AI Regulation – Leveraging Artificial Intelligence (AI)
1. General Information
2. Use of AI Systems at SnapCube
3. AI-generated Content & Transparency
4. Classification as Low-risk AI System
5. Technical and Organizational Measures
6. Ethical Principles of AI Usage
7. Internal Compliance and Training
8. Amendments to this AI Policy
1. General Information
We, SnapNext GmbH & Co. KG (operators of the SnapCube® brand), place a high value on responsible and transparent use of Artificial Intelligence. With this AI policy, we inform you about how we use AI systems on our website and products, and the measures we take to meet the requirements of the European AI Act.
This AI policy applies to:
our website www.snapcube.de, and
all SnapCube® products and services that use AI technologies (e.g., the SnapCube® AI filter in our photo booths and web apps).
You will learn which content is AI-generated, how we ensure transparency, and why our offerings are classified as a "low-risk AI system" according to the EU AI Act. We also describe the technical precautions and ethical principles we follow in our use of AI, as well as our internal processes to ensure compliance.
2. Use of AI Systems at SnapCube
SnapCube® utilizes AI technology to create unique photo and video experiences for you. Specifically, modern AI models—including diffusion models like Stable Diffusion—are employed to generate new visual content based on uploaded photos and your dynamic inputs (e.g., text inputs for image descriptions or theme style selection). Your photo can be transformed into a whimsical scenario or enhanced with special artistic effects using AI.
The use of these AI functions is always initiated by you—you decide whether a photo is processed with an AI filter. The underlying AI system analyzes the provided image purely technically, without collecting any additional personal information. No personal data beyond the uploaded photo is processed. In particular, we refrain from any identification of people depicted or systematic evaluation of sensitive features of the photo.
The AI-generated results (images and possibly videos) are made available to you or authorized persons—such as event participants—via a QR code or download link. We use the captured photos solely for the intended AI generation and delivery of the result. Further usage of your images, such as for training our models, does not take place. Once processing is complete, recordings are stored only as long as necessary (details can be found in our privacy policy).
3. AI-generated Content & Transparency
Transparency is key: We clearly indicate when content has been generated by AI and when you are interacting with AI. You will be explicitly informed at appropriate points that an AI system is in use—such as directly in the web app or on the display of our photo booths when using the AI filter. This ensures you're always aware that the following result has been created with AI assistance, not handcrafted by humans.
All images and videos generated by our AI are also technically marked. We incorporate metadata (following IPTC/XMP standards) into each AI-generated file, making it machine-readable to confirm that the content was artificially generated or manipulated. This ensures the AI-origin of the visual material is traceable, even in later use. Where technically feasible, we use additional visible cues or watermarks for identification, without affecting the user experience.
These measures ensure that AI content is always recognizable as such. They meet the transparency obligations of the EU AI Act: users must know when they are dealing with an AI or consuming AI-generated content. Our system is designed without misleading or manipulative functions, serving the clear purpose of creating creatively edited images without deceiving you.
4. Classification as Low-risk AI System
Our AI systems used at SnapCube® are classified as "low-risk AI systems" according to the EU AI Act. This means our offerings are not categorized under prohibited or high-risk categories. We use AI exclusively for creative photo and video applications in entertainment and marketing contexts—not for critical security decisions, scoring, surveillance, or other high-risk purposes affecting user rights. Accordingly, we primarily comply with specific transparency requirements, not stringent certification or reporting obligations like those for high-risk AI.
As providers of a low-risk AI system, we fulfill our duties by particularly ensuring transparency (see section 3) and enhancing our employees' AI expertise (see section 7). We have internally reviewed and documented that our use cases fit this risk category. Should the legal framework change or our system gain a higher risk profile, we will immediately take action to ensure ongoing full compliance. Currently, our AI functions are permissible and—adhering to stipulated care and transparency obligations—considered safe under the AI regulation, assured by the outlined measures.
5. Technical and Organizational Measures
We implement various technical and organizational measures with our AI systems to ensure a secure, reliable, and privacy-compliant operation:
Content Filters and Usage Limits: Our AI models are equipped with filtering mechanisms to prevent inappropriate or dangerous content (e.g., glorifying violence or pornographic depictions). We define clear usage policies for AI filters, ensuring their use only within the prescribed scope—for creative, theme-specific image generation.
