AI Features Terms
IN FORCE. See 00-README. Governs CIQRA's AI-assisted features. Complements the ToS, Privacy Policy §4, DPA §13, and Acceptable Use Policy.
Legal basis. Every provision below rests on one of three things: a measured fact about the platform (cited to file and line), a rule of law (cited to the instrument and article in the Legal Basis Register), or a commercial choice CIQRA has made where the law leaves it open. Prepared and adopted by CIQRA OÜ.
Provider: CIQRA OÜ, Tallinn, Estonia · In force from: 2026-08-09 · Version: 1.0 · Adopted by: CIQRA OÜ
1. What the AI features are
CIQRA offers optional AI-assisted features — AI product-description/SEO generation, semantic search and recommendations, image generation/editing, and an AI assistant/copilot — delivered via third-party AI providers. Availability is plan-gated and features may change or be withdrawn (beta terms may apply).
Providers actually wired into the platform (measured 2026-08-09: ciqra-saas/src/modules/Ciqra.Modules.Ai/DependencyInjection/AiServiceCollectionExtensions.cs:92-102):
| Provider | Used for | Registration |
|---|---|---|
| Anthropic (Claude) | Text generation — platform default | :92 IAiChatClientFactory, AnthropicChatClientFactory |
| OpenAI | Text generation; embeddings | :93, :95 |
| Voyage AI | Embeddings — default embedding provider | :94 (https://api.voyageai.com/v1/embeddings, VoyageEmbeddingProvider.cs:11) |
| fal.ai | Image generation / editing | :96, :99, :102 |
🔴 Correction of an earlier internal version statement — no self-hosted AI gateway exists. An earlier internal version of this document and of the Subprocessor List stated that AI traffic is "accessed through a self-hosted AI gateway on CIQRA's Azure (Germany) infrastructure". That is not what the code does (measured 2026-08-09: AnthropicChatClientFactory.cs:30-40 constructs the official Anthropic SDK with a pooled HttpClient and calls the provider API directly; AiServiceCollectionExtensions.cs:77,87 set BaseAddress to the Voyage and fal.ai vendor endpoints). AI requests leave CIQRA's Azure Germany environment and go directly to the provider. This document and the Subprocessor List have been corrected. The practical consequence — that AI inference is a third-country transfer requiring Art. 46 safeguards rather than intra-EEA processing — is stated in §2.4 below and in the DPA.
🔴 Azure OpenAI is a decision, not a deployment. CIQRA has decided to move AI inference to Azure OpenAI (ciqra-openai-prod, germanywestcentral). As at 2026-08-09 that move has not been made: the identifier azure-openai exists in the codebase as a bare constant with no client factory, no HTTP client and no service registration (measured 2026-08-09: ciqra-saas/src/modules/Ciqra.Modules.Ai/Domain/AiVocabulary.cs:35 declares it; its only other occurrence is the All list at :45; grep -rn 'AzureOpenAi' src/ tests/ returns those two lines and nothing else). Until the migration ships, this document must continue to name Anthropic, OpenAI, Voyage and fal.ai as the live providers. Restating the intended end-state as the current state would misdescribe where personal data actually goes.
2. How your data is handled (data minimisation + no-training)
2.1 Minimisation. CIQRA sends AI providers only the input needed for the requested feature, and avoids sending personal data / PII except where strictly necessary and disclosed.
2.2 No training on your data; zero/limited retention. CIQRA uses AI providers under their business/commercial terms, under which customer content is not used to train the providers' models:
- Anthropic — under its Commercial Terms, does not train models on customer content; the customer owns outputs.
- OpenAI — by default does not train on business/API inputs or outputs; API data is retained only briefly (up to ~30 days) for abuse monitoring, with zero-data-retention options available.
- Voyage AI and fal.ai — engaged for embeddings and image generation respectively.
2.3 Executed provider terms.
CIQRA's determination: the statements in §2.2 describe each provider's publicly published business/commercial terms. CIQRA has not verified within this workstream that a signed Art. 28 DPA and an executed zero-retention / no-training commitment are on file for each of the four providers actually in use — including Voyage AI and fal.ai, which earlier internal versions of this document and of the Subprocessor List omitted entirely. Until each executed agreement is located and recorded, the no-training assurance in §2.2 rests on published vendor policy, not on a contract CIQRA can produce. This is an open item, not a completed control.
2.4 Third-country transfer. Because there is no gateway terminating AI traffic inside the EEA (§1), invoking an AI feature transfers the minimised input to the provider, and for these four providers that involves US processing. Art. 46 safeguards (SCCs) and a Transfer Impact Assessment are therefore required for the AI path specifically, not only for the payment path. See DPA §11 and Subprocessor List §4.
