HAPPY BUSINESS GLOBAL LTD — AI USAGE & RESPONSIBLE AI POLICY

Last updated: 11 August 2026

1. About this policy

This policy explains how Happy Business Global Ltd uses artificial intelligence (“AI”), the safeguards we apply, and the responsibilities of people using AI-enabled products, services or systems that we provide or configure.
Happy Business Global Ltd is registered in Scotland.
Company number: SC518154
Registered office: 1 Waterloo Bank, Penicuik, Midlothian, EH26 8NS
We trade under brands including The Happy Business Company and The Happy AI Company.
In this policy, “we”, “us” and “our” mean Happy Business Global Ltd.
This policy applies to AI used within our own business and to AI-enabled tools, assistants, workflows and services that we make available, configure or help clients to implement.
It should be read alongside our Terms of Business, Privacy Notice and, for bespoke business clients, any applicable Client Services Agreement, permissions schedule or data-processing terms.

2. Our approach to AI

We use AI to help people and businesses work more efficiently, creatively and confidently.
Our approach is based on the following principles:
use AI for a clear and legitimate purpose;
keep humans meaningfully involved where judgement or important consequences are involved;
use appropriate safeguards for personal, confidential and commercially sensitive information;
check important AI outputs rather than assuming they are correct;
be transparent about material AI use where appropriate or legally required;
reduce the risk of unfairness, bias, discrimination, deception or harm;
give AI systems only the level of access and authority they need;
keep responsibility for important business decisions with people; and
review our AI use as technology, guidance and law develop.
AI is a tool. It does not replace professional judgement, appropriate human responsibility or specialist advice.

3. AI systems covered by this policy

This policy may apply to:
generative AI services that create or transform text, images, audio, video, code or other content;
AI assistants and customised AI tools;
AI Employees and AI-enabled business workflows;
AI features contained within third-party software;
automated analysis, summarisation, classification or organisation tools;
AI used for administration, marketing, research, content creation or customer support;
AI used to help us create or maintain websites, documents, training or business systems; and
future AI or automated technologies used by us.
The names of individual tools and services may change over time.
We may use AI supplied by third-party technology providers rather than developing the underlying AI model ourselves.

4. How we may use AI in our business

We may use AI to support activities such as:
drafting and editing content;
summarising information;
research and idea generation;
administration;
email and document preparation;
marketing and visibility;
organising business information;
preparing training and educational material;
creating graphics or other media;
website and digital-service development;
preparing internal reports;
supporting customer-service administration;
analysing information provided by us or our clients;
creating or configuring AI assistants and workflows; and
other legitimate business activities appropriate to the capabilities of the relevant tool.
We do not treat AI output as automatically correct simply because it was produced by an AI system.

5. AI services we provide to clients

Where we help a business create or use an AI Employee, assistant, workflow or other AI-enabled service, the exact scope and authority of that system will depend on the service agreed with the client.
We may use:
a Business Brain or other approved source of business information;
role-specific instructions;
AI guardrails;
permissions defining what an AI system may read, draft, create, edit, send, publish or automate;
human approval checkpoints; and
escalation rules for sensitive or higher-risk situations.
A connection to an email account, calendar, file store, payment system, CRM or other service does not by itself give the AI unrestricted authority to act within that system.
Where a client has signed a Client Services Agreement or agreed a permissions schedule, those documents govern the client-specific scope and permissions.
Clients remain responsible for decisions and actions that are reserved to them under those arrangements.

6. Human oversight and important decisions

We use proportionate human oversight according to the nature and risk of the task.
Unless a specific lawful and appropriately safeguarded process has been deliberately approved, we do not intend AI acting on our behalf to make final decisions without meaningful human involvement where those decisions could have a legal or similarly significant effect on a person.
Examples may include important decisions concerning:
employment or recruitment;
access to an important service;
legal rights or liabilities;
health or medical treatment;
significant financial matters;
disciplinary decisions; or
similarly consequential decisions about individuals.
Where UK data-protection rules on significant automated decision-making apply, we will take account of the safeguards required by applicable law.
For bespoke client systems, clients must not expand an AI system into significant or high-risk decision-making simply because the technology is technically capable of doing so.

7. Legal and professional advice

Our AI tools and AI-enabled services are not substitutes for qualified professional advice.
AI must not be relied upon as a solicitor, doctor, accountant, tax adviser, regulated financial adviser or other regulated professional.
AI may help:
organise information;
explain general information in plain English;
identify issues for further investigation;
draft material for review; or
suggest questions to raise with an appropriately qualified professional.
Users remain responsible for obtaining specialist advice where their circumstances require it.

