OttoLegal

AI transparency statement

Draft — must be reviewed by a qualified lawyer in the EU before publishing.

Words in [SQUARE BRACKETS] are placeholders to fill in. Notes marked Review, Decision, Verify or Engineering are for the reviewing lawyer and for Max; remove every one of them before publishing.

Version: Draft 0.1 · 30 September 2026 · In force from [EFFECTIVE DATE]

Otto is an AI marketing service: most of what it makes is made with AI. This page says what is made with AI and what is not, how AI-made images, video and voice are marked, and who decides what gets published. It is written with Article 50 of the EU AI Act (Regulation (EU) 2024/1689) in mind, whose transparency duties apply from 2 August 2026.

The short version

What is made with AI, and what is not

Part of Otto's outputMade with AI?How
Strategy, monthly plan, captions, ad headlines and texts, video scripts, creator briefsYesWritten by Anthropic's Claude models from the business's website, answers and past decisions. Checked automatically against the business's list of words to avoid and, for health brands, against rules on health claims.
Images for posts, reels and adsOftenGenerated with OpenAI's GPT Image 2 through Higgsfield (Leonardo.ai as a fallback).
Ad images built from templatesPartlyLayouts designed by our team, filled with the business's own logo, photos, prices and reviews; some templates also use an AI-generated image.
Reels and faceless video adsYes, partlyPut together automatically from images (often AI-generated), captions, motion templates and royalty-free music.
Voice-oversYesSynthetic voices from ElevenLabs, sometimes through Higgsfield. They are stock synthetic voices; Otto does not clone anyone's voice. Verify: the configured voice IDs are stock voices.
Reviews and customer quotesNoCopied word for word from the business's own website. Otto never writes a review or a testimonial.
Creator videos (a person talking to camera)NoFilmed by a real creator. Otto writes the brief, the script and the shot list; the video is only used once the footage arrives with the creator's name and consent.
Logos, product photos, prices, offersNoThe business's own, from its website or uploads.

No AI people presented as real

Otto never presents an AI-generated person as a real customer, patient or user, and never puts invented words in a real person's mouth. This is built into Otto: its ad planner rejects any plan that would show an AI-generated person as a customer. Otto also does not make images, video or audio that show a real person, or that could be taken for a real event, without that being clear (a "deepfake"). A business may not use Otto for that under our Terms (section 7).

How AI-made images, video and voice are marked

Under Article 50(2) of the AI Act, the provider of an AI system that generates images, video or audio must make sure the output is marked in a machine-readable way as AI-generated. Otto does this as follows:

Who approves what

Talking to Otto

When a business deals with Otto in the app, by e-mail or in Telegram, it is dealing with an AI system, which is clear from the product itself. Messages written by a person on our team are signed with that person's name. Verify Otto does not talk to a business's customers: it does not answer comments or messages on the business's behalf. If that changes, those customers will be told they are talking to AI.

Roles under the AI Act

Otto is the provider of the Otto system, which is built on general-purpose AI models from Anthropic, OpenAI (through Higgsfield and Leonardo), Higgsfield, Leonardo and ElevenLabs. The business that uses Otto and publishes its output is the deployer. Review: confirm this split, in particular whether Otto is also a deployer where it runs campaigns for the client, and whether Otto becomes a provider of a general-purpose AI system. Otto's uses are not "high-risk" under Annex III of the AI Act. Otto does not target ads by sensitive characteristics: its ad targeting uses only location and age.

Our team is trained in how Otto's AI works and where it fails (AI Act Article 4), and we give businesses guidance on what to check before approving.

Questions and concerns

If you think something Otto made is misleading, is not marked as it should be, or shows you without your consent, write to [CONTACT EMAIL]. We look at it within two business days and, where needed, ask the business to remove it.

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