SaleCycle

Key Changes and Risks

1. Broader description of data collection

The notice changes the wording from collecting data in connection with “data centres” and suppliers to collecting information when individuals:

• Visit clients’ websites; or
• Interact with the company’s services.

The revised list expressly includes:

• Salutation, name, email address and telephone number;
• IP address and device information;
• Products and services of interest; and
• E-commerce and order information, including order ID, subtotal, title, currency, discounts, shipping, items, product IDs, URLs, prices, categories and tax details.

Risk: This is a material expansion and clarification of the categories of personal data covered. The notice should accurately identify all data collected and explain the purposes, lawful bases, retention periods and recipients for each category.

2. Client-specific data collection

The revised wording states that the information collected varies depending on the client’s service configuration and directs individuals to contact the relevant Data Controller for further details.

Risk: Responsibility for transparency is less clear. Referring individuals to the client may be insufficient if the company itself determines purposes or means of processing, or acts as a processor with independent transparency obligations. Client-specific collection should be supported by clear contractual allocation of controller/processor responsibilities.

3. Special category data

The previous wording stated that the company “may capture additional personal data, including special category data,” but described this as rare and said safeguards could be implemented. The revised text uses “additional information” in places, but ultimately retains wording that special category data may be captured in rare cases and that additional safeguards will be determined or implemented.

Risk: The revised language remains potentially ambiguous and may still permit processing of special category data without identifying the conditions under UK GDPR Article 9, the specific safeguards, or whether such processing is actually intended. “Rare” is not a legal basis or sufficient explanation.

4. Security and hosting statements

The notice continues to state that data centres and cloud storage are located in the EU and UK, with contractual controls for suppliers. However, wording about conducting supplier due diligence and maintaining security controls is reorganised and now emphasises the company’s own ISO/IEC 27001:2013-aligned controls.

Risk: The notice should not imply certification or controls that are not current, independently verified or applicable to all services. International transfer arrangements and supplier locations should also be accurately described.

5. AI model training

No express change relating to AI, machine learning or training models appears in this diff. The revised wording does not expressly:

• Authorise use of customer data to train, fine-tune or evaluate AI models;
• Prohibit such use;
• Explain whether data is anonymised before AI use;
• Identify AI providers or subprocessors; or
• Provide an opt-out or deletion mechanism for training data.

Accordingly, this diff does not create a clear contractual permission to use customer data for AI training, but it also does not address or rule out that possibility. A separate, explicit AI-data-use provision should be reviewed.

Summary

The provided diff does not include the actual contractual language that was added, deleted, or replaced. It only states:

> “Added approximately 79 words to the document”

Accordingly, there is not enough information to assess the legal or commercial impact of the changes.

AI Training and Customer Data

No provisions addressing any of the following are included in the diff:

• Whether customer data may be used to train, fine-tune, or improve AI models
• Whether customer data is used for product development or analytics
• Whether inputs, outputs, prompts, or metadata are retained
• Whether data is shared with affiliates, contractors, or AI service providers
• Whether the customer can opt out of AI training or secondary use
• Ownership or licensing rights in customer data, outputs, or derived data
• Confidentiality, anonymization, deletion, or data-security safeguards relating to AI use

Therefore, no conclusion can be drawn about whether the contract now permits or restricts AI training using customer data.

Risk Assessment

The diff is insufficient to identify:

• New customer obligations
• Expanded provider rights
• Changes to liability, indemnity, confidentiality, or compliance duties
• Changes to data retention, security, or deletion requirements
• Any new risk allocation concerning AI-generated content or model performance

Please provide the actual 79 words added, together with any surrounding text and any deleted or replaced language, for a meaningful legal analysis.

Summary

Document Provided

The diff states only:

> “Added approximately 79 words to the document”

No actual added, deleted, or replaced contract language was included.

Analysis of Changes

Because the underlying text is missing, it is not possible to determine:

• What contractual provisions changed;
• Whether any obligations, rights, liabilities, or remedies were added or removed;
• Whether customer data may be collected, accessed, disclosed, retained, or transferred differently;
• Whether the customer’s data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether the customer can opt out of AI training or object to such use;
• Whether data is anonymized, de-identified, aggregated, or otherwise protected before AI use;
• Whether the provider may use customer content for human review, service improvement, or third-party model training; or
• Whether the changes affect confidentiality, security, intellectual property, privacy, or regulatory compliance.