8. Accuracy, limitations and hallucinations

AI systems can make mistakes.
Outputs may:
contain factual errors;
omit relevant information;
reflect outdated information;
misunderstand context;
generate plausible but incorrect statements;
produce inconsistent results; or
reproduce or amplify bias contained in data or instructions.
Important information should be checked against an appropriate and reliable source before it is relied upon, published or used to make a consequential decision.
Users should apply a level of review proportionate to the purpose and risk of the output.
We do not guarantee that AI-generated output will be complete, error-free or suitable for every purpose.

9. Fairness, bias and discrimination

AI systems can reflect bias in training data, source information, prompts, system design or how outputs are interpreted.
We aim to use AI fairly and responsibly and to take reasonable steps to identify and reduce material risks of unfairness or unlawful discrimination.
AI outputs should not be used to unlawfully discriminate against a person or group.
Where AI is proposed for a use that could materially affect individuals, the need for additional assessment, testing, safeguards and human oversight should be considered before deployment.

10. Personal data and privacy

Where AI involves personal data, we apply applicable UK data-protection law, including the UK GDPR and Data Protection Act 2018 as amended, including amendments made by the Data (Use and Access) Act 2025.
Our Privacy Notice explains how and why we process personal data, the lawful bases we rely on, relevant service providers and international transfers, retention, individual rights and how to raise a privacy concern.
When using AI, we aim to follow data-protection principles including:
lawfulness, fairness and transparency;
purpose limitation;
data minimisation;
accuracy;
appropriate retention;
security; and
accountability.
Where practical, personal data should be minimised, anonymised or pseudonymised before it is provided to an AI system if the person’s identity is not needed for the task.

11. Confidential and sensitive information

Users must not provide personal, confidential or sensitive information to an AI tool unless:
they have authority to use that information;
doing so is necessary and appropriate for the task;
the relevant AI service is approved for that type of information; and
any required data-protection, confidentiality or contractual safeguards are in place.
Users should avoid placing unnecessary information into AI systems.
Passwords, one-time authentication codes, secret keys and full payment-card credentials must not be put into ordinary AI prompts or project files.
Special category personal data, highly sensitive commercial information and confidential third-party material require particular care.

12. Client responsibilities when providing information

Clients are responsible for ensuring that information they provide to us, including personal data or confidential information belonging to another person or organisation, may lawfully be shared and used for the agreed service.
Clients must tell us about any particular confidentiality, security, regulatory or data-handling restriction that is relevant to the service.
Clients must not instruct an AI system we provide or configure to carry out unlawful, discriminatory, deceptive, harmful or unauthorised activities.

13. Security and access

We aim to use AI systems with proportionate security and access controls.
Our approach includes, where appropriate:
limiting access to what is needed for the role;
separating client information;
using approved accounts and services;
avoiding unnecessary duplication of sensitive data;
using human approval for higher-risk actions;
protecting credentials and account access; and
reviewing access when it is no longer needed.
Users are responsible for keeping their own account credentials secure.

14. Transparency about AI use

We aim to be open about material uses of AI.
Where people interact directly with an AI assistant or system that we make available, we will provide an appropriate indication that AI is involved where this is required by law or where failing to do so could materially mislead the person.
We may also voluntarily identify AI-assisted content where we consider this useful for trust or clarity.
We do not take the position that every piece of content that has had any AI assistance must always carry an AI label.
The appropriate disclosure depends on:
the nature of the AI involvement;
the context in which the output is used;
the likelihood that a person could be misled;
any applicable law or platform rule; and
the degree of meaningful human review or editorial control.

15. AI-generated and manipulated content

We do not knowingly use AI to impersonate a real person, create deceptive deepfakes, fabricate evidence or deliberately mislead people about the origin or authenticity of material.
Where applicable law requires disclosure or machine-readable marking of AI-generated or manipulated content, we will take reasonable steps to comply with the obligations applicable to our role.
If AI-generated material could reasonably be mistaken for an authentic depiction, recording or statement by a real person, additional review and disclosure should be considered before publication.

16. Intellectual property

AI-generated material may raise copyright, trade mark, database-right, confidentiality and other intellectual-property issues.
We do not assume that an AI output is automatically free to use simply because an AI system generated it.
Users should review material intended for significant commercial use and avoid knowingly instructing AI to reproduce protected third-party material unlawfully.
Where appropriate, users should consider:
whether third-party rights may be involved;
whether attribution or a licence is required;
whether confidential information has been included;
whether a trade mark may be infringed; and
whether sufficient human creative input is needed for the intended use.
Ownership and permitted use of materials supplied by us are also governed by our Terms of Business or applicable Client Services Agreement.

17. Third-party AI providers

Many AI services we use depend on third-party technology providers.
Those providers may have their own:
terms of use;
privacy notices;
security arrangements;
data locations;
retention settings;
model-improvement settings; and
technical limitations.
We select and configure services proportionately to the task, but we do not control every aspect of a third-party provider’s technology.
Our Privacy Notice gives further information about relevant categories of service providers used to process personal data.
Users may also be bound by the terms of any third-party AI account they use directly.

