AI Transparency

Our Commitment to AI Transparency

At CCBONLINE Inc., we believe in transparency and responsible use of artificial intelligence. As a provider of AI-powered website development and customer service solutions, we are committed to being open about how we use AI technologies, how they benefit our clients, and how we protect your data.

This AI Transparency Statement (updated December 2025) explains our approach to AI, the technologies we use, the safeguards we have in place, and your rights regarding AI-driven services. We adhere to:

• Canadian Artificial Intelligence and Data Act (AIDA) - Part of Bill C-27 (Enacted 2025)
• Consumer Privacy Protection Act (CPPA) - Part of Bill C-27 (Enacted 2025)
• Directive on Automated Decision-Making - Government of Canada (Updated 2025)
• PIPEDA's AI Guidelines - Privacy Commissioner of Canada
• Quebec's Law 25 - AI and Automated Decision Systems provisions (Fully effective)
• Montreal Declaration for Responsible AI - Ethical AI principles
• OECD AI Principles - International best practices
• Voluntary Code of Conduct on Responsible AI - Innovation, Science and Economic Development Canada

As of December 2025, we are fully compliant with Canada's Artificial Intelligence and Data Act (AIDA), which establishes regulatory requirements for high-impact AI systems, including transparency obligations, risk assessments, and accountability measures.

How We Use Artificial Intelligence

CCBONLINE integrates AI technologies across our services to enhance efficiency, improve user experience, and deliver better outcomes for our clients. Here's how we use AI:

Our AI Principles

We are committed to developing and deploying AI systems that are ethical, responsible, and beneficial. Our AI principles guide every decision we make:

AI, Data, and Privacy (Updated December 2025)

When our AI systems process data, we follow strict privacy and security protocols aligned with Canada's evolving AI governance framework. Our practices include:

Data Minimization & Purpose Limitation

• Collect Only What's Needed: We only collect personal data necessary for the specific AI service being provided
• Purpose-Bound Processing: Data is used only for the purpose disclosed at collection time
• Time-Limited Storage: AI training data is retained only as long as needed, then securely deleted
• Anonymization First: Whenever possible, we anonymize or aggregate data before use in AI systems

AI Model Security (2025 Standards)

• Encryption: End-to-end encryption for data in transit and at rest (AES-256)
• Model Protection: Proprietary AI models are secured against unauthorized access and extraction
• Access Controls: Role-based access controls (RBAC) with multi-factor authentication
• Audit Trails: Complete logging of AI system access and decision-making processes
• Regular Security Testing: Quarterly penetration testing and vulnerability assessments

Your Data Rights with AI Systems

Under Quebec's Law 25, AIDA (enacted 2025), and CPPA regulations, you have comprehensive rights regarding AI processing:

• Right to Know: You can request information about what data our AI systems have processed about you
• Right to Explanation: You can request an explanation of AI-driven decisions that affect you
• Right to Human Review: You can request human review of automated decisions
• Right to Opt-Out: You can choose not to be subject to fully automated decision-making
• Right to Deletion: You can request deletion of your data from AI training datasets

All AI data handling complies with PIPEDA, Quebec's Law 25, AIDA (2025), CPPA (2025), and our comprehensive Privacy Policy. For technical details about our AI systems' data practices, contact our Data Protection Officer at privacy@ccbonline.ca.

Human Oversight and Control

While AI enhances our services, human experts remain at the center of critical decisions. We maintain human oversight throughout the AI lifecycle:

• Quality Review: Human experts review AI-generated content and recommendations before delivery
• Escalation Paths: Complex issues are automatically escalated to human specialists
• Continuous Monitoring: Our team monitors AI performance and intervenes when necessary
• Feedback Loops: User feedback is reviewed by humans to improve AI systems
• Override Capability: Human operators can always override AI decisions when appropriate

AIDA Compliance & AI Accountability (2025)

In compliance with Canada's Artificial Intelligence and Data Act (AIDA), enacted as part of Bill C-27 in 2025, CCBONLINE acknowledges specific responsibilities and obligations regarding the deployment and management of AI systems.

AI System Classification

AIDA classifies AI systems based on their impact level. CCBONLINE currently operates the following AI systems:

• General-Purpose AI Systems (Low to Medium Impact):
  • AI chatbots for customer service and support
  • Content generation and optimization tools
  • Website analytics and user behavior analysis
  • SEO and marketing optimization AI
• No High-Impact AI Systems: CCBONLINE does not currently deploy high-impact AI systems as defined by AIDA (those that pose significant risk to health, safety, human rights, or access to essential services)

AIDA Risk Assessment & Mitigation

We conduct regular risk assessments of all AI systems to identify and mitigate potential harms:

AI Transparency Obligations

Under AIDA, CCBONLINE provides the following disclosures:

• AI Identification: All AI-powered interactions are clearly labeled (e.g., "AI Assistant," "Powered by AI")
• Purpose Disclosure: We disclose the purpose of each AI system (customer support, content optimization, analytics, security)
• Data Processing Disclosure: We explain what data AI systems process and how it's used (see "AI, Data, and Privacy" section above)
• Automated Decision-Making Disclosure: We disclose when AI makes automated decisions and provide options for human review
• Limitation Disclosure: We clearly communicate AI limitations, accuracy levels, and potential errors (see "AI Limitations and Risks" below)

