AI Transparency & Data Use Notice

(EU AI Act & GDPR)
Last updated: 01/01/2026

This AI Transparency & Data Use Notice explains how artificial intelligence (“AI”) and automated systems are used by Motive Journey, a brand operated by RichProMax Limited, and how data is processed in compliance with the EU AI Act, GDPR, and applicable Irish and EU law.

This notice is provided to ensure transparency whenever you interact with AI-enabled systems operated by us.

1. Who We Are

Brand: Motive Journey

Legal Entity: RichProMax Limited

Registered Jurisdiction: Ireland

Business Activity: Design and implementation of AI-enhanced digital business systems for SMEs

For the purposes of GDPR and the EU AI Act, RichProMax Limited is the data controller for AI systems operated under the Motive Journey brand.

Contact:

  • Email: info@motivejourney.com
  • Website: https://www.motivejourney.com

2. Purpose of This Notice

This notice exists to:

  • Inform you when you are interacting with AI systems
  • Explain what AI systems we use
  • Describe what data may be processed
  • Clarify how decisions are made
  • Explain your rights
  • Meet transparency obligations under:
    • EU AI Act
    • GDPR (Articles 12–14, 22)
    • Irish data protection law

3. AI Systems We Use

Motive Journey uses AI-assisted and automated systems for operational, informational, and support purposes.

These may include:

3.1 AI Chatbots

  • Website chat interfaces
  • Automated FAQ and information responses
  • Initial enquiry handling
  • Lead qualification support

3.2 AI Voice Call Assistants

Motive Journey uses AI-powered voice agents to handle incoming and outgoing communications efficiently.

  • Mandatory Transparency Declaration: To strictly comply with EU regulations, our AI voice systems are programmed to explicitly announce their automated nature at the very beginning of every call (within the first few seconds).
  • Functions:
    • Automated call answering and screening
    • Call routing and scheduling assistance
    • Information delivery and FAQ responses
    • Missed-call handling and callbacks

 

3.3 Automated Decision Support

  • Workflow automation
  • Booking and follow-up systems
  • Lead routing and prioritisation
  • Performance analytics

3.4 AI-Assisted Content & Analysis

  • Summarisation of enquiries
  • Internal analysis of operational patterns
  • System optimisation insights

Important:

AI systems used by Motive Journey do not make legally binding decisions about individuals without human oversight.

4. Transparency: Human vs AI Interaction

When interacting with Motive Journey systems:

  • You may be interacting with an AI system
  • This will be clearly indicated where applicable (e.g. chatbot, automated call)
  • You may request human assistance at any time
  • AI systems do not replace human decision-makers

This is in line with Article 52 of the EU AI Act.

5. Data Categories That May Be Processed

Depending on your interaction, the following categories of data may be processed:

5.1 Identification & Contact Data

  • Name
  • Business name
  • Email address
  • Phone number

5.2 Communication Data

  • Chat messages
  • Call audio (where disclosed)
  • Emails
  • Form submissions

5.3 Business & Operational Data

  • Business type
  • Operational challenges
  • Booking and workflow information

5.4 Technical Data

  • IP address
  • Device type
  • Browser information
  • Interaction timestamps

5.5 Audio & Recordings (Where Applicable)

  • AI-assisted call recordings
  • Meeting recordings (only where disclosed and lawful)

6. Purpose of AI Data Processing

AI systems are used only for legitimate business purposes, including:

  • Responding to enquiries
  • Providing information
  • Improving response speed
  • Reducing administrative burden
  • Scheduling and follow-ups
  • Service delivery and system performance
  • Quality assurance and training (where lawful)

We do not use AI systems to:

  • Profile individuals for unrelated purposes
  • Make automated legal or financial decisions about you
  • Conduct covert surveillance
  • Sell personal data

7. Legal Basis for Processing (GDPR)

Data processed via AI systems is handled under one or more of the following lawful bases:

  • Consent (where required and explicitly given)
  • Legitimate interest (operational efficiency, customer support)
  • Contractual necessity (service delivery)
  • Legal obligation (compliance and record-keeping)

Where consent is used, it may be withdrawn at any time.

8. Oversight & Right to Intervention

Motive Journey maintains strict human oversight over all AI-supported systems. While we use automation for efficiency, humans remain the ultimate decision-makers for critical business operations.

