This AI Usage & Transparency Policy (“Policy”) explains how Two Painters Studio, a trade name of Goya de Hoog Consultancy (“the Company,” “we,” “us”), registered with the KVK under number 96682329, uses artificial intelligence (AI) tools in its creative and brand packaging studio services, in accordance with Regulation (EU) 2024/1689 (the “EU AI Act”) and the GDPR / Uitvoeringswet AVG. A separate policy applies to the education consultancy activities operated under our registered name, Goya de Hoog Consultancy.
1. Purpose & Scope
This Policy covers our use of AI tools in delivering digital marketing, branding, and web design services to our clients, including internal drafting, creative support, and client communications.
2. Our Philosophy: Technology in Service of Creativity
We embrace technology where it makes our workflow more efficient, but we deliberately rely on AI as little as possible in the actual creative work itself. AI tools support research, drafting scaffolding, and administrative tasks; they do not replace the creative direction, concept development, and final judgment that our clients hire us for. Efficiency is the goal of using AI — not a substitute for craft.
3. Permitted Uses
AI tools may be used to assist with:
• Drafting or refining written copy for review and revision by our team
• Brainstorming and early-stage ideation support
• Minor image editing or generation assistance, where relevant to a project
• Administrative and scheduling support
Final designs, brand strategy, and creative concepts are always developed and authored by our human Creative Director and team, informed by AI-assisted input where used, never generated wholesale by AI and delivered unreviewed.
4. Human Oversight & Creative Integrity
Every deliverable is reviewed, refined, and approved by our Creative Director before it reaches a client. AI-assisted drafts are treated as a starting point, not a finished product, and are never delivered as final work without meaningful human creative revision.
5. Client Data & Confidentiality When Using AI Tools
Where client information (project briefs, logos, brand assets, or other business information) may be used with an AI tool, we take the following precautions:
• We use reputable AI providers and, where available, configurations that do not use submitted content to train the provider's underlying models
• We limit what is shared with AI tools to what is reasonably necessary for the task at hand
• Our use of AI tools is consistent with, and does not override, the commitments made in our Privacy Statement
6. Transparency With Clients
We are happy to disclose, on request, whether and how AI tools were used in producing a deliverable. Clients may request this information at any time by contacting us.
7. Disclosure of AI-Generated Public Content
In line with Article 50(2) of the EU AI Act, where content we publish publicly (for example, portfolio posts or marketing materials) is substantially AI-generated or AI-edited, we will label it as such where required and technically feasible. A limited grace period applies to the machine-readable marking of content from systems already in use before 2 August 2026, extending to 2 December 2026; content generated before 2 August 2026 does not require retroactive labelling.
8. No AI Chatbots for Direct Interaction
We do not use AI-driven chatbots to interact with clients or website visitors. If this changes in the future, we will update this Policy and add the disclosure required under Article 50(1) of the EU AI Act.
9. AI Literacy
In accordance with Article 4 of the EU AI Act, we ensure that team members and collaborators who use AI tools on our behalf understand those tools' capabilities and limitations, and know when human creative review is required.
10. Third-Party AI Providers
We use third-party AI providers for content drafting, image generation assistance, and administrative automation. We select providers based on their data protection terms and reliability, and review this selection periodically as tools and regulations evolve.
11. Questions or Complaints
For questions about this Policy or our use of AI, contact us at admin@twopainters.studio. Complaints regarding data protection aspects of our AI use may also be lodged with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
12. Changes to This Policy
We may update this Policy as our use of AI tools evolves or as EU and Dutch AI regulation develops. The version published on our website is the current version.
Version: 001 — Effective from: 01 August 2026