AI Accountability Framework

CCBONLINE has established an AI governance framework to ensure responsible AI deployment:

AI Incident Reporting

In compliance with AIDA's incident reporting requirements:

• Reportable AI Incidents: Any AI system failure, bias event, privacy breach, or harm caused by AI that meets AIDA's reporting thresholds
• Internal Reporting: Employees and clients can report AI incidents to ai@ccbonline.ca
• Regulatory Reporting: Serious AI incidents are reported to the AI and Data Commissioner within required timeframes
• User Notification: Affected users are notified of AI incidents that impact them, including remediation steps
• Incident Documentation: All AI incidents are documented and retained for at least 5 years as required by AIDA

No Automated High-Impact Decisions

Important Disclosure: CCBONLINE does NOT use AI for high-impact automated decision-making without human oversight. Specifically:

• ✅ AI Does NOT Make Final Decisions On:
  • Contract terms, pricing, or service eligibility (human approval required)
  • Employment decisions (hiring, firing, promotions)
  • Credit or financial decisions
  • Access to essential services
  • Legal or regulatory compliance determinations
• ✅ All Significant Decisions Involve Human Review: Human employees review and approve all business decisions that significantly affect clients
• ✅ Human Override Always Available: Clients can always request human review of any AI recommendation or action

AI Limitations and Risks

We are transparent about the capabilities and limitations of our AI systems. Understanding these limitations helps set appropriate expectations and ensures responsible use:

Known Limitations:

• Not Always Accurate: AI-generated responses may contain errors, inaccuracies, outdated information, or "hallucinations" (fabricated information presented as fact)
• Context Understanding: AI may misinterpret nuanced or ambiguous queries despite advances in natural language processing
• Cultural and Language Nuances: While we support bilingual services (English/Chinese), AI may not always capture cultural subtleties perfectly
• Creativity and Judgment: AI excels at pattern recognition but may lack the creative judgment, common sense, and ethical reasoning that humans provide
• Evolving Knowledge: AI models are trained on historical data and may not reflect the most recent developments, policy changes, or current events
• Bias Risk: Despite our bias testing, AI systems trained on historical data may inadvertently reflect societal biases present in training data
• No Legal or Professional Advice: AI responses do not constitute legal, financial, tax, medical, or other professional advice and should not be relied upon as such

Risk Mitigation:

We implement multiple layers of safeguards: human review of AI outputs, regular model updates, bias testing, user feedback mechanisms, and clear escalation paths. We continuously monitor AI performance and adjust systems based on real-world results. Critical decisions always involve human oversight.

Your Rights Regarding AI (AIDA, CPPA, Law 25)

Under Canada's Artificial Intelligence and Data Act (AIDA), Consumer Privacy Protection Act (CPPA), Quebec's Law 25, and PIPEDA, you have comprehensive rights when interacting with our AI-powered services:

Transparency Rights

• Right to Know When Interacting with AI: You have the right to know when you're interacting with an AI system versus a human agent. We clearly label all AI interactions.
• Right to Information About AI Systems: You can request information about:
  • What AI systems we use and their purposes
  • How AI systems process your data
  • What data is used to train AI models
  • How AI decisions are made (explainability)
• Right to Explanation: You can request a clear, understandable explanation of any AI-driven decision, recommendation, or action that affects you

Control & Opt-Out Rights

• Right to Opt-Out of AI: You can request human assistance instead of AI-powered services at any time by:
  • Emailing info@ccbonline.ca with "Human Support Request"
  • Calling +1 (647) 568-1128 and asking for a human representative
  • Using the "Speak to Human" option in our chatbot (if available)
• Right to Human Review: You can request human review of any automated decision, including:
  • AI-generated quotes or pricing
  • AI content recommendations
  • AI customer service responses
  • AI-driven project suggestions
• Right to Challenge AI Decisions: You can dispute or appeal AI decisions through our human support team, who will conduct an independent review

Data Rights Related to AI

• Right to Access AI Data: You can request a copy of your data that has been processed by AI systems
• Right to Correct AI Data: You can request correction of inaccurate data used by AI systems
• Right to Delete AI Data: You can request deletion of your data from AI training datasets and active AI systems (subject to legal retention requirements)
• Right to Data Portability: You can request your AI-processed data in a structured, machine-readable format
• Right to Object to AI Processing: You can object to specific AI processing activities that affect you
• Right to Restrict AI Processing: You can request temporary restriction of AI processing while disputes are resolved

Complaint & Redress Rights

• Right to File Complaints: You can file complaints about AI systems with:
  • CCBONLINE: ai@ccbonline.ca
  • Privacy Commissioner of Canada: If AIDA/PIPEDA violations are suspected
  • AI and Data Commissioner: For AIDA-specific concerns (once operational)
  • Quebec's CAI: For Law 25 violations (Quebec residents)
• Right to Compensation: If you suffer harm due to AI system failures or AIDA violations, you may be entitled to compensation under AIDA's liability framework

Questions About Our AI Use?

We welcome your questions, feedback, and concerns about our use of AI. Your input helps us improve our systems and practices:

Updates to This Statement

As AI technology evolves and our practices improve, we will update this AI Transparency Statement. Material changes will be communicated through our website and via email to registered users. We encourage you to review this statement periodically.

Last Updated: December 7, 2025