9. Use the Platform to attempt to bypass or circumvent any content filters, security measures, or moderation systems;

3.4 Misuse of Platform Resources. You must not:

1. Use the Platform in a manner that could damage, disable, overburden, or impair the Platform or interfere with others’ use of the Platform;
2. Use Platform resources in an unintended way, affecting stability, performance, or security;
3. Exploit vulnerabilities in the Platform or external services connected to the Platform;
4. Exceed API usage limits and rate restrictions (as specified in the API Terms of Use);
5. Resell access to the Platform without appropriate authorization; or
6. Use the Platform primarily to compile data for a competing service.

3.5 Agent-Specific Prohibitions. When creating or using AI Agents, you must not:

3. Create Agents that deliberately generate prohibited content as described in Section 3.2;
4. Create Agents designed to bypass Platform safeguards or content filters;
5. Create Agents with names, descriptions, or functionalities that infringe on trademarks or impersonate individuals or organizations without authorization;
6. Create Agents that promote, facilitate, or engage in any Prohibited Uses as outlined in this Policy;
7. Create Agents that intentionally spread misinformation or disinformation;
8. Use Agents to automate activities that violate our Terms of Service or this Policy; or
9. Misrepresent an Agent’s capabilities or purpose to users.

4. AGE-APPROPRIATE USAGE

4.1 Age Restrictions. While the Brilio Platform has a general audience rating (4+), certain Agents may have specific age restrictions set by their creators based on content and functionality.

1. Agent creators are responsible for setting appropriate age restrictions for their Agents based on content and functionality.
2. Parents and guardians should supervise minors’ use of the Platform.
3. Users must respect the age restrictions specified for individual Agents.

4.2. Child Safety:

1. All users must comply with our Child Safety Policy, which is incorporated by reference herein.
2. Content aimed at or likely to be accessed by children must be appropriate for their age group.
3. Collection and processing of data from children must comply with applicable laws, including COPPA, GDPR-K, and other relevant regulations.
4. Any violations of child safety measures should be reported immediately through our reporting mechanisms.
5. We reserve the right to suspend or terminate any Agent or account that we reasonably believe poses a risk to child safety or violates applicable child protection laws.

5. MONITORING AND ENFORCEMENT

5.1 Monitoring Authority:

1. We reserve the right, but do not assume the obligation, to monitor the Platform for compliance with this Policy.
2. We may use automated systems and human review to detect violations of this Policy.
3. We respect user privacy and will conduct monitoring in accordance with our Privacy Policy and applicable laws.

5.2 Enforcement Actions. If we determine, in our sole discretion, that you have violated this Policy, we may take any of the following actions:

1. Issue a warning;
2. Temporarily suspend your access to the Platform;
3. Permanently terminate your access to the Platform;
4. Remove or disable access to content that violates this Policy;
5. Suspend or terminate specific Agents;
6. Report the violation to law enforcement or appropriate regulatory authorities;
7. Take legal action against you; or
8. Any combination of the above actions.
9. Implement additional monitoring or restrictions on your account or Agents.

5.3 Factors Considered in Enforcement. In determining the appropriate enforcement action, we may consider:

1. The nature and severity of the violation;
2. Your history of previous violations;
3. The impact of the violation on other users, third parties, or the Platform;
4. Whether the violation was intentional or accidental;
5. Your cooperation and responsiveness in addressing the violation; and
6. Legal or regulatory requirements.

6. CONSEQUENCES OF POLICY VIOLATIONS

6.1 Account and Agent Suspension or Termination:

1. Accounts may be suspended if they violate this Policy, with suspension lasting up to 30 days depending on the severity of the violation.
2. Accounts may be permanently terminated for serious or repeated violations.
3. AI Agents may be suspended or removed independently of account actions if they violate this Policy.
4. During a suspension period, you may have limited or no access to your account, Agents, or related data.

6.2 Data Retention After Termination:

1. If your account is terminated for policy violations, we will handle your data in accordance with our Data Retention and Deletion Policy, which is incorporated by reference herein.
2. We may preserve your data if required by law or for legitimate business purposes, such as investigating violations, preventing abuse, or protecting our legal rights.

6.3 Financial Consequences:

1. Subscription fees and Top-up credits will not be refunded if your account is suspended or terminated due to policy violations.
2. Revenue from paid Agents may be withheld or forfeited in cases where the Agent violates this Policy.
3. You may be liable for costs we incur as a result of your violations, as specified in the ToS.

6.4 Third-Party Claims. You agree to indemnify and hold Innovatica harmless from any claims, damages, liabilities, costs, and expenses (including reasonable attorneys’ fees) arising from your violation of this Policy, as detailed in the indemnification provisions of the ToS.

7. REPORTING VIOLATIONS

7.1 Reporting Mechanisms. You can report violations of this Policy through the following channels:

1. In-platform reporting: Use the “Report” feature available within the Platform interface;
2. Email: Send details of the violation to support@innovatica.ai;
3. Contact form: Submit a report through the contact form available at brilio.ai/report; or
4. For urgent or serious matters: Contact us at +971 509 083 742.

7.2 Required Information. When reporting a violation, please provide:

1. A detailed description of the violation;
2. The date and time of the violation;
3. The name of the user or Agent involved;
4. URLs, screenshots, or other evidence of the violation, if available;
5. Any additional context that may help us understand and address the violation; and
6. Your contact information (unless reporting anonymously).

