NEVTAN ENGAGE
AI & Data Usage Policy
Effective Date: June 5, 2026 · Last Updated: June 5, 2026
This AI & Data Usage Policy explains how Nevtan Engage develops, deploys, and operates artificial intelligence features, and how Customer data is processed in connection with those features. This Policy forms part of Engage's legal framework and should be read with the Privacy Policy, DPA, Terms and Conditions, and Security & Compliance documentation at engage.nevtan.com/legal.
1. Core AI Commitments
Engage makes the following binding commitments across all AI features:
1.Customer data is never sold to AI providers or third parties for any purpose.
2.Customer data is not used to train publicly available or general-purpose AI models without express written opt-in.
3.One Customer's data is never used to train, fine-tune, or improve AI systems for any other Customer.
4.Data submitted to third-party AI providers is processed under zero data retention and no-training API agreements.
5.Customers retain full ownership of all data, including data processed through AI features. No ownership is transferred to Engage or its providers.
6.AI features are designed to assist users — not replace human judgment. Customers remain responsible for all decisions made using AI-assisted outputs.
2. What AI Means in Engage
For the purposes of this Policy, "Artificial Intelligence" or "AI" refers to machine learning models, large language models (LLMs), statistical prediction systems, and related techniques that generate outputs, recommendations, or predictions based on patterns learned from data.
Not all platform features use AI. Where AI is involved in a specific feature, it is identified within the product interface.
3. AI Features
| AI Feature | What It Does | Available On |
|---|---|---|
| Email Content Generation | LLM-powered drafting of email body copy, subject lines, preview text, and CTAs from user prompts. | All plans |
| Subject Line Optimization | AI-scored subject line variants ranked by predicted open rate based on account engagement history. | All plans |
| SMS Content Suggestions | Short-form message generation based on campaign objective and audience. | All plans |
| Send-Time Optimization | Per-contact delivery time prediction based on individual historical interaction patterns. | Pro and Enterprise |
| Engagement Scoring | Predictive lead and contact scoring identifying engaged, at-risk, and high-value contacts. | Pro and Enterprise |
| AI Customer Segmentation | Behavioral and predictive audience building with dynamic segments updated automatically. | Pro and Enterprise |
| Campaign Recommendations | AI-driven suggestions for automation triggers, journey optimization, channel mix, and content personalization. | Pro and Enterprise |
| Landing Page Copy Assistance | AI-assisted headline and body copy generation for landing pages and forms. | Pro and Enterprise |
| Marketing Copilot (Chat) | Conversational AI assistant for campaign planning, content ideation, report interpretation, and workflow building. | Enterprise |
| Natural Language Reporting | Plain-language campaign and audience analytics via conversational queries. | Enterprise |
| Workflow Builder AI | Natural language workflow creation: describe the automation and Engage builds the journey structure as a starting point. | Enterprise |
4. How AI Features Process Customer Data
4.1 User Inputs (Generative AI)
When an Authorized User interacts with a generative AI feature, the following may be transmitted to the AI processing layer: prompts, instructions, and questions entered by the user; campaign configuration and context provided by the user; and content fragments explicitly submitted for AI refinement. Inputs are transmitted to AI providers under zero data retention agreements and are not retained beyond the API call.
4.2 Account and Campaign Data (Predictive AI)
Predictive AI features process data held within the Customer's own Engage account: contact-level engagement metrics, customer lifecycle stage and purchase history, campaign performance data, and custom attributes. Predictive models operate per Customer only — no cross-customer data mixing occurs.
4.3 What Is Not Processed by AI
Unless the Customer explicitly includes it in a user prompt, the following is not transmitted to AI systems: raw contact personal information not included in a prompt, payment or billing information, and authentication credentials or API keys.
5. Third-Party AI Providers
Engage uses the following approved AI providers, both listed on the Subprocessor List at engage.nevtan.com/legal/subprocessors:
OpenAI (OpenAI, LLC — USA)
Generative AI features including email content generation, subject line suggestions, and the Marketing Copilot. Processed under OpenAI's zero data retention API tier and Data Processing Addendum.
