Responsible Growth and Responsible AI

In brief

Persooa is a remote-first consulting, implementation and operations organization focused on the Synerise ecosystem. We help retail networks, e-commerce brands, financial institutions and consumer companies build data-driven growth - with no compromises on privacy, security and AI ethics.

This is our position: how we understand responsible growth and how we work with data, AI and customers day to day. These are not declarations for show - they are backed by written internal policies, which we link to below.

Our thesis: in CDP, loyalty, AI recommendations and agentic commerce projects, the model alone does not decide the advantage. What decides it is whether you can grow fast and responsibly - with human oversight, data governance and full customer control over their data.

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Seven pillars of responsible growth

Pillar	What it means in practice
🧭 Responsible AI	Human in the decision loop, explainability, bias mitigation, control over generative AI.
🤝 Ethical personalization	Personalization that serves the customer - it does not exploit vulnerabilities or manipulate.
🗂️ Customer-data governance	Data minimization, consent management, clear data ownership on the customer's side.
🔒 Privacy & Security by design	Privacy and security built into the architecture, not bolted on at the end.
👤 Human oversight	Critical decisions remain under human supervision - AI supports, it does not replace responsibility.
🛡️ Business integrity	Internal policies: anti-corruption (Transparency International, PEP screening), conflict of interest (independent assessment, register), competition law (ban on bid-rigging), protection of trade secrets.
🌱 Sustainable digital operations	A remote-first, cloud-first model, a low travel footprint and paperless operations.

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Our policies and declarations

This position is backed by specific, written documents. We make them publicly available:

Document	Area
Responsible Growth Policy	ESG and operations
Responsible AI Policy	AI governance
Customer Data Ethics Charter	Data ethics and privacy
Security & Governance Statement	Security
Supplier Sustainability Statement	Sustainability
Frequently asked questions (FAQ)	Compliance and governance
Executive One-Pager	Summary for the board

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Our philosophy

We believe that responsible growth emerges at the intersection of three things: value for the customer, operational discipline and trust. In the era of AI agents, this trust becomes an asset of strategic importance - easy to lose, hard to rebuild.

That is why Persooa does not treat governance as a compliance cost. We treat it as part of the product. Every personalization scenario, every decision model and every agent we launch is designed to pass three tests:

• The value test: does this genuinely help the end customer?
• The transparency test: can we explain why it works the way it does?
• The control test: do the customer (the company) and the end customer retain control over their data and the decision?

These principles are embedded in the public Persooa Code of Conduct, which covers integrity and compliance with the law, anti-corruption, conflict of interest, protection of confidential information and intellectual property, equal treatment, and reporting violations without the risk of retaliation.

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Responsible Personalization

Personalization is only effective when it is trustworthy. Our approach:

• Value instead of exploitation - we recommend what serves the customer over the long term (CLV), not only what maximizes a single transaction.
• Frequency capping and contact hygiene - we protect the customer from an excess of communication.
• No dark patterns - we do not design mechanics based on pressure, false urgency or hiding the opt-out.
• Sensitive segments - special caution toward vulnerable groups; we do not target on the basis of sensitive characteristics.

→ Details: Customer Data Ethics Charter

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Responsible AI

Every AI deployment at Persooa operates within our Responsible AI Policy. The key principles:

• Human-in-the-loop for decisions with a significant impact on the customer.
• Explainability - we can describe the logic of our decision and recommendation models.
• Data minimization - the model receives only the data it genuinely needs.
• Bias mitigation - we test models for unintended discrimination.
• Generative AI principles - control over where and how we use GenAI, with human verification.

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Data Privacy & Security

Customer data is a resource entrusted to us, not our property. That is why:

• We operate in accordance with GDPR as a processor acting on behalf of the customer.
• We apply privacy by design & by default and the least privilege principle.
• We maintain access management, team security awareness and an incident management process.
• The customer retains full ownership of their data - including after the engagement ends.
• We protect not only personal data but also the customer's confidential information and trade secrets - within a formalized Trade Secret Protection System, with readiness to sign an NDA and flow-down of confidentiality obligations to subcontractors.

The data-processing layer is usually the Synerise platform, which - according to its official statement (synerise.com/security) - provides enterprise-grade security together with SOC 2, GDPR and CCPA compliance. Persooa is responsible for the secure configuration and operation of this platform within the customer's project.

→ Details: Security & Governance Statement

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Ethical Customer Engagement

Agentic commerce changes the rules of the game - AI agents can act on behalf of the brand and the customer. This raises the bar for responsibility:

• Agent transparency - the end customer should know when they are interacting with an AI system.
• Boundaries of action - agents operate within clearly defined limits and escalate to a human beyond them.
• Auditability - agents' decisions and actions are logged and can be traced.
• Reversibility - critical actions can be undone or require confirmation.

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Advisory independence and conflict of interest

Persooa is an independent implementation partner in the Synerise ecosystem - we recommend what serves the customer's goals. We base our independence on our binding Policy for Preventing and Managing Conflicts of Interest:

• Reporting by anyone - a conflict, or a suspicion of one, can be reported by any person or entity, including the customer.
• Assessment by an independent person - a report is verified by someone other than the person it concerns, not subordinate to the management of those being assessed, acting after signing an NDA; they prepare a written report with justification.
• Exclusion from decisions - a confirmed conflict results in the person being excluded from activities related to the other party to the conflict.
• Register - we maintain a register of reported conflicts of interest.

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Sustainable Digital Operations

Persooa operates in a remote-first model, without dedicated office space for project teams. We communicate only what we genuinely control - no greenwashing and no comparative claims that we are unable to measure and sustain reliably.

• Remote-first - we do not maintain dedicated office space for project teams.
• Cloud-first delivery - we use the cloud infrastructure of large-scale providers.
• Paperless operations - fully digital collaboration.
• Responsible use of resources - right-sizing of processing and an extended hardware lifecycle.

We deliberately do NOT make Net Zero, SBTi or carbon-neutrality commitments, and we do not publish emissions data or comparative claims. Full breakdown of practices: Supplier Sustainability Statement.

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Have questions about how we work?

If you want to understand in more detail how we approach data, AI, privacy and security, we have gathered the most frequent questions - from retail, e-commerce, banking, insurance and telecommunications - in a separate document.

→ Frequently asked questions (FAQ)

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Let's talk

Want to talk about how we combine growth with responsibility?

Book a call with the Persooa team → write to kontakt@persooa.com

This document is informational and describes Persooa's operational practices and intentions. It does not constitute an offer, a guarantee or a binding contractual commitment; specific commitments are governed by the agreements concluded with customers.