2.5 Roles. Where CIQRA acts as processor on Merchant data, these safeguards are mirrored in the DPA §13; the Merchant remains the controller and must not instruct AI processing of special-category or excessive personal data without its own lawful basis.
3. Transparency (EU AI Act Article 50)
3.1 Interaction disclosure. Where you (or a Storefront's shoppers) interact with an AI system (e.g. a chatbot), this is disclosed so it is clear you are dealing with AI, unless it is obvious from the context.
3.2 AI-generated content marking — mechanism present, with a stated limit. AI-generated or AI-manipulated content is marked in machine-readable form. What exists (measured 2026-08-09): generated image assets carry an IPTC Digital Source Type provenance marking — chosen deliberately over C2PA — (ciqra-saas/src/Ciqra.Api/Ai/AiProvenanceMetadata.cs:15-20); every generative operation stamps an ai:<operation> provenance tag on the produced asset (ImageStudioEndpoints.cs:332-333); and an AiDisclosureAck flag is recorded (ModelShotEndpoints.cs:303, migration 20260730004326_AiMarkingVerified).
Limit, in the code's own words (
ImageStudioEndpoints.cs:79-81): the platform "records provenance without being able to enforce a disclosure", because the surrounding merchant-facing copy is merchant-editable. CIQRA's determination: machine-readable marking of generated images is implemented; enforcement that a merchant does not strip or contradict the disclosure is not, and Art. 50(2) compliance therefore depends in part on merchant conduct governed by §4 and the AUP rather than on a platform control alone.
3.3 Timing. These obligations track the EU AI Act (Reg. (EU) 2024/1689) Art. 50, applicable from 2 August 2026. A provisional "Digital Omnibus" grace period may extend only the machine-readable marking duty (Art. 50(2)) to 2 December 2026 for generative-AI systems already on the market before 2 August 2026; the interaction-disclosure duty is not delayed.
CIQRA's determination: CIQRA plans to the 2 August 2026 baseline and does not rely on the Digital Omnibus grace period. The Omnibus text was at provisional agreement (07.05.2026) and not formally adopted as at this date; a compliance plan that assumed the deferral would be resting on an instrument that does not yet exist. This position must be revisited if and when the final text is adopted.
4. Your responsibilities & output use
4.1 Review before publishing. AI outputs can be inaccurate, biased, or incomplete. You are responsible for reviewing and verifying AI-assisted output before publishing or relying on it (e.g. product descriptions, translations, images).
4.2 Rights & lawful input. You must have the rights to any content you submit to AI features, and must not use them to generate illegal, infringing, deceptive, or harmful content, to produce unlabelled synthetic media where labelling is required, to impersonate, or to attempt to extract/reverse-engineer models or other tenants' data (see AUP §1). You must not remove, obscure or contradict the provenance marking described in §3.2.
4.3 Output ownership. As between CIQRA and you, you own the outputs you generate through the AI features (subject to third-party rights and provider terms), and you are responsible for their lawful use. AI output is provided "as is" with no warranty of accuracy or fitness.
5. Content safety & limits
CIQRA applies content-safety filtering to AI inputs/outputs and may block or limit AI usage that violates these terms, the AUP, provider policies, or law. AI features are not a substitute for professional (legal, medical, financial, tax) advice.
6. Changes
CIQRA may update these AI Terms, the providers used, and the features, on notice consistent with ToS §14; the Subprocessor List reflects current AI providers with change-notification. A provider migration — including the intended move to Azure OpenAI (§1) — is a subprocessor change and triggers the ≥30-day notice and objection right in DPA §5.
Provision register (this document)
| Provision | Basis | Where |
|---|---|---|
| / legend | Replaced by the marker scheme note in the header | header |
| — | (B) declared position — executed agreements not verified; two providers were missing from the list entirely | §2.3 |
| — | (B) declared position — plan to the 2 Aug 2026 baseline, do not rely on an unadopted instrument | §3.3 |
| (not previously flagged) | (A) measured — provider inventory; no AI gateway; Azure OpenAI inert | §1 |
| (not previously flagged) | (A) measured — Art. 50(2) marking mechanism exists, enforcement does not | §3.2 |
Carried into force? No. This document carries 2 measured facts requiring no further input and 3 declared positions (§2.3, §3.2 limit, §3.3). Per the gate in 00-README §6, the (A) items are closed; the (B) items may remain visible at launch but must be visible, not silent.
End of AI Terms . See: Privacy Policy §4 · DPA §13 · AUP · Subprocessor List.