AI POLICY

Zeydoo Ltd (Cyprus), Zeydoo Limited (Isle of Man), Propeller Ads Ltd (Cyprus), Propeller Ads Limited (Isle of Man), Propeller Ads s.r.o. (Czech Republic) and Adtech Agency FZ-LLC (United Arab Emirates) (referred to as “Zeydoo” or “we” or “us” or “our”) operate a global CPA network that connects advertisers and Affiliates through a broad range of Offers, tracking and optimisation tools available at zeydoo.com. Zeydoo’s technologies leverage the latest developments in artificial intelligence (“AI”) to deliver a smarter, faster and safer performance-marketing experience across digital channels.

This Artificial Intelligence Policy (“AI Policy”) outlines how Zeydoo develops, procures, deploys and governs AI and machine-learning systems used in connection with its services.

This AI Policy applies to all AI Systems operated by Zeydoo, to anyone engaged in AI-related activities on Zeydoo’s AI Systems, and to all users of the Zeydoo Network, Platform and services whose traffic, Offers, campaigns or content are processed by Zeydoo’s AI Systems.

This AI Policy also applies to any artificial-intelligence system, software agent, large language model, model-context-protocol (MCP) server or client, or automated assistant that a user authorises, deploys or connects to the Zeydoo Platform, services or API to access an account or manage activity on the user’s behalf (a “Connected AI Agent”). Each user remains fully responsible for any Connected AI Agent it connects, as set out in this Policy, the Advertiser Agreement and Publisher Agreement (including Section 20) and the Zeydoo API & MCP-Connector Legal Notice. For clarity, a Connected AI Agent is deployed by the user and is distinct from the AI Systems operated by Zeydoo.

How We Use AI

Zeydoo is committed to the responsible development, deployment and use of AI systems within its Network, Platform and services, including Zeydoo’s Offer and traffic management tools, tracking and attribution infrastructure, anti-fraud infrastructure, reporting and analytics infrastructure and audience-intelligence tools (available at zeydoo.com) (collectively, the “AI Systems”), aiming to provide users with the ability to select, launch, manage, optimise and scale their performance-marketing activity more efficiently.

Our AI Systems consist of tools that may help users find and match relevant Offers, manage and optimise traffic and creatives, generate content and audience insights, improve conversion performance, and automate marketing workflows, including through recommendation systems and generative AI features. These AI Systems are designed to enhance user productivity and improve the performance-marketing experience from Offer selection and audience targeting to performance reporting and optimisation.

Zeydoo uses AI and machine learning to power Offer matching, traffic and conversion quality assessment, fraud detection and creative tools, and specifically for the following purposes:

  • automated Offer recommendation, matching and ranking for Affiliates;
  • traffic and conversion quality scoring, attribution support and performance optimisation;
  • AI-generated or AI-assisted creative content (images, copy, landing pages and funnels), where such functionality is made available;
  • fraud, bot and incentivised-traffic detection, including the identification of non-Qualified Actions;
  • anti-spam and content and policy moderation of inputs and generated outputs;
  • audience segmentation and audience insights for advertising purposes;
  • predictive analytics and forecasting of Offer and traffic performance.

Based on our current assessment, the AI Systems we operate are intended for advertising- and performance-marketing-related functions such as Offer matching, optimisation, fraud prevention, analytics and reporting, and are not designed or used for any purpose that would be classified as high-risk or prohibited under applicable law. We do not carry out extensive profiling or large-scale predictive analytics of the kind associated with high-risk AI.

User inputs, content, traffic and campaign data, queries, ratings, interactions with AI-assisted tools or AI-generated content, and any other resulting outputs submitted to or received through our Network, Platform and services, including through the API or by a Connected AI Agent acting on the user’s behalf, may be processed by Zeydoo, and where applicable by our authorised subprocessors, for the purpose of generating responses and delivering the requested products and services. Zeydoo does not use personal data to train AI models. We may use aggregated, anonymised or otherwise non-personal information to monitor, maintain and improve the performance, accuracy and reliability of our AI Systems and services, in accordance with applicable laws and our Privacy Policy.