7.3 Response Time:

1. We aim to acknowledge reports within 24 hours.
2. Reports will be investigated and acted upon within 72 hours, as specified in the Platform information.
3. Complex cases may require additional time for investigation and resolution.
4. We may contact you for additional information if needed.

7.4 Confidentiality of Reports:

1. We will maintain the confidentiality of reports to the extent possible.
2. Anonymous reports are accepted, though our ability to investigate may be limited without contact information.
3. We may be required to disclose information about reports in response to legal processes or as needed to investigate and address the reported violation.

8. APPEAL PROCESS

8.1 Right to Appeal. You have the right to appeal enforcement actions taken under this Policy, including account or Agent suspension or termination.

8.2 Appeal Procedure. To appeal an enforcement action:

1. Submit your appeal within 14 days of the enforcement action through our designated appeal channel at brilio.ai/appeal;
2. Include your account information, details of the enforcement action, and the basis for your appeal;
3. Provide any relevant evidence or information that supports your appeal; and
4. Cooperate with any additional requests for information during the appeal review process.

8.3 Appeal Review:

1. Appeals will be reviewed by a team member not involved in the original enforcement decision.
2. We aim to complete the appeal review within 10 business days.
3. The appeal decision will be communicated to you via the email associated with your account.
4. Appeal decisions are final unless new material information becomes available.

9. SECURITY AND INTEGRITY PROTECTION MEASURES

9.1 Account Security Requirements. To maintain the security and integrity of the Platform, you must:

1. Use strong, unique passwords for your account;
2. Enable multi-factor authentication when available;
3. Keep your account credentials confidential;
4. Log out from shared devices;
5. Promptly notify us of any unauthorized access to your account; and
6. Update contact information to ensure you receive security notifications.

9.2 Agent Security Requirements. When creating and managing Agents, you must:

1. Implement appropriate controls to prevent your Agent from being used for prohibited purposes;
2. Regularly review your Agent’s functionality and user interactions;
3. Implement rate limits and other measures to prevent abuse of your Agent;
4. Promptly address security vulnerabilities in your Agent; and
5. Keep your Agent’s knowledge base and training data secure.

9.3 Data Security Requirements. When uploading or processing data through the Platform, you must:

1. Ensure you have appropriate rights to use the data;
2. Follow security best practices for sensitive data;
3. Not intentionally submit malformed data that could compromise the Platform;
4. Report any data breaches or security incidents promptly;
5. Comply with the Data Security requirements specified in the Security Policy;
6. Implement appropriate safeguards when processing special categories of personal data (as defined under GDPR) or sensitive personal information (as defined under CCPA/CPRA), including obtaining explicit consent where required by law.

10. COMPLIANCE WITH LAWS

10.1 General Compliance. You are responsible for ensuring that your use of the Platform complies with all applicable laws, regulations, and industry standards.

10.2 Data Protection Laws. You must comply with applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other relevant privacy regulations when collecting, processing, or storing personal data through the Platform. Where you act as a data controller (as defined under GDPR) or business (as defined under CCPA/CPRA), you are responsible for providing appropriate privacy notices and obtaining necessary consents from data subjects.

10.3 Export Control Laws. You must comply with all applicable export control laws and sanctions, as further detailed in our Export Compliance Policy.

10.4 Intellectual Property Laws. You must respect intellectual property rights and comply with copyright, trademark, patent, and other intellectual property laws when using the Platform.

10.5 Industry-Specific Regulations. If you use the Platform in a regulated industry (such as healthcare, finance, or education), you must comply with industry-specific regulations and standards applicable to your use case.

11. CROSS-BORDER DATA TRANSFERS

When processing personal data that originated from the European Economic Area (EEA), United Kingdom, Switzerland, or other jurisdictions with data localization requirements, we and you will comply with applicable data transfer mechanisms, including but not limited to the use of Standard Contractual Clauses, adequacy decisions, Binding Corporate Rules, or other approved transfer mechanisms as may be required under applicable data protection laws. You acknowledge that, by using the Platform, your data may be transferred to and processed in jurisdictions outside your country of residence, including the United Arab Emirates.

12. USER REPRESENTATIONS AND WARRANTIES

By using the Platform, you represent and warrant that:

1. You have the legal capacity and authority to enter into and comply with this Policy;
2. You will use the Platform in accordance with all applicable laws, regulations, and this Policy;
3. All information you provide in connection with the Platform is accurate, complete, and current;
4. You have obtained all necessary rights, permissions, and consents to share any data, content, or information with us through the Platform; and
5. Your use of the Platform will not infringe, misappropriate, or violate any third party’s rights or cause us to violate any applicable laws or regulations.

13. SURVIVAL

The following provisions will survive the termination or expiration of your relationship with us: Sections 6 (Consequences of Policy Violations), 8 (Appeal Process), 10 (Compliance with Laws), 11.4 (Governing Law and Jurisdiction), 13 (User Representations and Warranties), and this Section 14 (Survival).

14. INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Innovatica Technologies FZ-LLC, its affiliates, officers, directors, employees, agents, licensors, and service providers from and against any claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to your violation of this Policy or your use of the Platform, including, but not limited to, your Agent content, any use of the Platform’s content, services, and products other than as expressly authorized, or your use of any information obtained from the Platform.

15. MISCELLANEOUS

15.1 No Waiver. Our failure to enforce any provision of this Policy shall not constitute a waiver of such provision or any other provision.

