AI Governance and Use Policy

About this Policy

Client Funnels Ltd Company No. 14135257 Registered in England and Wales

This policy explains how Client Funnels Ltd (“Client Funnels”, “we”, “us” or “our”) uses artificial intelligence (“AI”) within our business and in the work we carry out for clients.

Our approach is simple:

• AI can assist the work. It does not replace responsibility.

Humans remain responsible for the strategy, decisions and work delivered by Client Funnels.

1. Scope

This policy applies to the use of AI across Client Funnels, including within:

• consultancy;
• Done For You services;
• Done With You services;
• courses;
• workshops;
• training;
• marketing;
• sales;
• customer support;
• research;
• content creation;
• WhatsApp campaigns;
• conversational AI agents; and
• internal business operations.

It applies to employees, contractors, freelancers, agencies and technology providers working on our behalf.

For the purposes of this policy, AI includes generative AI, large language models, AI agents, machine learning systems, predictive systems, AI-assisted automation and similar technology.

2. How We Use AI

AI may be used to assist with work including:

• brainstorming;
• research support;
• analysing information;
• summarising meetings or transcripts;
• creating first drafts;
• content development;
• campaign planning;
• workflow automation;
• data organisation;
• customer support;
• conversational agents;
• lead qualification;
• campaign optimisation;
• testing ideas; and
• internal administration.

The use of AI does not remove our responsibility for the work we provide.

3. Human Oversight

AI may assist.

Humans remain accountable.

Where appropriate to the level of risk, Client Funnels will review AI-assisted work before it is used.

This includes particular care around:

• client strategy;
• public claims;
• sales messaging;
• factual statements;
• pricing;
• eligibility;
• reputational matters;
• customer complaints; and
• significant decisions affecting an individual.

Where we operate an AI-powered conversational agent, it may communicate automatically without each individual message being manually approved.

These systems should be designed, tested and monitored before and during use.

Where appropriate, people should be able to reach a human.

4. Decisions About People

Client Funnels does not currently use AI to make solely automated decisions about individuals which have legal or similarly significant effects on them.

AI may assist with:

• segmentation;
• lead qualification;
• prioritisation;
• scoring;
• suggested responses; or
• identifying possible next actions.

Where a decision could have a significant effect on someone, appropriate human involvement will be maintained unless another lawful process has been put in place.

5. Client Information and Confidentiality

Client confidentiality applies whether work is carried out by a person or with the assistance of AI.

Client Funnels will not knowingly upload confidential client information into an unapproved public AI service.

Where AI is used in connection with client information, we will take reasonable steps to:

• limit the information shared;
• use anonymised or reduced data where practical;
• use approved accounts and services;
• consider how the AI provider uses submitted information;
• review available retention and training settings;
• control access; and
• comply with applicable data-protection law.

Personal information must not be put into an unapproved AI service.

6. AI Model Training

We do not use confidential client information for the purpose of training our own public AI model.

We do not intentionally provide confidential client information to a third-party AI provider for the purpose of training its general AI models unless:

• the Client has agreed to this;
• there is another valid legal basis for doing so; and
• appropriate contractual and data-protection safeguards are in place.

Where available and suitable, we favour business AI services which provide controls over how submitted information is retained and used.

7. Client Data

Where personal information is processed using AI, the same data-protection standards apply as they would to any other processing.

Before introducing a new AI use involving personal data, we consider matters such as:

• why the information is being processed;
• the lawful basis;
• the minimum information required;
• security;
• retention;
• international transfers;
• the role of suppliers;
• possible harm to individuals; and
• whether a Data Protection Impact Assessment is required.

The ICO requires organisations using personal data in AI systems to be transparent about purposes, retention and sharing.

8. Client Customer Data

During Done For You, Done With You or consultancy work, a Client may provide Client Funnels with information about its customers, leads or prospects.

Where Client Funnels processes this information solely on the Client's instructions, the Client will normally remain the data controller and Client Funnels will act as processor.

The Client remains responsible for ensuring that:

• the information was collected lawfully;
• the Client is entitled to use it;
• appropriate marketing permissions exist;
• its privacy information is correct; and
• its instructions to Client Funnels are lawful.