Where a user has exercised their right to opt out of the use of their inputs for the development of Zeydoo AI Systems, Zeydoo will not use or share any content inputted into, or received from, our AI Systems for the purposes of using, refining or otherwise improving our AI models and systems. This commitment applies for as long as the opt-out preference remains in effect. Users retain the ability to review and update their opt-out preferences at any time through the designated opt-out mechanisms made available within the applicable platform rules or privacy controls.

We also use AI-powered tools internally to support our own teams – for example, to log, transcribe, summarise and analyse business communications between our staff and users or partners, and to prepare internal reports. Outputs of such internal tools are used to assist our personnel, are subject to human review, and are not used to take decisions producing legal or similarly significant effects concerning any individual by solely automated means. Personal data processed by such tools is handled in accordance with our Privacy Policy.

Prohibited AI Practices

The following practices are strictly prohibited on Zeydoo’s Network, Platform and services:

  • Subliminal and Manipulative Techniques: the deployment of AI systems that use subliminal techniques beyond a person’s consciousness, or that exploit psychological weaknesses or cognitive biases to distort behaviour in a manner that causes or is likely to cause physical, psychological or financial harm.
  • Exploitation of Vulnerable Groups: AI systems that exploit any known vulnerability of a specific group of persons, including vulnerability due to their age, disability, or specific social or economic situation, to distort the behaviour of those groups in a way that is likely to cause harm.
  • Social Scoring: AI systems used by public authorities or on behalf of public authorities for general-purpose social scoring of natural persons.
  • Real-Time Remote Biometric Identification: the use of real-time remote biometric identification systems in publicly accessible spaces for law-enforcement purposes.
  • Emotion Recognition in Prohibited Contexts: AI systems that infer emotions of natural persons in the context of the workplace and educational institutions, except for medical or safety reasons.
  • Biometric Categorisation Based on Sensitive Attributes: AI systems that categorise natural persons based on their biometric data to deduce or infer race, political opinion, trade-union membership, religious or philosophical beliefs, sex life or sexual orientation.
  • Artificial Generation of Conversions: the use of any AI system, automation or Connected AI Agent to generate, simulate or facilitate traffic, clicks, impressions, conversions or Qualified Actions by automated, artificial, incentivised or otherwise non-human means, or to circumvent Zeydoo’s anti-fraud controls.

Data and Privacy

The collection, use and processing of personal data in Zeydoo’s AI Systems is conducted in accordance with our Privacy Policy.

All personal data in our AI Systems is used for the purpose for which it was collected and is processed on a clearly documented and legitimate basis.

AI systems are designed, procured and configured to use the minimum amount of personal data necessary to achieve the intended purpose. Where anonymisation or pseudonymisation can achieve equivalent functional outcomes, such techniques are preferred.

The use of sensitive categories of personal data, including any information relating to, or capable of inferring, an individual’s health status, religious beliefs, political views or sexual orientation, is strictly prohibited for the purposes of AI-driven targeting, profiling or any related automated processing throughout Zeydoo’s Network, Platform and services.

Zeydoo’s Network, Platform and services are intended for businesses and are not directed to, or available for use by, minors or persons lacking full legal capacity. We do not knowingly process the personal data of minors through our AI Systems, and AI-driven targeting of children is not permitted.

Where you connect a Connected AI Agent or use a third-party AI provider to access your account or the API, you direct Zeydoo to make available to that agent or provider the account and related data necessary for the operations you request. You act as controller (or otherwise as the responsible party) in respect of any subsequent processing of such data by that agent or provider, and Zeydoo is not responsible for that processing. Such transfers may involve recipients located outside the EEA, as further described in our Privacy Policy. You must not transmit to a Connected AI Agent, or to any third-party AI provider, any personal data for which you do not hold a lawful basis and all necessary rights.

Security

Zeydoo applies reasonable and proportionate safeguards designed to protect user safety, prevent harm to individuals, and maintain the integrity of its Network, Platform and services. Ethical considerations and security requirements are embedded throughout our design and development lifecycle, with appropriate controls in place to detect, prevent and report instances of misuse or abuse.