18. UK AI regulation

The United Kingdom regulates AI through a combination of existing legislation, sector-specific regulation and a principles-based regulatory approach rather than one single general AI Act applying to every use of AI.
Depending on the circumstances, AI use may engage laws relating to:
data protection and privacy;
equality and discrimination;
consumer protection;
intellectual property;
confidentiality;
contract;
employment;
online safety;
competition;
advertising and marketing; and
sector-specific regulation.
We aim to use AI consistently with applicable law and with principles of safety, security, transparency, fairness, accountability and appropriate human oversight.

19. EU Artificial Intelligence Act

The EU Artificial Intelligence Act may apply to some AI systems or uses even where the organisation involved is established outside the European Union.
Its application depends on matters including the role played in relation to the AI system, where it is made available or used, and where its outputs are used.
We do not assume that the EU AI Act applies to every AI service we provide.
Where it is potentially applicable, we will assess our role and take reasonable and proportionate steps to comply with the obligations that apply to that role and use case.
Depending on the circumstances, the EU AI Act may distinguish between roles such as:
provider;
deployer;
importer;
distributor; or
another regulated participant.
We will not describe ourselves or a client as a particular regulated role merely because an AI tool has been customised or configured. The legal role depends on the facts.

20. EU AI Act transparency

Where the EU AI Act applies, we take account of the transparency obligations applicable to our role.
These may include requirements concerning:
informing people when they are interacting directly with certain AI systems;
machine-readable identification of certain AI-generated or manipulated content;
disclosure of deepfake content;
disclosure of certain AI-generated text published to inform the public on matters of public interest where the relevant legal conditions are met; and
other transparency duties prescribed by applicable law.
The exact requirement depends on the system, content, use case and our legal role.

21. AI literacy and competence

We recognise that responsible AI use depends on people understanding what AI can and cannot do.
We take proportionate steps to support appropriate AI knowledge and competence among people using AI systems on our behalf.
This may include:
training;
written guardrails;
role instructions;
testing;
supervision;
guidance on personal data and confidentiality;
guidance on accuracy and verification; and
escalation procedures.
Where the EU AI Act applies, we will take account of any AI-literacy obligations applicable to our role.

22. Prohibited and unacceptable uses

AI systems supplied, configured or used by us must not knowingly be used to:
commit or facilitate unlawful acts;
deceive or impersonate people for fraudulent purposes;
unlawfully discriminate;
harass, threaten or exploit people;
breach another person’s confidentiality or privacy unlawfully;
infringe intellectual-property rights deliberately;
bypass security controls;
create false financial or business records;
fabricate testimonials, evidence or credentials;
provide regulated professional services without appropriate qualification and authority; or
carry out any AI practice prohibited by applicable law.
Where a client wants to extend an AI system into a materially different, sensitive, regulated or high-risk use case, a fresh assessment may be required before that use is implemented.

23. High-risk and regulated use cases

AI use in areas such as employment, recruitment, education, healthcare, financial services, biometric processing, legal services or other regulated fields may require additional legal, technical and governance safeguards.
Our ordinary AI business-support services should not be assumed to be approved for those purposes.
If a proposed use could fall within a legally regulated or high-risk category, we may:
decline the use;
restrict the AI’s role to administrative or preparatory assistance;
require meaningful human review;
request additional information;
require appropriate professional or legal input; or
require a separate agreement or assessment.

24. Reporting concerns

If you identify a material error, bias, privacy concern, security issue, potentially unlawful use or other significant concern involving an AI system supplied or used by us, please tell us promptly.
We will assess the issue and take proportionate action where appropriate.
This may include:
correcting an output or business record;
restricting or stopping a workflow;
adjusting instructions or permissions;
investigating the issue;
notifying an affected client;
reviewing a provider or process; or
taking other appropriate corrective action.

25. Privacy and data-protection concerns

For questions or concerns about personal data, please contact:
Julie Begbie
Happy Business Global Ltd
1 Waterloo Bank
Penicuik
Midlothian
EH26 8NS
Julie Begbie is the Company’s privacy contact.
Nothing in this policy describes Julie Begbie as a statutory Data Protection Officer unless the Company formally appoints one where legally required.
Our Privacy Notice explains how to exercise data-protection rights and how to complain to the Information Commissioner’s Office.

26. Changes to this policy

AI technology and regulation change quickly.
We may update this policy to reflect:
new AI tools or services;
changes in how we use AI;
changes to our business;
new legal or regulatory requirements;
updated regulatory guidance; or
lessons from our practical use of AI.
The current version will be published on our website with the date it was last updated.

27. Contact us

For questions about this policy:
Happy Business Global Ltd
Company number: SC518154
1 Waterloo Bank
Penicuik
Midlothian
EH26 8NS
Processing...

Privacy Policy