15.2 Severability. If any provision of this Policy is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary so that this Policy shall otherwise remain in full force and effect.

15.3 Assignment. We may assign this Policy, in whole or in part, at any time without notice to you. You may not assign this Policy or transfer any rights to use the Platform without our written consent.

15.4 Governing Law and Jurisdiction. This Policy shall be governed by the laws of the United Arab Emirates without giving effect to any conflicts of law principles. Any disputes arising from or relating to this Policy shall be resolved in accordance with the dispute resolution provisions in Section 14 of the ToS.

15.5 Contact Information. If you have questions about this Policy, please contact us at:

Innovatica Technologies FZ-LLC
Address: VUNE0632, Compass Building – Al Hulaila, Al Hulaila Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates
Email: info@innovatica.ai
Phone: +971 509 083 742
Website: https://innovatica.ai/

By using the Brilio Platform, you acknowledge that you have read, understood, and agree to be bound by this Acceptable Use Policy.

AGENT CONTENT GUIDELINES

Last Updated: 11/May/2025 12:32

1. INTRODUCTION

1.1 Purpose and Scope

These Agent Content Guidelines (“Guidelines”) establish legally binding requirements for the creation, publication, and operation of AI Agents on the Brilio platform (“Platform”) operated by Innovatica Technologies FZ-LLC (“Innovatica,” “we,” “us,” or “our”). These Guidelines form an integral part of the Agent Creator Agreement and constitute enforceable terms governing all Agent-related activities.

1.2 Legal Framework Integration

These Guidelines are incorporated by reference into our comprehensive legal framework, including:

• Master Terms of Service (governing document)
• Agent Creator Agreement (specialized terms)
• AI Ethics and Responsible Use Policy (ethical standards)
• Acceptable Use Policy (platform-wide restrictions)
• DMCA Copyright Policy (intellectual property)

In case of conflict, the Master Terms of Service prevails, followed by the Agent Creator Agreement, then these Guidelines.

1.3 Regulatory Compliance

These Guidelines ensure compliance with applicable global regulations, including:

• EU AI Act (Regulation 2024/1689) and Digital Services Act
• UK AI regulatory framework and Online Safety Act
• US state AI laws (California SB 942, Colorado AI Act)
• UAE Federal Decree-Law No. 34 of 2021 on Combatting Rumors and Cybercrimes
• China’s AI regulation framework and content restrictions

1.4 Modifications and Updates

Innovatica reserves the right to modify these Guidelines with 30 days’ advance notice for material changes, except for emergency modifications required by law or to address imminent safety risks.

2. MANDATORY CONTENT STANDARDS

2.1 Universal Requirements

All Agents created on the Platform must:

• Provide accurate, truthful, and non-misleading information with clear source attribution
• Serve legitimate, lawful purposes as defined under applicable law
• Clearly communicate capabilities, limitations, and intended use cases to users
• Comply with all applicable laws in jurisdictions where the Agent is accessible
• Respect intellectual property rights through proper licensing and attribution
• Maintain professional standards appropriate for the target audience
• Implement automated content authenticity verification where technically feasible
• Comply with AI transparency requirements under EU AI Act, UK AI White Paper, and similar regulations
• Maintain comprehensive audit trails for all Agent decisions and content generation activities

2.2 Transparency and Disclosure Requirements

Agent Creators must:

• Provide comprehensive Agent descriptions including purpose, capabilities, limitations, and data sources
• Disclose training data sources with appropriate anonymization to protect proprietary information
• Clearly indicate the Agent’s intended purpose (entertainment, information, professional use)
• Identify known biases or limitations that may affect outputs
• Disclose commercial affiliations or sponsorships that may influence Agent responses
• Implement clear AI identification ensuring users understand they are interacting with artificial intelligence
• Provide contact information for Agent-related inquiries and complaints

2.3 Quality and Performance Standards

Agents must demonstrate:

• Consistent performance within their designated domain and use cases
• Coherent, relevant responses appropriate to user queries and context
• Appropriate error handling for queries outside the Agent’s scope
• Bias detection and mitigation mechanisms with regular fairness auditing
• Regular maintenance and updates to ensure continued compliance and performance
• User feedback integration for continuous improvement

3. PROHIBITED CONTENT AND ACTIVITIES

3.1 Illegal Activities and Content

Agents are strictly prohibited from:

• Facilitating or promoting illegal activities under any applicable jurisdiction
• Circumventing legal protections or regulatory compliance requirements
• Violating export control regulations or international sanctions
• Enabling financial crimes including money laundering or terrorist financing
• Generating or distributing child sexual abuse material (CSAM)
• Creating content that violates intellectual property rights without proper authorization

3.2 Harmful and Dangerous Content

Agents must not generate, facilitate, or promote:

• Violence, terrorism, or extreme harm against individuals or groups
• Discrimination or hate speech based on protected characteristics
• Non-consensual intimate imagery or privacy violations
• Self-harm, suicide, or eating disorders without appropriate safeguards and resources
• Harassment, bullying, or intimidation in any form
• Malware, phishing, or cyberattacks or instructions for such activities

3.3 Deceptive and Fraudulent Content

Agents are prohibited from:

• Impersonating individuals or organizations without explicit authorization
• Spreading misinformation or disinformation that could cause public harm
• Generating deepfakes or synthetic media designed to deceive or manipulate
• Facilitating market manipulation or fraudulent business practices
• Enabling academic dishonesty or credential fraud

