Artificial Intelligence Policy

Propeller Ads Limited (Cyprus) and Propeller Ads Limited (Isle of Man) (referred to as “Propush.me” or “we” or “us” or “our”) operate a traffic-monetization network that enables publishers and other clients to collect and monetize subscribers and to build and customize monetization tools (such as landing pages), connecting clients and advertisers through a range of ad formats and AI-powered tools available at propush.me.

Propush.me leverages the latest developments in artificial intelligence (“AI”) to deliver a smarter, faster and safer monetization experience across digital channels.

This Artificial Intelligence Policy (“AI Policy”) outlines how Propush.me develops, procures, deploys, and governs AI and machine-learning systems used in connection with its services.

This AI Policy applies to all AI Systems operated by Propush.me, to anyone engaged in AI-related activities on Propush.me’s AI Systems, and to all Clients whose content, subscribers, campaigns or monetization tools are processed by Propush.me’s AI Systems.

This AI Policy also applies to any artificial-intelligence system, software agent, large language model, model-context-protocol (MCP) server or client, or automated assistant that a Client authorises, deploys, or connects to the Propush.me Network, services, or API to access an account or manage monetization activities on the Client’s behalf (a “Connected AI Agent”). Each Client remains fully responsible for any Connected AI Agent it connects, as set out in this Policy, the Propush.me Terms & Conditions, the AI Assistant Rules and (in respect of the Constructor) the Constructor Rules. For clarity, a Connected AI Agent is deployed by the Client and is distinct from the AI Systems operated by Propush.me.

How We Use AI

Propush.me is committed to the responsible development, deployment and use of AI systems within its Network and Services, including but not limited to the Propush.me AI Assistant; the Constructor; fraud detection, traffic-quality scoring, anti-spam and content-moderation systems; and recommendation, forecasting and optimization tools used to improve monetization performance (collectively, the “AI Systems”).

Our AI Systems are designed to enhance Client productivity and improve the monetization experience, including assistance with onboarding, tool creation and customization, performance reporting and optimization.

Propush.me uses AI and machine learning specifically for the following purposes:

  • generation and customization of monetization tools and creative content (landing pages, images, copy);
  • AI-assisted client support, guidance and information about the Service;
  • fraud detection, traffic-quality scoring and anti-abuse controls;
  • content and policy moderation of inputs and generated outputs;
  • predictive analytics, forecasting and optimization of monetization performance.

Based on our current assessment, the AI Systems we operate are intended for monetization-related functions such as tool creation, customization, support, optimization, analytics and reporting, and are not designed or used for any purpose that would be classified as high-risk or prohibited under applicable law. We do not carry out extensive profiling or large-scale predictive analytics of the kind associated with high-risk AI.

Client inputs, prompts, content, queries, interactions with AI-assisted tools or AI-generated content, and any resulting outputs submitted to or received through our Network and services may be processed by Propush.me, and where applicable by our authorised third-party providers and subprocessors, for the purpose of generating responses and delivering the requested services. We may use aggregated, anonymised, or otherwise non-personal information to monitor, maintain and improve the performance, accuracy and reliability of our AI Systems and services, in accordance with applicable laws and our Privacy Policy.

Where a Client has exercised their right to opt out of the use of their inputs for the development of Propush.me AI Systems, Propush.me will not use or share any content inputted into, or received from, our AI Systems for the purposes of using, refining or otherwise improving our AI models and systems. This commitment applies for as long as the opt-out preference remains in effect. Clients may review and update their opt-out preferences at any time through the designated opt-out mechanisms made available within the applicable rules or privacy controls.

We also use AI-powered tools internally to support our own teams — for example, to log, transcribe, summarise and analyse business communications between our staff and clients or partners, and to prepare internal reports. Outputs of such internal tools are used to assist our personnel, are subject to human review, and are not used to take decisions producing legal or similarly significant effects concerning any individual by solely automated means. Personal data processed by such tools is handled in accordance with our Privacy Policy.