Quality Assurance: Before publishing a new AI function, it is thoroughly tested. We verify generated results for quality, accuracy, and any undesirable effects (such as distortions or biases). We continuously monitor AI performance during operation and make necessary adjustments to quickly address any errors or deviations.
Data Security: Image processing by AI takes place on secure, controlled servers in Germany. We protect transmitted data through encryption and limit access to authorized personnel. Your photos are not forwarded to external AI services or third parties but processed within our infrastructure, ensuring a high level of data protection and control over data flows.
Data Minimization: We collect only the data necessary for the AI service (typically just the photo and any entered prompts or selection criteria). These data are used solely for image/video generation as per the purpose limitation principle. Storage occurs only as long as necessary; uploaded recordings are automatically deleted after a defined period (details are provided in our privacy policy).
Robustness and Reliability: Our developers ensure that AI systems function stably and reliably. We keep AI models updated with the latest technology and install necessary updates or enhancements to guarantee security and stability. We promptly react with countermeasures to new findings about potential risks or weaknesses, keeping AI usage continually secure.
6. Ethical Principles of AI Usage
We emphasize a trustworthy and human-centered approach to AI. We adhere to the following ethical principles:
Fairness and Non-Discrimination: Our AI must function equally for all users. We ensure no one is disadvantaged or represented stereotypically based on attributes such as skin color, gender, or origin through generated content. If bias or unfairness in results is detected, we actively counter it.
Transparency: Being open about AI usage is crucial (see section 3 above). We clearly communicate where and how AI is used. No AI functions are hidden. As users, you always know when a result is AI-generated and not crafted by humans.
Safety and Protection: User safety is a priority. We ensure AI applications pose no physical or psychological threat. Through content controls and testing, we prevent the generation of potentially harmful or offensive content by AI. Moreover, we guarantee controlled use of AI offerings (e.g., at events always supervised by our team).
Privacy: We respect your privacy. Personal data is used only within the necessary scope for the AI service (see Data Minimization above) and never for other purposes without legal basis or your consent. We adhere to all relevant privacy principles (especially GDPR) like purpose limitation, data security, and retention periods. Your data belongs to you—it will not be used otherwise without your consent.
Accountability: We take responsibility for our AI usage. SnapNext has defined internal responsibilities to oversee compliance with all regulations and principles in AI usage (see section 7). For questions or problems related to our AI, we are available to provide solutions transparently. Additionally, our AI systems undergo continuous review to maintain high ethical standards.
7. Internal Compliance and Training
Behind the scenes, we ensure AI usage meets our standards and legal requirements:
Training and Expertise: Our employees receive regular training on the use of AI systems. We foster AI competence within the team so that everyone involved fully understands the operation of our models, legal requirements (e.g., EU AI Act, GDPR), and our ethical guidelines. New employees and partners are also introduced to our AI policies and processes.
Internal Policies & Processes: We have defined clear internal guidelines for the development and operation of AI functions. This includes an internal AI policy and a code of conduct all must adhere to. Compliance with these guidelines is overseen by the management and our Data Protection/Compliance team.
Documentation (Procedural Directory): We maintain an internal directory of all AI applications and related processing activities. It records the purpose of AI usage, its operation, processed data, and implemented protection measures. This procedural directory helps us keep track and provide information to authorities if necessary.
Review and Development: We regularly review our AI systems and their usage. If new risks or improvement opportunities are identified, we adjust our processes and technical measures. We stay informed about developments in AI law and technology to respond promptly. Our AI policy is also evaluated and updated at defined intervals if required.
Contact Persons and Notifications: We have designated contacts for AI usage questions (including our Data Protection Officer, reachable at datenschutz@snapnext.de). Users and clients can contact us with any uncertainties or observations. There are established procedures for handling incidents or complaints related to our AI systems internally and notifying relevant authorities if necessary.
8. Amendments to this AI Policy
We reserve the right to adapt this AI policy as needed to account for new legal or technical developments. Should further implementation of the EU AI Act or changes in our offerings prompt updates, this policy will be revised accordingly. The current version of this AI policy will be published on our website.
Effective date: May 21, 2025