1. Purpose and Application
This Artificial Intelligence Use & Client Data Protection Addendum (“AI Addendum”) supplements Pullman Marketing’s Terms of Service and applies to artificial intelligence and automated processing technologies used in providing services to CLIENT.
This AI Addendum is incorporated into the parties’ Agreement when referenced or accepted through an applicable Order or other authorized agreement.
The existing Agreement, including its order of precedence, confidentiality provisions, intellectual property provisions, and Data Privacy Addendum (“DPA”), remains in effect. Nothing in this AI Addendum authorizes a use or disclosure of Personal Data otherwise prohibited by the Agreement or applicable law.
2. Use of Artificial Intelligence
Pullman Marketing may use approved artificial intelligence tools to assist with:
- Marketing strategy, planning and research
- Drafting, editing and reviewing marketing content
- Graphic design, image development and video production
- Website development and technical troubleshooting
- Search engine optimization and advertising analysis
- Reporting, analytics and campaign optimization
- Internal administration and project management
AI-assisted tools support the work of Pullman Marketing’s employees and contractors. Pullman Marketing remains responsible for managing its services, applying appropriate professional judgment, and conducting reasonable quality reviews.
Use of an AI-assisted tool does not, by itself, change the fees, ownership provisions, or scope of services agreed upon with CLIENT.
3. Permitted Marketing Data
Subject to applicable confidentiality obligations, client instructions and approved security controls, Pullman Marketing may process the following information using authorized systems:
A. Public or approved business information
- Published website content
- Publicly available company and professional information
- Approved branding, marketing materials and product descriptions
- Client-approved photographs, videos and creative assets
B. Marketing and performance information
- Non-sensitive website analytics
- Advertising campaign results
- Aggregated performance measurements
- Anonymized or appropriately de-identified reporting data
- Search engine and market research information
C. Authorized customer and prospect information
Business contact information, marketing subscriptions, lead records and CRM information may be processed only when reasonably necessary for contracted services and within an approved system that has appropriate access controls and data-protection terms.
Permission to process such information for marketing services does not automatically authorize submitting it to a general-purpose AI application.
4. Restricted and Sensitive Information
Unless specifically authorized through a separate written agreement and an approved processing arrangement, CLIENT shall not provide, and Pullman Marketing shall not intentionally submit into AI systems, the following restricted information:
- Protected Health Information and identifiable patient records
- Social Security numbers, government identification numbers or copies of identification documents
- Complete payment-card information or security codes
- Bank account credentials, account numbers or sensitive financial authentication information
- Nonpublic investment holdings, client financial plans, individual tax records or confidential financial-advisory account records
- Passwords, private keys, access tokens, recovery codes or other authentication secrets
- Sensitive information concerning children or students
- Legally privileged communications or similarly protected records
- Other categories of sensitive personal information requiring specialized statutory, contractual or regulatory safeguards
Confidential business information, nonpublic client documents, customer lists and proprietary records may be used only in systems and workflows specifically approved for that purpose.
Where possible, unnecessary identifying information shall be removed before materials are processed.
5. Approved AI Systems and Third-Party Providers
Pullman Marketing will maintain an internal process for approving AI tools used with client information.
Approval shall consider, as appropriate:
- The business purpose of the tool
- Access restrictions and account security
- Vendor data-use, retention and model-training terms
- Confidentiality and contractual safeguards
- Whether Personal Data or other restricted information will be processed
- Available logging, deletion and administrative controls
Client confidential information may not be submitted to unapproved personal AI accounts.
Pullman Marketing will not knowingly authorize the use of CLIENT’s Confidential Information to train publicly available general-purpose AI models without appropriate authorization from CLIENT.
Where an AI provider processes Personal Data on Pullman Marketing’s behalf, the applicable DPA, subprocessor requirements and client instructions will govern that processing.
6. Human Review and Quality Control
Pullman Marketing will apply appropriate human review to AI-assisted work before final publication or delivery.
Review may include checking factual accuracy, client instructions, branding, originality, licensing, references, and applicable advertising requirements.
AI-generated content may contain errors, omissions or material that is not eligible for exclusive intellectual property protection. Pullman Marketing does not guarantee that AI-assisted output will be error-free or independently copyrightable.
The intellectual property provisions of the underlying Agreement remain applicable, subject to applicable law and third-party rights.
7. Regulated Marketing and Client Approval
Clients operating in regulated industries remain responsible for identifying applicable advertising, disclosure, privacy and professional compliance requirements.
For financial services, healthcare, legal services and other regulated industries, materials requiring client compliance approval shall not be published until the designated client representative approves them through the agreed workflow.
Pullman Marketing will not knowingly fabricate endorsements, testimonials, performance results, credentials or customer experiences through AI tools.
Synthetic portrayals, including simulated individuals, voices and likenesses, require appropriate authorization and disclosure when applicable.
8. Automated Actions and Connected AI Agents
AI tools or agents connected to client accounts shall operate only within authorized access and task boundaries.
Unless CLIENT has expressly authorized an automated workflow, material actions such as publishing content, sending customer communications, altering production settings, purchasing advertising, modifying permissions or deleting data require appropriate human authorization.
Access shall be limited to what is reasonably necessary for the approved work.
9. Data Storage, Retention and Export
Client information shall be stored in approved systems for purposes consistent with the Agreement.
Unless otherwise required by law or specified in an applicable Order, Pullman Marketing’s proposed standard retention schedule is:
| Data category | Retention Schedule |
|---|---|
| Temporary client-upload or transfer files | Up to 30 days after confirmed successful transfer |
| Active project working files | During active work and up to 90 days after completion |
| Final deliverables and designated client archives | Up to 3 months after completion or termination |
| Export access following termination | Client may request available client-owned materials within 30 days |
| Routine system backups | Rolling retention, targeted at 30–90 days, according to the approved backup provider’s actual capabilities |
| Contract, billing, security and compliance records | According to applicable law, the DPA and documented retention requirements |
Extended archival storage, particularly for large video, photography or other media libraries, may be offered under a separate written arrangement.
Pullman Marketing may retain information as necessary to comply with legal obligations, preserve records relevant to disputes or security events, or satisfy other lawful requirements.
Deletion from active systems does not necessarily result in immediate deletion from disaster-recovery backups or third-party services. Backup copies will expire according to their established retention cycles, subject to legal holds or other applicable exceptions.
Upon termination and settlement of applicable accounts, client-owned deliverables and electronic materials will be made available according to the Terms of Service. Retrieval of archived materials may be subject to applicable de-archiving charges. Pullman Marketing makes no guarantees and is absolved from any liability related to data retention.
10. Client Requests and AI Restrictions
CLIENT may request limitations on the use of AI in connection with its services.
Any special restrictions, prohibited tools, additional approval requirements or regulated-data processing obligations must be documented and agreed upon in writing.
Restrictions may affect project scope, delivery schedules, available services or pricing, which the parties will address before implementation.
11. Confidentiality and Security Events
Confidentiality obligations remain in effect regardless of whether information is processed manually, through conventional software or through approved AI systems.
Security events involving Personal Data will be handled under the notification, investigation and cooperation obligations established by the Data Privacy Addendum.
12. Updates
Pullman Marketing may revise this AI Addendum as technology, industry standards and legal requirements evolve, subject to the notice and amendment requirements of the underlying Agreement.
Material changes affecting existing contractual obligations will be implemented in accordance with the applicable Agreement.