8.1 Scope of AI Decisions Our AI systems do not make fully autonomous decisions with legal or similarly significant effects (such as legally binding contract rejections or credit denials).

8.2 Right to Human Review If you believe an AI system has made an incorrect decision (e.g., incorrectly rejecting a booking request, misinterpreting an enquiry, or failing to route a critical message), you have the right to request human intervention.

8.3 Review Procedure & Timeframe To exercise this right, please follow this clear path:

  • How to Request: Send an email to info@motivejourney.com with the subject line “Human Review Request.”
  • Response Time: A human team member will review the interaction and respond to you within 24–48 business hours.
  • Outcome: If the AI system made an error, we will manually correct the outcome (e.g., reinstating a booking or manually processing an enquiry) immediately.

8.4 Override Capability Human operators retain full authority to override, correct, or disable AI outputs at any time. We regularly monitor system behaviour to ensure reliability and fairness.

9. AI Training & Data Use

9.1 No Training of Public Models Personal data processed by Motive Journey is never used to train public, open-source, or third-party foundational AI models (e.g., publicly available versions of ChatGPT, Gemini, or similar). We strictly prohibit third-party providers from using your data to improve their general public models.

9.2 Proprietary System Improvement & Fine-Tuning To ensure our systems become smarter and more accurate over time, Motive Journey retains the right to use fully anonymised and aggregated data to train, fine-tune, and optimise our proprietary internal models and workflows.

9.3 How This Works

  • Anonymisation: Before any data is used for system improvement, all personal identifiers (names, emails, phone numbers, specific addresses) are stripped away.
  • Purpose: This anonymised data allows us to identify operational patterns (e.g., “common times for appointment cancellations” or “frequently asked questions”) to refine our automation logic and improve accuracy for all users.
  • Outcome: This process helps us reduce errors, improve response relevance, and enhance the overall efficiency of the system without compromising individual privacy.

9.4 Data Minimisation We apply strict data minimisation principles. Only the specific data points necessary for system improvement are used, and no data capable of re-identifying a specific individual or business is used for model training.

 

10. Data Sharing & Third Parties

Motive Journey uses trusted third-party service providers for hosting, AI infrastructure, communications, and analytics.

Some providers may process data outside the EU, including in the United States.

Where personal data is transferred outside the EU/EEA, Motive Journey relies on EU Standard Contractual Clauses (SCCs) approved by the European Commission, alongside additional safeguards where required.

Data transfers are limited to what is necessary for service delivery and are subject to technical and organisational security measures.

Third-party providers are contractually restricted from using data for their own purposes.

Motive Journey does not sell personal data under any circumstances.

 

⚠️ Implementation & Legal Notes

  • The “SCCs” Keyword:
      • Do not remove or hide the phrase “EU Standard Contractual Clauses (SCCs)”. This is the specific legal mechanism that legitimizes using US-based AI tools (like OpenAI) for EU businesses. Irish corporate clients look for this specific acronym.
  • Trust Signal:
    • The final sentence (“Motive Journey does not sell personal data…”) should be visually distinct (e.g., Bold text) to provide immediate reassurance to the user.

 

11. Data Retention

Data is retained:

  • Only as long as necessary
  • In line with operational needs
  • In accordance with legal obligations
  • With regular review and deletion schedules

12. Your Rights

Under the General Data Protection Regulation (GDPR), you have the right to:

  • Access your personal data
  • Rectify inaccurate or incomplete data
  • Erase your data (where legally applicable)
  • Restrict processing in certain circumstances
  • Object to processing, including AI-assisted interactions. (Note: If you object to AI processing during an interaction, support can be continued via email or direct human contact.)
  • Request human review of AI-assisted interactions
  • Lodge a complaint with the Data Protection Commission (Ireland)
 

Requests can be made via:

info@motivejourney.com

13. Security Measures

We apply appropriate:

  • Technical safeguards
  • Organisational controls
  • Access restrictions
  • Encryption where applicable

No system is 100% risk-free, but we take reasonable and proportionate measures to protect data.

14. Changes to This Notice

This notice may be updated to:

  • Reflect regulatory changes (including EU AI Act updates)
  • Reflect system changes
  • Improve clarity and transparency

The latest version will always be available on our website.

15. Contact

For questions about AI use or data processing:

RichProMax Limited

Operating brand: Motive Journey

Email: info@motivejourney.com

Website: https://www.motivejourney.com