3.4 Biometric and Sensitive Personal Data

Agents must not:

• Process biometric identifiers without explicit consent and lawful basis under GDPR Article 9
• Generate synthetic biometric data for impersonation purposes
• Store or transmit biometric templates or raw biometric data
• Use biometric data for automated decision-making without human oversight and appropriate safeguards

3.5 Automated Decision-Making Restrictions

Agents making automated decisions with legal or similarly significant effects must:

• Provide explicit notice of automated decision-making to affected users
• Offer meaningful human review processes as required by GDPR Article 22
• Implement bias testing and fairness monitoring for all automated decisions
• Maintain comprehensive decision logs for regulatory compliance and audit purposes

3.6 Content Authenticity and Deepfake Prevention

Agent Creators must:

• Implement content provenance tracking where technically feasible
• Clearly label synthetic or AI-generated content as required by applicable transparency laws
• Prohibit generation of non-consensual intimate imagery or deepfakes of real persons
• Comply with content authenticity standards (e.g., C2PA, Adobe CAI)
• Implement technical measures to prevent misuse for identity impersonation

4. COMPLIANCE VERIFICATION AND REVIEW

4.1 Mandatory Pre-Publication Review

All public Agents must successfully complete:

• Automated compliance scanning for prohibited content and security vulnerabilities
• Content standards verification against these Guidelines and applicable laws
• Performance and functionality testing to ensure Agent operates as described
• Bias and fairness assessment using established evaluation frameworks

4.2 EU AI Act Compliance Review

For Agents accessible to EU users:

• High-risk AI system classification assessment and documentation
• Conformity assessment procedures where required under the AI Act
• Risk management system implementation with documented mitigation measures
• Quality management system establishment and maintenance

4.3 Ongoing Monitoring and Maintenance

Approved Agents are subject to:

• Periodic automated compliance checks using advanced detection systems
• Random manual spot-checks by qualified content moderation teams
• User feedback analysis and complaint investigation procedures
• Performance monitoring for quality degradation or compliance drift

4.4 Review Timelines and Communication

• Initial reviews completed within 72 hours of submission
• Complex or sensitive domain reviews may require up to 10 business days
• Emergency safety reviews prioritized for immediate processing
• Agent Creators notified of all review outcomes with detailed feedback

4.5 Appeals and Remediation Process

If an Agent is rejected or flagged:

• Detailed violation explanation provided to Agent Creator
• Remediation guidance offered for compliance achievement
• Appeal mechanism available through senior review team
• Timeline for resolution communicated clearly to all parties

5. INDUSTRY-SPECIFIC REQUIREMENTS

5.1 Healthcare and Medical Information

Agents providing health-related information must:

• Display prominent regulatory disclaimers compliant with FDA, EMA, and UAE health authority requirements
• Include mandatory safety statements: “This Agent is not a medical device and has not been evaluated by regulatory authorities. Information provided is for educational purposes only and is not intended to diagnose, treat, cure, or prevent any disease.”
• Implement safeguards preventing generation of personalized medical advice
• Comply with health data regulations including HIPAA, GDPR health provisions, and regional requirements
• Maintain interaction logs for regulatory compliance and safety monitoring
• Direct users to emergency services when appropriate safety triggers are detected

5.2 Financial Services and Investment

Agents in the financial domain must:

• Comply with financial regulations including SEC, FINRA, FCA, DFSA, and CBI requirements
• Implement KYC and AML compliance measures where applicable
• Distinguish clearly between factual information and investment advice
• Include mandatory risk disclosures: “Investment advice requires proper licensing. Past performance does not guarantee future results. Consult qualified financial professionals before making investment decisions.”
• Maintain comprehensive audit trails for all financial recommendations
• Comply with market manipulation and insider trading restrictions

5.3 Legal Information and Services

Agents providing legal information must:

• Clearly state limitations: “This Agent provides legal information, not legal advice, and does not create an attorney-client relationship.”
• Specify jurisdictional scope and applicable legal frameworks
• Avoid language that could create professional relationships or liability
• Present balanced information without advocating for specific legal strategies
• Direct users to qualified legal professionals for specific legal matters
• Maintain current information on relevant laws and regulations

5.4 Educational Content and Services

Agents designed for educational purposes must:

• Align with recognized educational standards appropriate to target audience
• Present information using pedagogically sound methodologies
• Provide balanced perspectives on controversial or disputed topics
• Cite authoritative sources for factual content and claims
• Adapt content delivery to different learning styles and accessibility needs
• Include age-appropriate safeguards for younger users

5.5 Government and Public Sector

Agents created for government or public sector use must:

• Maintain strict political neutrality in all communications
• Present policy information accurately without partisan interpretation
• Distinguish clearly between official government positions and general information
• Comply with accessibility standards (WCAG 2.1 AA or equivalent)
• Provide transparent sourcing for all claims and recommendations

6. SPECIALIZED DISCLOSURE REQUIREMENTS

6.1 High-Risk AI Systems

Agents classified as high-risk under applicable regulations must:

• Implement human oversight mechanisms for critical decisions
• Provide clear explanations of automated decision-making processes
• Maintain detailed logs of all system interactions and decisions
• Undergo regular third-party audits for bias, fairness, and safety
• Establish clear accountability chains for system outputs and decisions

6.2 Agents for Vulnerable Populations

Agents designed for or likely to be accessed by vulnerable populations must:

• Implement enhanced age verification and parental controls
• Use simplified, accessible language appropriate for the target audience
• Include additional safeguards against manipulation or exploitation
• Provide clear paths to human support and assistance
• Comply with child protection laws including COPPA, GDPR-K, and regional equivalents

6.3 Commercial and Advertising Content

Agents with commercial purposes must:

• Clearly disclose commercial relationships and sponsorships
• Distinguish between editorial content and promotional material
• Comply with advertising standards including truth-in-advertising laws
• Provide clear opt-out mechanisms for promotional communications
• Respect user privacy preferences regarding commercial interactions

7. CROSS-BORDER COMPLIANCE

7.1 Multi-Jurisdictional Requirements

Agent Creators must ensure compliance with laws in all accessible jurisdictions:

• EU regulations: AI Act, Digital Services Act, GDPR
• UK frameworks: AI regulatory approach, Online Safety Act
• US state laws: California AI transparency, Colorado AI Act
• UAE regulations: Cybercrime laws, data protection requirements
• Other jurisdictions: As applicable based on Agent accessibility

7.2 Geographic Access Controls

Agent Creators may implement geoblocking when:

• Required by local law to comply with content restrictions
• Necessary for regulatory compliance in specific jurisdictions
• Technically feasible and proportionate to compliance needs
• Clearly communicated to affected users with alternative options

7.3 Content Localization

For Agents serving multiple jurisdictions:

• Implement jurisdiction-specific content filtering where required
• Provide appropriate language localization for accessibility
• Adapt cultural content to local norms and sensitivities
• Maintain compliance documentation for each jurisdiction served

8. ENFORCEMENT AND SANCTIONS

8.1 Violation Response Framework

Content violations are addressed through graduated enforcement:

• Level 1 – Warning: First-time minor violations with remediation guidance
• Level 2 – Suspension: Temporary Agent suspension pending compliance
• Level 3 – Removal: Permanent Agent removal for serious or repeated violations
• Level 4 – Account Action: Account suspension or termination for egregious violations

8.2 Emergency Response Procedures

For content posing imminent harm:

• Immediate suspension within 15 minutes of verified threat
• Law enforcement notification for criminal content as required by law
• User safety measures including warnings and resource provision
• Post-incident analysis and prevention measure implementation

8.3 User Reporting and Investigation

Violation reports are processed as follows:

• Acknowledgment within 24 hours of receipt
• Investigation completed within 72 hours for standard cases
• Priority processing for safety-critical reports
• Outcome communication to reporters and Agent Creators

8.4 Appeals Process

Agent Creators may appeal enforcement actions by:

• Submitting appeals within 14 days of action notification
• Providing detailed justification and remediation plans
• Participating in review process with senior moderation team
• Receiving final determination within 10 business days

9. TECHNICAL STANDARDS AND SECURITY

9.1 Data Security Requirements

Agent Creators must implement:

• End-to-end encryption for sensitive data processing
• Access controls limiting data access to authorized personnel
• Audit logging for all data access and processing activities
• Regular security assessments and vulnerability management
• Incident response procedures for security breaches

9.2 Performance and Reliability Standards

Agents must maintain:

• Consistent response quality across different user interactions
• Appropriate response times for user queries and requests
• Error handling mechanisms for system failures or unexpected inputs
• Scalability measures to handle varying user loads
• Monitoring systems for performance degradation detection

9.3 Integration and Compatibility

Agents must:

• Follow platform API standards for consistent integration
• Maintain compatibility with platform updates and changes
• Implement standard protocols for data exchange and communication
• Support accessibility features for users with disabilities
• Provide clear documentation for technical specifications

10. MONITORING AND CONTINUOUS IMPROVEMENT

10.1 Performance Metrics and Evaluation

Agent performance is assessed using:

• User satisfaction scores and feedback analysis
• Accuracy measurements for factual content and responses
• Bias detection metrics across different demographic groups
• Safety incident tracking and resolution effectiveness
• Compliance audit results and remediation success rates

10.2 Regular Assessment and Updates

Innovatica conducts:

• Quarterly compliance reviews of all active Agents
• Annual comprehensive assessments including third-party audits
• Continuous monitoring using automated detection systems
• User feedback integration for guideline improvements
• Regulatory tracking for emerging compliance requirements

10.3 Industry Collaboration and Standards

Innovatica participates in:

• Industry working groups for AI safety and ethics
• Standards development organizations for technical specifications
• Regulatory consultation processes for policy development
• Academic research collaboration for safety and fairness advancement
• Cross-industry sharing of best practices and lessons learned

11. CONTACT AND SUPPORT

11.1 Guidelines Questions and Clarification

For questions regarding these Guidelines:

• Email: compliance@innovatica.ai
• Response time: 3 business days for standard inquiries
• Priority support: Available for compliance-critical issues
• Documentation: Additional guidance available at brilio.ai/agent-guidelines

11.2 Violation Reporting

To report potential violations:

• Platform reporting tool: Available within each Agent interface
• Email: violations@innovatica.ai
• Emergency hotline: +971 509 083 742 (for imminent safety threats)
• Anonymous reporting: Supported through web portal

11.3 Technical Support and Assistance

For implementation support:

• Technical documentation: Available at docs.brilio.ai
• Developer support: support@innovatica.ai
• Training resources: Including webinars and best practice guides
• Consultation services: Available for complex compliance scenarios

12. LEGAL PROVISIONS

12.1 Governing Law and Jurisdiction

These Guidelines are governed by UAE law, with mandatory local consumer protections applied where required. Disputes are resolved through binding ICC arbitration in Dubai, UAE, with individual claim requirements and 12-month limitation periods.

