Policy on the Use of Artificial Intelligence (AI) within the KFB Group

Policy Administrator: KFB Technologies sp. z o.o., ul. Mydlana 7, Wrocław

1. Purpose and Scope

This Policy sets out how the KFB Group uses artificial intelligence (AI) tools and systems in its public communications, on its websites, in the products it offers, and in the day-to-day work of its teams. Our objective is to ensure transparency in compliance with Regulation (EU) 2024/1689 of the European Parliament and of the Council of 13 June 2024 laying down harmonised rules on artificial intelligence and amending Regulations (EC) No 300/2008, (EU) No 167/2013, (EU) No 168/2013, (EU) 2018/858, (EU) 2018/1139 and (EU) 2019/2144 and Directives 2014/90/EU, (EU) 2016/797 and (EU) 2020/1828 (Artificial Intelligence Act) (Text with EEA relevance) (OJ L, 2024/1689, as amended) (the “AI Act”), and with the Polish Act of 3 July 2026 on Artificial Intelligence Systems (Journal of Laws, item 1003), which establishes the framework for the supervision of the AI market in Poland, as well as with the principles of fair and accurate communication.

This Policy applies to the websites of the KFB Group brands, in particular: kfb-technologies.com, kfb-solutions.com, kfb-labs.com and rafa-imp.com, as well as to any further websites of KFB Group brands launched in the future.

2. Our Principles

In our work with AI technologies, we adhere to the following five principles:

1. Human oversight — AI supports the work of our experts but does not replace their expertise or accountability; final substantive decisions are always made by a human.

2. Transparency — we inform users in a clear and distinguishable manner when they are interacting with an AI system or when published content has been generated by AI. Such information is provided in an accessible format, at the latest at the time of the first interaction with, or exposure to, the relevant feature or content.

3. Accuracy — when describing the capabilities of our technologies, including AI features, we make only those claims that we are able to substantiate.

4. Data protection — any processing of data in connection with AI features is carried out in accordance with the GDPR and our Privacy Policy.

5. AI literacy — we support the development of AI literacy among persons working with these tools, tailoring training and materials to their technical knowledge, experience, education and training, and the context in which the AI systems are to be used, including the needs of the persons on whom the AI systems may have an impact.

3. AI in Content Published on Our Websites

Content published on KFB Group websites — articles, news, case studies, publications and expert materials — is prepared and edited by our specialists. Certain materials are produced with the support of AI tools (e.g. at the research, translation or initial editing stage). Every published text is subject to substantive review and editorial control, for which KFB Technologies sp. z o.o. is responsible.

Where we publish image, audio or video content generated or manipulated by AI that could falsely appear to a person to be an authentic or truthful depiction of existing persons, objects, places, entities or events, we will label such content in a visible manner (e.g. with the label “Generated with AI”), irrespective of whether the material has undergone editorial control.

Where, in exceptional cases, we publish AI-generated or manipulated text with the purpose of informing the public on matters of public interest, we will label such text in a visible manner (e.g. with the label “Generated with AI”), unless the AI-generated content has undergone human review or editorial control.

4. AI Assistants and Chatbots

Where we make an AI assistant or chatbot available on our websites, we inform users of this in a clear and distinguishable manner and in an accessible format — at the latest at the start of the conversation. Users may at any time request contact with a human.

5. AI Features in Our Products

AI features in KFB products support users’ decision-making and do not replace expert judgement — final decisions are made by a human. Detailed information on the functioning, data and limitations of AI features is provided in the product documentation.

Before being made available, each new AI feature undergoes an internal risk assessment, including verification that its use does not fall within the prohibitions laid down in Article 5 of the AI Act (prohibited AI practices) and that it does not constitute a high-risk AI system. Where a feature is classified as a high-risk AI system, we ensure that it is used in accordance with the provider’s instructions for use and under human oversight, and we inform natural persons in respect of whom decisions are made, or assisted, using that system that they are subject to the use of such a system.

Where, as part of our products, we make available AI systems generating synthetic image, audio, video or text content, we ensure that their outputs are marked in a machine-readable format and are detectable as artificially generated or manipulated, by applying effective and reliable technical solutions insofar as this is technically feasible.

6. Accurate Communication about AI

We undertake not to attribute to our products and services any AI capabilities that they do not possess. Claims regarding AI features in our marketing materials are based on documented and verifiable characteristics of our solutions.

7. Personal Data and Privacy

The rules governing the processing of personal data, including in connection with AI features, are set out in our Privacy Policy. Where AI features may influence decisions concerning natural persons, the final decision rests with a human, and the person concerned may obtain an explanation and request contact with a human. Should any AI feature in the future be used in such a way that a decision is based solely on automated processing and produces legal effects concerning, or similarly significantly affects, the person concerned, we will inform users accordingly and ensure their right to express their point of view, to obtain human intervention and to contest the decision.

8. Emotion Recognition and Biometric Data

Where we deploy emotion recognition or biometric categorisation features on our websites or in our products, we will inform the natural persons exposed thereto of this fact at the latest at the time of first use.

9. Internal Use of AI Tools

In the work of KFB Group teams, we use only AI tools that have been internally approved for use, the list of which is maintained and updated by the Policy Administrator. We do not enter into publicly available AI tools any client data, personal data obtained in connection with our services, or information constituting trade secrets, unless the activity in question has been approved in advance from a legal and information security perspective.

Employees shall report any suspected malfunction of an AI system, including the generation of harmful or misleading content, to the Policy Administrator, who shall document the incident and take appropriate action.

10. Policy Amendments and Contact

This version of the Policy is effective as of 1 September 2026. We update the Policy in line with the development of our technologies and of the regulatory environment. Joanna Dymińska-Kęczkowska is responsible for the implementation and updating of this Policy. Questions regarding the use of AI within the KFB Group may be addressed to: [email protected].