Where Zeydoo operates or deploys within its Network, Platform or services a chatbot, virtual assistant or any other AI-powered system that engages directly with individuals, we will clearly inform users that they are interacting with an automated AI system rather than a human representative, prominently and at the earliest practicable point of engagement. Where our features incorporate or depend upon third-party AI platforms, such integrations will be clearly identified through designated markers, labels, interactive tooltips, codebase annotations or such other notification methods as Zeydoo deems appropriate.

Each AI system deployed at Zeydoo is assigned measurable performance and quality thresholds, and any third-party AI vendors working with us must confirm their compliance status with applicable legislation and standards, and notify us of any AI incident that could affect our own compliance. AI system outputs, performance metrics and anomaly events are logged in a manner that enables retrospective auditing.

Zeydoo recognises the fundamental importance of meaningful human oversight in the governance of AI systems and therefore, in furtherance of this commitment, significant automated decisions with material consequences shall, where required by applicable law, be subject to human review. Our authorised personnel are empowered to intervene in, override, suspend or fully deactivate any AI System at any time and without delay.

Further to the necessary controls implemented across our AI Systems, Platform and services, our policies, procedures and internal governance frameworks are subject to periodic review and revision to ensure ongoing compliance with applicable data-protection laws, regulations and recognised industry standards.

User Responsibilities and Rights

By using Zeydoo’s Network, Platform and services and when engaging with our AI Systems, you agree to comply with this AI Policy, including the following principles:

  • not to submit AI-generated content that is deceptive or manipulative;
  • not to target users using prohibited criteria;
  • not to deploy AI systems on your Traffic sources that violate this AI Policy;
  • not to use AI Systems, the API or any Connected AI Agent to generate, simulate or facilitate traffic, clicks, impressions, conversions or Qualified Actions by automated, artificial, incentivised or otherwise non-human means;
  • not to use the API or any Connected AI Agent in a manner that breaches the Advertiser Agreement and Publisher Agreement (including Section 20), the Zeydoo API & MCP-Connector Legal Notice, this AI Policy or applicable law;
  • not to deliberately remove, conceal or manipulate AI-identification labels or metadata, and to ensure that all AI-generated outputs or creative assets are properly labelled where required before submission into our AI Systems or use in connection with any Offer;
  • to exercise sound judgment when interacting with our AI Systems and to independently evaluate any AI output or generated content for accuracy, reliability and appropriateness prior to use or implementation; NOTE: you are solely responsible for the compliance of your use of any AI System, the API and/or any Connected AI Agent with Zeydoo Advertiser Agreement and Publisher Agreement, this AI Policy, the Zeydoo API & MCP-Connector Legal Notice, the requirements of each relevant Offer and any special rules as may be applicable (including those communicated via the interface of any of our relevant platforms), as well as for ensuring the same compliance of any results or outputs of such use. In no case shall Zeydoo be responsible or accountable for any of your activities or decisions engaging our AI Systems, the API and/or any Connected AI Agent, including but not limited to any of your activities or decisions related to Offer participation, traffic routing, tracking links, streams, postbacks or creatives created, changed or removed with the assistance of any AI System.
  • to apply human oversight and review before deployment or commercial use of AI output or generated content, to help identify potential defects, intellectual-property concerns, security vulnerabilities or the unintended disclosure of confidential or proprietary information;
  • to hold all necessary legal bases for any personal data submitted into AI Systems;
  • to ensure that any AI-driven personalisation content on your properties is disclosed to end users in accordance with applicable law;
  • to maintain AI-usage records and make them available to Zeydoo on request and when required for regulatory compliance;
  • to support responsible AI practices and reduce the risk of unintended outcomes or errors;
  • to promptly notify Zeydoo if you become aware of any AI system operating on the Zeydoo Network, Platform or services that may violate this AI Policy.

Subject to and in accordance with applicable law, natural persons affected by AI Systems operated by Zeydoo have the following rights:

  • Right to transparency: request information about how AI processes your data.
  • Right to object to AI profiling: opt out of interest-based profiling and AI-driven personalisation at any time.
  • Right to human review: request manual review of any decision made solely by an AI automated process with significant effect.
  • Right to explanation: receive a plain-language explanation of any automated decision.
  • Right to withdraw consent: withdraw consent for AI-based processing at any time.

