EU AI Act & GDPR Compliance
AI Transparency and Data Use Notice
This 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, the GDPR, and applicable Irish and EU law. Review our Privacy Policy and Terms of Service for full compliance details.
01. Who We Are
Brand / trading name: Motive Journey (Registered Business Name No. 764794)
Legal entity: RichProMax Limited, a private company limited by shares
Place of registration: Ireland
Company Registration Number (CRO): 779918
Registered office: Apartment 2, 4 O’Neill Crowley Quay, Fermoy, Co. Cork, Ireland (P61X407)
Business activity: Diagnoses, designs, builds and operates connected delivery systems (explore what we build) for organisations whose people sell expensive expertise.
Contact: info@motivejourney.com · +353 89 944 8950
For the purposes of the GDPR and the EU AI Act, RichProMax Limited is the data controller for AI systems operated under the Motive Journey brand.
Note on VAT: RichProMax Limited is not currently registered for VAT, so no VAT is added to our fees.
Full corporate details are available on our Legal and Company Information page.
02. Purpose of This Notice
This Notice exists to inform you when you are interacting with AI systems, explain what AI systems we use and what data may be processed, clarify how decisions are made, and explain your rights. It supports our transparency obligations under the EU AI Act (including Article 50), the GDPR (Articles 12 to 14 and 22) and Irish data protection law. Learn more about our governance approach.
03. AI Systems We Use
We use AI-assisted and automated systems for operational, informational and support purposes:
3.1 Website AI Chatbot
Website chat interfaces operating on our own website, providing automated FAQ responses, initial enquiry handling, and qualification support. Check how our systems operate.
3.2 Automated Decision Support
Workflow automation, booking and follow-up systems, lead routing and prioritisation, and performance analytics.
3.3 AI-Assisted Content and Analysis
Summarising enquiries, internal analysis of operational patterns, and system optimisation insights.
AI systems we use do not make legally binding decisions about individuals without human oversight.
04. AI System Applicability & Obligations
The following table sets out the AI features operated directly by us on our website and systems, clarifying legal ownership, roles, and compliance mechanisms under Article 50 of the EU AI Act:
| Feature / System | System Role | EU AI Act (Art. 50) Obligation | Where Disclosure Appears | Ownership |
|---|---|---|---|---|
| Website AI Chatbot | Deployer | Transparency obligation to inform users that they are interacting with an AI system (Art. 50(1)). | Disclosed explicitly in the first message of the chatbot window upon opening, as well as in this Notice. | RichProMax Limited |
| Workflow Diagnostic Tools | Deployer / Internal User | Internal processing transparency and data minimisation safeguards. | Specified directly in our Privacy Policy and client agreements. | RichProMax Limited |
Transparency obligation to inform users that they are interacting with an AI system (Art. 50(1)).
Disclosed explicitly in the first message of the chatbot window upon opening, as well as in this Notice.
Internal processing transparency and data minimisation safeguards.
Specified directly in our Privacy Policy and client agreements.
05. Data Categories That May Be Processed
Depending on your interaction, we may process:
- Identification and contact data: Name, business name, email address, phone number.
- Communication data: Chatbot messages, emails, and form submissions.
- Business and operational data: Business type, operational challenges, booking and workflow information.
- Technical data: IP address, device type, browser information, interaction timestamps.
- Audio and recordings (where applicable): Recordings made during online calls and during in-person diagnostic visits to a client’s premises, collected only with explicit prior consent (read our Call Recording Notice).
06. Purpose of AI Data Processing
We use AI systems only for legitimate business purposes: responding to enquiries, providing information, improving response speed, reducing administrative burden, service delivery, and quality assurance 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, infer emotions or intentions, or sell personal data.
07. Legal Basis for Processing (GDPR)
We process data via AI systems under one or more of these bases:
- Consent: Explicitly given prior to collection (for example, discovery call or in-person audio recordings).
- Legitimate Interest: Operational efficiency, securing and operating our website, with balancing tests applied.
- Contractual Necessity: Service delivery and client solution planning.
- Legal Obligation: Statutory record-keeping and statutory reporting.
Where consent is used, it may be withdrawn at any time.
08. Oversight and Right to Intervention
We maintain human oversight over all AI-supported systems. Humans remain the ultimate decision-makers for critical operations.
8.1 Scope of AI decisions: Our AI systems do not make fully autonomous decisions with legal or similarly significant effects.
8.2 Right to human review: If you believe an AI system made an incorrect response or routing error, you can request human intervention.
8.3 Procedure and timeframe: Email info@motivejourney.com with the subject “Human Review Request”. A team member will review and respond within 24 to 48 business hours. If the AI system made an error, we correct the outcome.
8.4 Override: Human operators can override, correct or disable AI outputs at any time.
09. AI Training and Data Use
9.1 No training of public models: Personal data we process is never used to train public, open-source, or third-party foundational AI models. We prohibit third-party providers from using your data to improve their general public models.
9.2 Retention of developed frameworks: We retain the frameworks, methods and reusable components we develop through our work. That is separate from your data, which is used only to deliver your engagement.
9.3 No training on your recordings or content: Call recordings, transcripts, and meeting summaries are not used to train, fine-tune, or improve any AI model, whether ours or a third party’s.
9.4 Anonymisation and data minimisation: We use only aggregated, non-personal operational metrics that cannot be linked back to an individual or business for internal operational reviews.
10. Data Processors and Third Parties
We use processors that provide data processing terms meeting Article 28 GDPR. Our current main processor is Google, whose Data Processing Addendum applies to our use of its services (including Google Workspace, Google Calendar, Google Analytics, and Google Cloud).
Where personal data is transferred outside the EU/EEA by our processor, standard protection measures including EU Standard Contractual Clauses (SCCs) apply. RichProMax Limited does not sell personal data under any circumstances.
11. Data Retention Criteria
We keep personal data only for as long as it is needed for the purpose it was collected for. In practice this means:
- Enquiry and contact data: For as long as we are in active discussion with you and for a reasonable period afterwards;
- Recordings and transcripts: Only for as long as needed to prepare your solution plan, after which they are deleted;
- Call summaries: For the duration of our work together;
- Client records and invoices: For the period required by Irish tax and company law.
You can ask us to delete your data at any time, and we will do so unless we are legally required to keep it.
12. Your Rights
Under the GDPR, you have the right to access, rectify, erase, restrict processing, object to processing, request human intervention, and lodge a complaint with the Data Protection Commission (Ireland).
Requests should be sent to: info@motivejourney.com.
13. Security Measures
We apply appropriate technical and organisational safeguards, access restrictions, and encryption where applicable to secure personal data processed via our web services and internal infrastructure. Review our Accessibility Statement to learn about our interface standards.
14. Changes to This Notice
We may update this Notice to reflect legal, technical, or operational changes. The latest version is always published on our website.
15. Contact Us
RichProMax Limited (trading as Motive Journey)
Apartment 2, 4 O’Neill Crowley Quay, Fermoy, Co. Cork, Ireland (P61X407)
Email: info@motivejourney.com | Phone: +353 89 944 8950
