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LEGAL

AI and Data Statement

Last updated: May 2026

Transform with Toska uses AI-assisted tools as part of how we operate our platform, create content, and serve our community. This statement explains what AI tools we use, what data they process, and the protections we apply. It is provided in compliance with the EU AI Act and UK data protection law.

1. AI Tools We Use

1.1 Platform Operations

Our platform uses AI language models, including Claude by Anthropic, to assist with internal operations including content management, audience intelligence, and platform administration. These tools are operated by our team. They are not deployed to interact with members directly without prior disclosure.

1.2 Content Intelligence

We use AI-assisted analysis to process publicly available data from Instagram and TikTok, including public posts, comments, and engagement data from our own accounts. This analysis helps us understand what content resonates with our audience, identify patterns in public engagement, and inform our content strategy. This analysis is conducted on publicly visible data only. We do not access private accounts or private messages on any platform.

1.3 Community Intelligence

We process content shared within the Many Butterflies Telegram community to build member profiles and improve the community experience. AI tools may assist in analysing participation patterns, identifying common themes, and improving the relevance of content Toska creates for members. Community data is processed on a confidential basis and is never shared outside of Transform with Toska's platform. Member content is not used to train third-party AI models.

2. Classification Under the EU AI Act

The AI systems we use fall within the following classifications under the EU AI Act (Regulation (EU) 2024/1689):

  • General purpose AI (GPAI): We use general purpose AI models (Claude by Anthropic) for internal content and platform operations. These are classified as GPAI systems under the Act.
  • No high-risk AI systems: We do not use AI systems that make automated decisions with significant legal or personal effects on individuals. We do not use AI for recruitment, credit scoring, biometric identification, or any other high-risk application listed in Annex III of the Act.
  • No prohibited AI practices: We do not use AI for subliminal manipulation, social scoring, real-time biometric surveillance, or any other prohibited practice under Article 5 of the Act.

3. What We Do Not Do

  • We do not use your personal data to train external AI models
  • We do not sell data to AI companies or data brokers
  • We do not use AI to make automated decisions that have legal or similarly significant effects on you
  • We do not deploy AI systems that interact with members without disclosure
  • We do not collect data from private social media accounts or private messages on platforms we do not control
  • We do not use emotion recognition or biometric categorisation systems

4. Data Sources and Legal Bases

4.1 Instagram and TikTok Public Data

Public content from Instagram and TikTok is processed under legitimate interests (UK GDPR Article 6(1)(f)): understanding our audience and improving our content. This data is publicly available. Individuals who comment publicly on our posts should be aware that their public comments may be included in our audience analysis.

4.2 Telegram Community Data

Community data is processed on the basis of your consent (UK GDPR Article 6(1)(a)), given when you join the Many Butterflies community. You can withdraw from the community at any time and request deletion of your data, subject to our retention obligations.

4.3 Website and Platform Data

Standard analytics and usage data are processed under legitimate interests for platform improvement and security.

5. Third-Party AI Providers

We use AI services provided by Anthropic (Claude). Anthropic processes data on our behalf under a data processing agreement. We have assessed that data shared with Anthropic is used only for the purposes of processing our requests, Anthropic is not permitted to use our data to train their models without our consent, and appropriate international data transfer safeguards are in place.

6. Human Oversight

In line with EU AI Act requirements and our own values, we maintain meaningful human oversight of all AI-assisted processes. No decision that materially affects a member or customer is made by AI alone. Our team reviews AI outputs before they are acted upon in any context that affects individuals.

7. Transparency and Your Rights

You have the right to:

  • Be informed about the use of AI tools that process your data (this statement fulfils that obligation)
  • Object to processing of your data by AI tools on the basis of legitimate interests
  • Request human review of any AI-assisted process that affects you
  • Request information about how your data has been processed
  • Request deletion of your personal data, subject to our retention obligations

To exercise any of these rights, contact us at hello@transformwithtoska.com.

8. Updates to This Statement

As AI tools evolve and as AI regulation develops, we will update this statement to reflect changes in our practice and our legal obligations. Material changes will be communicated to active members by email. This statement will also be updated when significant new AI obligations under the EU AI Act come into effect for our category of use.

9. Contact

For any questions about how we use AI or how your data is processed, contact us at hello@transformwithtoska.com.