Subject to your compliance with Zeydoo Advertiser Agreement and Publisher Agreement, this AI Policy and other applicable rules and regulations, you may retain rights in the specific pieces of AI outputs to the extent such rights are capable of being owned by you under applicable law. You acknowledge that outputs are not unique by default, and that Zeydoo does not guarantee the exclusivity of any AI System output.

Connected AI Agent and API Use Responsibilities

Where you generate API credentials and/or connect or authorise a Connected AI Agent or another third party to access your account or the API, you additionally agree that:

  • you are solely responsible for selecting, configuring, instructing, monitoring and controlling the Connected AI Agent, and for all of its actions, requests, omissions and outputs, which are deemed to be your own;
  • the Connected AI Agent is a third-party product operated by its own provider; Zeydoo does not control it, does not review its instructions or outputs, and is not responsible for how it interprets your instructions; account and performance data retrieved through the API will be processed by the Connected AI Agent and its provider under their own terms and privacy policies;
  • you will connect a Connected AI Agent only to your own account, using valid API credentials issued to or generated by you, and will keep those credentials confidential and not share them with any third party other than the Connected AI Agent acting on your behalf;
  • you will ensure the Connected AI Agent operates within the rate limits, security requirements and technical rules published by Zeydoo, and will not use it to exceed your permitted access, circumvent security or access controls, place undue load on, disrupt or interfere with the services, access any account other than your own, or generate or facilitate any fraudulent, artificial or non-human-initiated traffic, clicks, impressions, conversions or Qualified Actions;
  • you will not use the Connected AI Agent or the API to extract, aggregate or re-distribute Offer terms, payouts, advertiser information or other non-public data beyond what is permitted under the Advertiser Agreement and Publisher Agreement, and you remain bound by your confidentiality obligations in respect of such data;
  • you will apply meaningful human oversight to material decisions taken by the Connected AI Agent, and you accept responsibility for any erroneous or unintended action, including any action that alters your Offer participation, tracking links, streams or postbacks and thereby affects the measurement of Qualified Actions or your earnings, and any action that is irreversible;
  • you hold a lawful basis and all necessary rights for any data that you, or the Connected AI Agent, transmit to or through Zeydoo or to any third-party AI provider in connection with such use, and your use of any third-party AI provider complies with that provider’s terms and applicable law;
  • Zeydoo is not responsible for, and gives no warranty in respect of, any Connected AI Agent, any third-party AI provider you use, or any outcome of their use; and
  • you will promptly notify Zeydoo of any compromise of your API credentials or of any Connected AI Agent operating in breach of this Policy, the Advertiser Agreement and Publisher Agreement or the Zeydoo API & MCP-Connector Legal Notice.

Enforcement

Violations of this AI Policy are treated at Zeydoo’s sole discretion, and Zeydoo reserves the right to take one or more of the following actions in response: (a) immediate suspension or permanent termination of the user’s account(s); (b) withholding of account balances pending investigation of AI-related fraud or AI Policy violations; (c) suspension or termination of the user’s participation in any or all Offers, and removal of non-compliant AI-generated creatives, landing pages or funnels from the Zeydoo Network; (d) pursuit of civil or criminal remedies where losses or harm result from the violation; (e) any other legal action available; and (f) suspension, throttling, restriction or revocation of API access and/or of any Connected AI Agent’s access to the Network, Platform and services.

Policy Updates

We may review and update this AI Policy from time to time by publishing a new version of it on our Website. Users are encouraged to review this AI Policy periodically so as to always be informed about how we use AI. This AI Policy forms part of, and must be read together with, the Zeydoo Advertiser Agreement and Publisher Agreement and the Zeydoo API & MCP-Connector Legal Notice. It is governed by, and shall be construed in accordance with, the laws of the Republic of Cyprus. In the event of any conflict between this AI Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

Contacts

For all queries, complaints or requests relating to this AI Policy please contact us via email at: dpo@zeydoo.com.

Last update: August 5, 2026.