The use of AI does not transfer those responsibilities from the Client to Client Funnels.

9. AI Agents and Chatbots

Client Funnels may build, configure or operate AI agents and conversational systems.

Where a person is interacting materially with an AI system rather than a human, we aim to make that clear where appropriate.

AI agents may:

• answer common questions;
• collect information;
• qualify leads;
• provide information supplied by the business;
• help people find relevant resources;
• suggest next steps;
• book or support appointments; and
• hand conversations to a human.

Clients remain responsible for approving the source information, offers, claims and commercial rules provided to an AI agent used for their business.

An AI agent should not be treated as a substitute for regulated legal, medical, financial or other professional advice.

10. Accuracy

AI can make mistakes.

It can misunderstand information, create incorrect information or present an answer confidently when it is wrong.

For this reason, AI-generated information is assessed according to its intended use and level of risk.

Important factual claims should be checked before publication or reliance.

We do not assume something is correct simply because an AI system generated it.

11. Marketing and Content

AI may assist us with marketing and content.

AI-assisted content remains subject to the same standards as human-created content.

We will not knowingly use AI to create:

• false testimonials;
• fabricated customer results;
• fake case studies;
• deceptive impersonation;
• materially misleading claims; or
• discriminatory marketing.

The fact that AI was involved does not excuse an inaccurate or misleading claim.

12. Synthetic Media

Where AI-generated or altered audio, video, imagery or other media could reasonably cause someone to believe something false about a real person or event, appropriate disclosure should be made.

Client Funnels will not knowingly use synthetic media to deceive people.

13. Fairness

AI must not be used by Client Funnels to intentionally discriminate unlawfully against individuals.

Where AI assists with segmentation, qualification or scoring, we consider whether the process may create unfair results.

Higher-risk uses receive greater human oversight.

14. AI Suppliers

Before approving an AI service for material business use, we may consider:

• data security;
• access controls;
• data-use terms;
• whether submitted information may be used for training;
• retention;
• deletion controls;
• location of processing;
• international data transfers;
• incident procedures; and
• contractual protections.

No technology provider can be guaranteed to remain unchanged.

We may change AI suppliers or stop using an AI service where we consider this appropriate.

15. Intellectual Property

Using AI does not change the intellectual-property restrictions contained in our Terms and Conditions or individual client agreements.

Client Funnels retains ownership of its underlying:

• systems;
• campaign structures;
• methodologies;
• frameworks;
• training;
• templates;
• processes;
• prompts;
• documentation; and
• know-how.

Clients must not upload Client Funnels proprietary material into AI systems for the purpose of:

• recreating our methodology;
• creating competing training;
• training or fine-tuning another system on our work;
• producing products for resale;
• providing our work to third parties; or
• replicating Client Funnels services for other businesses.

This applies whether the copying is carried out manually or through AI.

Where AI assists us in creating client deliverables, any contractual licence granted to the Client applies to those deliverables to the extent that Client Funnels has the rights required to grant that licence.

16. Security

AI tools are subject to the same security expectations as other business software.

Access should be limited to authorised users.

Sensitive information should only be processed where there is a valid reason and suitable safeguards.

Suspected loss, disclosure or misuse of information through an AI service must be reported immediately.

17. AI Incidents

An AI incident may include:

• confidential information being disclosed;
• personal data being entered into an unauthorised system;
• inaccurate high-risk advice;
• discriminatory output;
• misleading content;
• impersonation;
• unauthorised AI use;
• security incidents; or
• significant complaints concerning an AI interaction.

Incidents will be assessed and dealt with according to their nature and level of risk.

Where required, data-protection incidents will be handled under our data-protection procedures.

18. Third-Party AI Systems

AI services are provided by third parties and can change.

We cannot guarantee that any external AI service will:

• remain available;
• retain the same features;
• produce consistent outputs;
• remain compatible with other platforms; or
• continue under the same commercial terms.

Where AI technology forms part of client work, our general third-party platform provisions also apply.

19. Changes to This Policy

AI technology and the law surrounding it continue to change.

We will review this policy regularly and update it where required.

Material changes to the way we use personal information will also be reflected in our Privacy Policy.

Questions about our use of AI can be sent to:

paul@clientfunnels.co.uk