12.2 Compliance Documentation

Agent Creators must maintain:

• Implementation records for all guideline requirements
• Training documentation for relevant personnel
• Audit trails for compliance verification
• Incident reports and remediation activities
• Regular attestations of continued compliance

12.3 Indemnification and Liability

Agent Creators agree to indemnify Innovatica for claims arising from guideline violations, with liability limitations as specified in the Master Terms of Service.

 

Contact Information: Innovatica Technologies FZ-LLC

VUNE0632, Compass Building – Al Hulaila

Al Hulaila Industrial Zone-FZ

Ras Al Khaimah, United Arab Emirates

Email: compliance@innovatica.ai

Phone: +971 509 083 742

By creating or operating Agents on the Brilio platform, you acknowledge reading, understanding, and agreeing to comply with these Guidelines and accept full responsibility for ensuring your Agent’s compliance with all applicable laws and regulations.

DMCA COPYRIGHT POLICY

Last Updated: 19/May/2025 23:36

1. Introduction

This Digital Millennium Copyright Act (“DMCA”) Copyright Policy (“Policy”) is an integral part of Innovatica Technologies FZ-LLC’s (“Innovatica,” “we,” “us,” “our”) legal framework governing the use of the Brilio platform (“Brilio” or the “Platform”) and is incorporated by reference into our Terms of Service. This Policy outlines the procedures for reporting copyright infringement, submitting counter-notifications, and our approach to addressing copyright claims on the Platform.

Innovatica respects the intellectual property rights of others and expects users of our Platform to do the same. In accordance with our commitment to protecting intellectual property rights, we have established this Policy to address claims of copyright infringement on our Platform.

This Policy is incorporated by reference into our Terms of Service. Terms used but not defined in this Policy have the meanings provided in the Terms of Service.

2. Scope and Applicability

This Policy applies to all aspects of the Brilio platform, including but not limited to:

1. AI Agents created and published on the Platform
2. Content generated by or through these Agents
3. Knowledge bases, datasets, and other information uploaded to or stored on the Platform
4. Any other materials made available through the Platform

3. Designated Copyright Agent

As required by the DMCA, Innovatica has designated a Copyright Agent to receive notifications of alleged copyright infringement and to process these notifications in accordance with applicable laws and regulations. Our designated agent’s contact information is:

Designated Copyright Agent
Innovatica Technologies FZ-LLC
VUNE0632, Compass Building – Al Hulaila
Al Hulaila Industrial Zone-FZ
Ras Al Khaimah, United Arab Emirates
Email: copyright@innovatica.ai
Phone: +971 509 083 742

4. Copyright Infringement Reporting Procedure

If you are a copyright owner or authorized to act on behalf of one, and you believe that material on our Platform infringes your copyright, please follow these steps to submit a DMCA takedown notice. Failure to include all required elements may result in delayed processing or rejection of your notice.

4.1 Required Elements for Takedown Notices. For your notice to be effective and processed, it must include all of the following information:

1. Identification of the Copyrighted Work: A clear identification of the copyrighted work(s) you claim has been infringed. If multiple copyrighted works are covered by a single notification, a representative list of such works.
2. Identification of the Allegedly Infringing Material: A clear identification of the material you claim is infringing and sufficient information for us to locate it on the Platform (such as the URL, Agent ID, or other specific location where the material appears).
3. Contact Information: Your contact information, including your name, address, telephone number, and email address.
4. Statement of Good Faith Belief: A statement that you have a good faith belief that the use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law.
5. Statement of Accuracy: A statement that the information in the notification is accurate, and under penalty of perjury, that you are authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.
6. Electronic or Physical Signature: Your physical or electronic signature.

4.2 Submission Methods. You may submit your DMCA takedown notice through one of the following methods:

1. Email: Send your notice to our designated Copyright Agent at copyright@innovatica.ai with “DMCA Takedown Notice” in the subject line.
2. Mail: Send your notice to our physical address listed in Section 3 above.

5. Processing of DMCA Notices

5.1 Initial Review. Upon receipt of a properly submitted DMCA takedown notice, our Copyright Agent will:

1. Confirm receipt of your notice within one (1) business day.
2. Review the notice for compliance with the requirements outlined in Section 4.1.
3. If the notice is incomplete or does not substantially comply with the requirements, we will notify you of the deficiencies and provide an opportunity to submit a revised notice.

5.2 Action on Valid Notices. If your notice substantially complies with the requirements, we will:

1. Remove or disable access to the allegedly infringing material promptly, typically within 24-48 hours of receipt of a valid notice.
2. Make a reasonable attempt to notify the user who posted the material that it has been removed due to a claim of copyright infringement.
3. Provide the user with a copy of your takedown notice (with personal information redacted as appropriate) and information about the counter-notification process.

5.3 Timeline for Response. We strive to process all DMCA notices promptly. While actual processing times may vary based on complexity and volume, our typical response timeline is:

1. Confirmation of receipt: 1 business day;
2. Initial review of notice: 1-2 business days;
3. Action on valid notices: 1-2 business days;
4. Total resolution time: Typically within 2-4 business days from receipt of a valid notice.

These timeframes are provided as estimates only and do not constitute a binding obligation

6. Counter-Notification Process

If you believe that your content was removed or disabled by mistake or misidentification, you may submit a counter-notification.