Anthropic (Anthropic, PBC — USA)
Generative AI and conversational assistant capabilities. Processed under Anthropic's API Data Processing Agreement with no-training commitments.
New AI providers will be added to the Subprocessor List with at least 30 days' advance notice. Customers may object per the process in the DPA. Engage does not currently use Google, AWS, or Microsoft for AI inference; if this changes, advance notice will be provided.
6. Data Retention for AI Features
| Data Type | Retention Period | Notes |
|---|---|---|
| User prompts and AI inputs | Not retained by AI providers beyond the API call | Engage may retain prompts in audit logs for up to 12 months for security monitoring. |
| AI-generated outputs (saved by user) | Subscription duration + 90-day post-termination | Treated as Customer Data under the DPA. Deleted per standard data deletion process. |
| Predictive model results | Subscription duration + 90 days | Engagement scores and predictions stored in Customer's account. |
| AI feature usage logs | 12 months | Used for abuse detection, debugging, and security monitoring. |
| Aggregated anonymized analytics | Up to 3 years | De-identified usage patterns for platform improvement. Cannot be re-identified. |
7. Human Oversight and AI Accuracy
7.1 Engage's Safeguards
7.2 Customer Responsibilities
Customers are solely responsible for reviewing AI-generated content before sending; ensuring communications comply with applicable laws; verifying accuracy of AI-generated factual claims; all business decisions made using AI recommendations; and obtaining any required disclosures when using AI-generated content in customer-facing communications.
8. Automated Decision-Making
No Engage AI feature currently makes solely automated decisions that produce legal or similarly significant effects on individuals without human involvement. Engagement scores, segments, send-time predictions, and workflow recommendations are all presented as suggestions that Authorized Users must review and activate.
If Engage introduces features that involve automated processing with legal or significant effects, Engage will: disclose this in advance; obtain any required consent; provide human review and override mechanisms; and update this Policy and the DPA accordingly.
9. Bias, Fairness, and Responsible AI
Model Selection
Engage evaluates providers and models against safety benchmarks and bias evaluations before deployment.
Output Filtering
Generative AI outputs are filtered for content that is discriminatory toward protected classes, hateful, or otherwise harmful.
Prohibited Outputs
AI features are configured to refuse requests to generate content targeting individuals based on protected characteristics, containing false authoritative claims, constituting deceptive advertising, or mimicking real individuals without disclosure.
Periodic Review
Engage conducts periodic reviews of AI output quality, bias indicators, and alignment with this Policy.
10. Responsible Use of AI Features
The following uses of AI features are expressly prohibited:
10.1 Fraud and Deception
10.2 Harmful and Illegal Content
10.3 Platform Abuse
11. AI Feature Opt-Out
AI features are opt-in — activated through explicit user action. Customers may disable AI features via: Settings → AI Features → Feature Controls; role management under Settings → Team → Roles; or by contacting privacy@nevtan.com. Disabling AI features does not affect access to non-AI platform functionality.
12. Regulatory Compliance
12.1 Global Privacy Laws
12.2 EU AI Act
The EU AI Act (Regulation (EU) 2024/1689) entered into force on 1 August 2024. Engage's assessment: no prohibited-risk systems are deployed; current AI features are not classified as high-risk under Annex III; transparency obligations for limited-risk systems are implemented in the product interface. Engage will update this Policy as obligations become effective and regulatory guidance develops.
12.3 Emerging AI Governance
Engage monitors developing AI governance frameworks globally. Material changes arising from new regulatory requirements will be communicated to Customers with at least 30 days' advance notice.
13. Changes to This Policy
Material changes — including new AI providers, new AI-processed data categories, or changes to AI training commitments — will be communicated at least 30 days in advance. Non-material updates take effect upon publication. The current version is always available at engage.nevtan.com/legal/ai-policy.
14. Contact
Privacy Officer
Email: privacy@nevtan.com
Security Team
Email: security@nevtan.com
Legal Team
Email: legal@nevtan.com