Prohibited AI Practices

The following practices are strictly prohibited on the Propush.me Network and services:

  • Subliminal and Manipulative Techniques: the deployment of AI systems that use subliminal techniques beyond a person’s consciousness, or that exploit psychological weaknesses or cognitive biases to distort behaviour in a manner that causes or is likely to cause physical, psychological, or financial harm.
  • Exploitation of Vulnerable Groups: AI systems that exploit any known vulnerability of a specific group of persons, including vulnerability due to age, disability, or specific social or economic situation, to distort the behaviour of those groups in a way that is likely to cause harm.
  • Social Scoring: AI systems used by or on behalf of public authorities for general-purpose social scoring of natural persons.
  • Real-Time Remote Biometric Identification: the use of real-time remote biometric identification systems in publicly accessible spaces for law-enforcement purposes.
  • Emotion Recognition in Prohibited Contexts: AI systems that infer emotions of natural persons in the context of the workplace and educational institutions, except for medical or safety reasons.
  • Biometric Categorisation Based on Sensitive Attributes: AI systems that categorise natural persons based on their biometric data to deduce or infer race, political opinion, trade-union membership, religious or philosophical beliefs, sex life, or sexual orientation.

Data and Privacy

The collection, use and processing of personal data in Propush.me’s AI Systems is conducted in accordance with our Privacy Policy.

All personal data in our AI Systems is used for the purpose for which it was collected and is processed on a clearly documented and legitimate basis.

AI systems are designed, procured, and configured to use the minimum amount of personal data necessary to achieve the intended purpose. Where anonymisation or pseudonymisation can achieve equivalent functional outcomes, such techniques are preferred.

Clients must not submit personal data to the Propush.me AI Assistant, as further set out in the AI Assistant Rules, the Constructor Rules and Terms & Conditions. The use of sensitive categories of personal data, including any information relating to, or capable of inferring, an individual’s health status, religious beliefs, political views, or sexual orientation, is strictly prohibited for the purposes of AI-driven targeting, profiling, or any related automated processing throughout the Propush.me Network and Services.

The Propush.me Network and Services are intended for businesses and are not directed to, or available for use by, minors or persons lacking full legal capacity. We do not knowingly process the personal data of minors through our AI Systems, and AI-driven targeting of children is not permitted.

Where you connect a Connected AI Agent or use a third-party AI provider to access your account or the API, you direct Propush.me to make available to that agent or provider the account and related data necessary for the operations you request. You act as controller (or otherwise as the responsible party) in respect of any subsequent processing of such data by that agent or provider, and Propush.me is not responsible for that processing. Such transfers may involve recipients located outside the EEA, as further described in our Privacy Policy.

Security

Propush.me applies reasonable and proportionate safeguards designed to protect user safety, prevent harm to individuals, and maintain the integrity of its Network and Services. Ethical considerations and security requirements are embedded throughout our design and development lifecycle, with appropriate controls in place to detect, prevent and report instances of misuse or abuse.

Where Propush.me operates or deploys a chatbot, virtual assistant, or any other AI-powered system that engages directly with individuals (including the Propush.me AI Assistant), we will clearly inform users that they are interacting with an automated AI system rather than a human representative, prominently and at the earliest practicable point of engagement. Where our features incorporate or depend upon third-party AI platforms or providers, such integrations will be clearly identified through designated markers, labels, interactive tooltips, or such other notification methods as Propush.me deems appropriate.

Each AI system deployed at Propush.me is assigned measurable performance and quality thresholds, and any third-party AI vendors working with us must confirm their compliance status with applicable legislation and standards, and notify us of any AI incident that could affect our own compliance. AI system outputs, performance metrics and anomaly events are logged in a manner that enables retrospective auditing.

Propush.me recognises the fundamental importance of meaningful human oversight in the governance of AI systems. In furtherance of this commitment, significant automated decisions with material consequences shall, where required by applicable law, be subject to human review. Our authorised personnel are empowered to intervene in, override, suspend, or fully deactivate any AI System at any time and without delay.

Our policies, procedures and internal governance frameworks are subject to periodic review and revision to ensure ongoing compliance with applicable data-protection laws, regulations and recognised industry standards.

Client Responsibilities and Rights

By using the Propush.me Network and Services and when engaging with our AI Systems, you agree to comply with this AI Policy, including the following principles:

  • not to submit AI-generated content that is deceptive or manipulative;
  • not to use AI Systems to create monetization tools or content that violates the Terms & Conditions, the AI Assistant Rules, or applicable law;
  • not to deploy AI systems on our Network that violate this AI Policy;
  • not to deliberately remove, conceal or manipulate AI-identification labels or metadata, and to ensure that all AI-generated outputs or creative assets are properly labelled where required before use;
  • to exercise sound judgment when interacting with our AI Systems and to independently evaluate any AI output or generated content for accuracy, reliability, and appropriateness prior to use or implementation;
    NOTE: you are solely responsible for the compliance of your use of any AI System with the Propush.me Terms & Conditions, this AI Policy, the AI Assistant Rules, the Constructor Rules and any special rules as may be applicable (including those communicated via the interface of any of our platforms), as well as for ensuring the same compliance of any results or outputs of such use. In no case shall Propush.me be responsible or accountable for any of your activities or decisions engaging our AI Systems, including but not limited to any activities or decisions related to monetization tools or landing pages drafted with the assistance of any AI System.
  • to apply human oversight and review before deployment or commercial use of AI output or generated content, to help identify potential defects, intellectual-property concerns, security vulnerabilities, or the unintended disclosure of confidential or proprietary information;
  • to hold all necessary legal bases for any personal data submitted into AI Systems, noting that submission of personal data to the AI Assistant is prohibited;
  • to ensure that any AI-driven personalisation content on your properties is disclosed to end users in accordance with applicable law;
  • to maintain AI-usage records and make them available to Propush.me on request and when required for regulatory compliance;
  • to promptly notify Propush.me if you become aware of any AI system operating on the Propush.me Network or Services that may violate this AI Policy.

Subject to and in accordance with applicable law, natural persons affected by AI Systems operated by Propush.me have the following rights:

  • Right to transparency: request information about how AI processes your data.
  • Right to object to AI profiling: opt out of interest-based profiling and AI-driven personalisation at any time.
  • Right to human review: request manual review of any decision made solely by an AI automated process with significant effect.
  • Right to explanation: receive a plain-language explanation of any automated decision.
  • Right to withdraw consent: withdraw consent for AI-based processing at any time.

Subject to your compliance with the Propush.me Terms & Conditions, this AI Policy and other applicable rules and regulations, you may retain rights in the specific pieces of AI outputs to the extent such rights are capable of being owned by you under applicable law. You acknowledge that outputs are not unique by default, that the Constructor operates on standardised templates made available to multiple users, and that Propush.me does not guarantee the exclusivity of any AI System output.

Connected AI Agent Use Responsibilities

Where you connect or authorise a Connected AI Agent to access your account or the API, you additionally agree that:

  • you are solely responsible for selecting, configuring, instructing, monitoring and controlling the Connected AI Agent, and for all of its actions, requests and outputs, which are deemed to be your own;
  • you will connect a Connected AI Agent only to your own account, using valid API Credentials issued to or generated by you, and will keep those credentials confidential and not share them with any third party other than the Connected AI Agent acting on your behalf;
  • you will ensure the Connected AI Agent operates within the rate limits, security requirements and technical rules published by Propush.me, and will not use it to exceed your permitted access, circumvent security or access controls, place undue load on, disrupt or interfere with the services, or access any account other than your own;
  • you will apply meaningful human oversight to material decisions taken by the Connected AI Agent, and you accept responsibility for any erroneous or unintended action;
  • you hold a lawful basis and all necessary rights for any data that you, or the Connected AI Agent, transmit to or through Propush.me or to any third-party AI provider in connection with such use, and your use of any third-party AI provider complies with that provider’s terms and applicable law;
  • Propush.me is not responsible for, and gives no warranty in respect of, any Connected AI Agent, any third-party AI provider you use, or any outcome of their use; and
  • you will promptly notify Propush.me of any compromise of API Credentials or of any Connected AI Agent operating in breach of this Policy or of the Propush.me Terms & Conditions.

Enforcement

Violations of this AI Policy are treated at Propush.me’s sole discretion, and Propush.me reserves the right to take one or more of the following actions in response: (a) immediate suspension or permanent termination of the Client’s account(s); (b) withholding of account balances pending investigation of AI-related fraud or AI Policy violations; (c) removal of non-compliant AI-generated monetization tools, landing pages or creatives from the Propush.me Network; (d) restriction, disabling or removal of access to the AI Assistant, the Constructor or any generated content; (e) pursuit of civil or criminal remedies where losses or harm result from the violation; (f) any other legal action available; and (g) suspension, throttling, or revocation of API access and/or any Connected AI Agent’s access to the Network and Services.

Policy Updates

We may review and update this AI Policy from time to time by publishing a new version of it on our website. Clients are encouraged to review this AI Policy periodically so as to always be informed about how we use AI. This AI Policy forms part of, and must be read together with, the Propush.me Terms & Conditions, the AI Assistant Rules and the Constructor Rules. It is governed by, and shall be construed in accordance with, the laws of the Republic of Cyprus. In the event of any conflict between this AI Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

Contacts

For all queries, complaints or requests relating to this AI Policy please contact us via email at: dpo@propush.me.

Last update: July 24, 2026