6.1 Required Elements for Counter-Notifications. For your counter-notification to be effective and processed, it must include all of the following information:

1. Identification of Material: A clear identification of the material that has been removed or to which access has been disabled, and the location where the material appeared before it was removed or access to it was disabled.
2. Statement Under Penalty of Perjury: A statement under penalty of perjury that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled.
3. Consent to Jurisdiction: A statement that you consent to the jurisdiction of the Federal District Court for the judicial district in which your address is located, or if your address is outside of the United States, the United Arab Emirates courts, and that you will accept service of process from the person who provided the copyright infringement notification or an agent of such person.
4. Contact Information: Your name, address, telephone number, and email address.
5. Electronic or Physical Signature: Your physical or electronic signature.

6.2 Submission Methods. You may submit your counter-notification through one of the following methods:

1. Email: Send your counter-notification to our designated Copyright Agent at copyright@innovatica.ai with “DMCA Counter-Notification” in the subject line.
2. Mail: Send your counter-notification to our physical address listed in Section 3.

6.3 Processing of Counter-Notifications. Upon receipt of a valid counter-notification, we will:

1. Promptly provide the copyright owner who submitted the takedown notice with a copy of the counter-notification.
2. Inform the copyright owner that we will restore the removed material in 10 business days unless the copyright owner files an action seeking a court order to restrain the user from engaging in infringing activity relating to the material on our Platform.
3. Replace or cease disabling access to the material in 10-14 business days following receipt of the counter-notification, unless we first receive notice from the copyright owner that they have filed an action seeking a court order to restrain the user.

7. Repeat Infringer Policy

Innovatica maintains a strict policy for addressing repeat copyright infringers on the Brilio platform. This policy is designed to ensure that individuals who repeatedly infringe copyrights are appropriately restricted from using our services.

7.1 Definition of Repeat Infringer. A user may be deemed a “repeat infringer” if:

1. We receive multiple valid DMCA takedown notices for content posted by that user.
2. A court has determined that the user has infringed copyright through our Platform.
3. We otherwise determine, in our reasonable discretion, that a user is a repeat infringer.

7.2 Consequences for Repeat Infringers. We reserve the right to limit, suspend, or terminate the accounts or access privileges of users who are deemed repeat infringers. The specific actions taken will depend on various factors, including:

1. The number and frequency of valid DMCA notices received.
2. The user’s history of DMCA notices and counter-notifications.
3. The nature and severity of the infringement(s).
4. Whether the user is making good faith efforts to comply with copyright law.

7.3 Documentation and Record-Keeping. We will maintain appropriate records of DMCA notices, counter-notifications, and actions taken against repeat infringers for a minimum of three (3) years or as otherwise required by applicable law, whichever is longer.

8. Fair Use Considerations

8.1 Recognition of Fair Use Doctrine. We recognize that not all uses of copyrighted material constitute infringement. The “fair use” doctrine permits limited use of copyrighted material without authorization for purposes such as criticism, comment, news reporting, teaching, scholarship, or research.

8.2 Fair Use Analysis. In evaluating DMCA notices and counter-notifications, we may consider whether the use at issue potentially constitutes fair use under applicable law. However, complex fair use determinations are ultimately for courts to decide, and we reserve the right to process valid DMCA notices even where fair use is claimed, particularly in cases where the fair use determination requires complex legal analysis beyond our reasonable capabilities.

8.3 User Guidance. Users who believe their use of copyrighted material constitutes fair use should:

1. Consider whether their use truly qualifies as fair use under applicable law.
2. If their content is removed pursuant to a DMCA notice and they believe fair use applies, submit a counter-notification as described in Section 6.
3. Consult with a qualified attorney for specific legal advice regarding fair use.

9. Agent Creator Responsibilities

Agent creators on the Brilio platform are responsible for ensuring that their agents and the content they upload or make available through those agents comply with all applicable copyright laws.

9.1 Due Diligence Requirements. Agent creators must:

1. Ensure they have obtained all necessary permissions, licenses, or rights to use any copyrighted material incorporated into their agents or agent knowledge bases;
2. Comply with all applicable privacy laws and regulations if their agents process personal data;
3. Accept full responsibility and indemnify Innovatica for any costs, damages, or legal claims that arise from their use of third-party materials without necessary licenses or permissions, including but not limited to copyright infringement claims, legal fees, and settlement costs.

9.2 Licensing and Attribution. Agent creators should:

1. Properly license and attribute third-party content used in their agents.
2. Document the sources and licenses for content used in training or informing their agents.
3. Where appropriate, integrate attribution mechanisms into their agents’ responses when the agent references specific copyrighted works.

9.3 Monitoring and Compliance. Agent creators should implement reasonable measures to:

1. Monitor their agents for potential copyright issues.
2. Promptly address any copyright concerns that arise.
3. Cooperate with Innovatica in responding to copyright claims involving their agents.

10. Consequences for False Claims

10.1 Misrepresentations in DMCA Notices. Under the DMCA, any person who knowingly materially misrepresents that material or activity is infringing may be subject to liability for damages, including costs and attorneys’ fees incurred by the alleged infringer or by Innovatica.

10.2 Misrepresentations in Counter-Notifications. Similarly, any person who knowingly materially misrepresents that material or activity was removed or disabled by mistake or misidentification may be subject to liability for damages, including costs and attorneys’ fees incurred by the copyright owner or by Innovatica.

10.3 Platform-Specific Penalties. In addition to potential legal liability under the DMCA for knowingly materially misrepresenting that material or activity is infringing or was removed by mistake, users who submit false or frivolous copyright claims or counter-notifications may be subject to Platform-specific penalties at our sole discretion, including but not limited to:

1. Warnings and educational notices;
2. Temporary suspension of certain Platform privileges;
3. Permanent restriction from submitting DMCA notices or counter-notifications;
4. Account suspension or termination in severe or repeated cases;
5. Being held responsible for any damages, including legal fees, incurred by Innovatica, the alleged infringer, or affected third parties.

11. Modifications to Content

11.1 Content Modifications. Rather than removing content entirely, copyright owners may request that we:

1. Remove only the specific portion of content that infringes their copyright.
2. Modify the content to remove infringing elements while preserving non-infringing portions.
3. Add appropriate attribution or licensing information.

11.2 Process for Requesting Modifications. Copyright owners seeking content modifications rather than complete removal should:

4. Submit a standard DMCA notice as outlined in Section 4.
5. Clearly specify in the notice that they are requesting modification rather than removal.
6. Provide specific instructions regarding the modifications requested.

12. Third-Party Content and Embedded Materials

12.1 Content Responsibility. Innovatica bears no responsibility for any potential intellectual property breaches related to Agent content, as Agent creators are solely and fully responsible for any content, datasets, websites, or other knowledge sources used in or accessed through their agents. Agent creators shall defend, indemnify, and hold harmless Innovatica against any claims, damages, costs, and expenses (including reasonable attorneys’ fees) arising from any alleged intellectual property infringement related to their Agent’s content.

12.2 Embedded and Linked Content. DMCA notices regarding content that is merely linked to (rather than hosted on) our Platform may be processed differently, as we may not have control over such content. In such cases, we may:

1. Remove or disable the link to the allegedly infringing content.
2. Forward the notice to the linked site or service.
3. Take other appropriate action based on the specific circumstances.

13. International Considerations

13.1 Global Compliance. While this Policy is designed primarily to comply with the DMCA (a United States law), we respect copyright laws globally and will respond appropriately to copyright claims from rightsholders worldwide.

13.2 Governing Law. This Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates, without regard to its conflict of law provisions. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of the courts of Ras Al Khaimah, United Arab Emirates, except where prohibited by applicable mandatory law.

13.3 International Copyright Treaties. We acknowledge and respect international copyright treaties, including the Berne Convention and the WIPO Copyright Treaty, which establish minimum standards for copyright protection across participating countries.

14. AI-Generated Content Considerations

14.1 Special Considerations for AI-Generated Content. Given the nature of the Brilio platform and its AI Agents, special considerations apply to copyright claims involving AI-generated content:

1. Content generated by Agents (“Agent-Generated Content”) is the sole responsibility of the Agent creator. The Agent creator is exclusively liable for any misuse, intentional or unintentional wrong information, or potentially infringing content provided by their Agent. Neither Brilio nor Innovatica assumes any responsibility or liability for such Agent-Generated Content, provided that Innovatica has complied with its obligations under this Policy. Agent creators acknowledge that they retain all responsibilities related to Agent-Generated Content even in cases where the underlying AI models or platform functionalities contribute to the generation process.
2. When evaluating copyright claims involving AI-generated content, we will consider factors such as:

• The degree of human involvement in creating the content
• The nature and source of training data used
• Any applicable licenses or terms governing the use of training data
• Relevant legal precedents regarding AI-generated content

14.2 Training Data and Copyright. We recognize the evolving legal landscape regarding copyright and AI training data. In addressing copyright claims related to Agent training data:

1. Agent creators must ensure they have appropriate licensing agreements needed to use their training datasets.
2. These licensing agreements must cover the usage rights and limitations of that data.
3. When a valid copyright claim targets training data used by an Agent, we may require the Agent creator to remove or replace the disputed training data and retrain the Agent as appropriate.

15. Education and Awareness

15.1 User Education. We are committed to educating our users about copyright law and compliance. To this end, we:

1. Provide resources and guidelines on copyright best practices.
2. Maintain a Copyright FAQ section on our website.
3. Offer guidance specific to AI and copyright considerations.

15.2 Platform Features. We implement features to help users comply with copyright law, such as:

1. Tools to properly attribute content sources.
2. Mechanisms to review and manage the data sources used by Agents.
3. Templates for obtaining necessary permissions and licenses.

16. Relationship with Other Policies

This DMCA Copyright Policy should be read in conjunction with our other policies, including but not limited to:

1. Terms of Service
2. Privacy Policy
3. Acceptable Use Policy
4. Agent Content Guidelines
5. Intellectual Property License Agreement

In case of any conflict between this Policy and any other of our policies, the Terms of Service will prevail, followed by this Policy.

17. Contact Information

For questions about this Policy or copyright matters generally, please contact:

Legal Department
Innovatica Technologies FZ-LLC
VUNE0632, Compass Building – Al Hulaila
Al Hulaila Industrial Zone-FZ
Ras Al Khaimah, United Arab Emirates
Email: legal@innovatica.ai
Phone: +971 509 083 742

18. Effective Date and Updates

We reserve the right to modify this Policy at any time. We will provide notice of any material changes through the Platform or by other means. Your continued use of the Platform after such modifications constitutes your acceptance of the updated Policy.