AI Training Risk Assessment

No conclusion can be reached regarding AI-model training. The added language should be reviewed for terms such as:

• “train,” “fine-tune,” “improve,” or “develop” models;
• “customer data,” “customer content,” “inputs,” or “outputs”;
• “service improvement” or “product development”;
• “aggregated,” “de-identified,” or “anonymized” data;
• “affiliates,” “service providers,” or “third-party AI providers”; and
• opt-out, deletion, retention, or confidentiality provisions.

Required Information

Please provide the actual diff, including the 79 added words and any deleted or replacement language. Without that text, a substantive legal-risk analysis would be speculative.

Summary of Important Changes

1. Expanded description of data collected

The notice changes from a general statement that data may be collected through clients’ websites to a more detailed list of information collected when individuals visit client websites or interact with the services. Examples now include:

• Salutation, name, email address and telephone number
• IP address and device information
• Information about products and services of interest
• Order and transaction information, including:
• Order ID and subtotal
• Title, currency and discounts
• Shipping and items
• Product ID and client product ID
• Product URL, single-item price, category and tax information

Risk: This is a material expansion and clarification of the categories of personal data covered. The notice should accurately reflect all data actually processed and explain the purposes, lawful bases, retention periods and relevant recipients for each category.

2. Broader wording regarding client-specific data

The revised wording says that the information collected “varies from client to client depending on the setup of our services.” It also states that additional information may be captured at the request of clients.

Risk: This gives the service provider broad flexibility to process different types of data without identifying clear limits. The notice should explain how individuals can obtain client-specific details and should ensure that the relevant Data Controller provides the required privacy information.

3. Special-category data wording changed

The previous wording expressly stated that the provider might determine or capture “personal data, including special category data,” but described this as rare. The revised text states that additional information may be captured and later says that special-category data may be involved, while retaining the qualification that this is rare and that additional safeguards will be implemented where identified.

Risk: The revised structure is less clear about whether special-category data is actually expected to be processed and under what circumstances. Processing such data requires an Article 9 UK GDPR condition, appropriate safeguards and clear transparency. The notice should specify the types of special-category data, purposes, legal conditions and safeguards, rather than relying only on the statement that it is rare.

4. Security and hosting language

The notice now expressly refers to:

• EU and UK data centres and cloud-based storage
• Contractual controls with suppliers
• Supplier security due diligence
• The provider’s own ISO/IEC 27001:2013-aligned security controls

Risk: These statements may create contractual or regulatory expectations. ISO certification should not be implied unless current and applicable. The notice should also address international transfers if any supplier or support access occurs outside the UK/EEA.

5. AI-model training

No express change concerning AI or the use of customer data to train AI models was identified. The diff contains no wording authorising, restricting or describing the use of personal data, customer content or transaction data for AI training, model development, testing or improvement.

If AI training is intended, this should be addressed expressly, including purposes, legal basis, data categories, opt-out or objection rights, anonymisation/pseudonymisation, retention and sharing arrangements.

6. Drafting and publication issues

The diff contains serious formatting and apparent corruption issues, including repeated text, missing spaces, and substitutions such as “Basket ID,” “Order ID,” “Subtotal” and “Title.” The ending now adds a privacy contact email and a last-updated date.

Risk: The published notice may be unclear or misleading unless fully redrafted and checked against the actual processing activities.

Summary of Important Changes

1. Expanded description of data collected

The notice changes from a general statement about using data centres and cloud storage to a detailed list of information collected when individuals visit clients’ websites or interact with the services. Listed data now includes:

• Salutation, name, email address and phone number
• IP address and device information
• Products and services of interest
• E-commerce/order information, including:
• Order ID and subtotal
• Title, currency and discounts
• Shipping and items
• Product ID, client product ID and URL
• Single-item price, category and tax

Risk: This is a substantial expansion and clarification of the stated data scope. The notice should accurately reflect all data actually collected and explain the purposes and lawful bases for each category. The inclusion of URLs, device data and purchasing information may involve profiling or tracking obligations.

2. More prominent role for clients as Data Controllers

The wording now repeatedly states that collection varies according to the “setup of our services” and directs individuals to contact the relevant Data Controller for further information.

Risk: The notice should clearly distinguish the company’s role as processor, controller or joint controller for each activity. Simply referring individuals to clients may be insufficient where the company independently determines purposes or means of processing, or must directly handle data-subject rights.

3. Special-category and additional personal data

The wording changes from saying the company “may be able to determine” additional personal data, including special-category data, to saying it may “capture” additional information and may determine personal data, including special-category data. The text now says this is rare and that additional safeguards will be implemented with clients where identified.

Risk: “Rare” does not remove GDPR obligations. Processing special-category data requires a specific Article 9 condition, appropriate transparency, minimisation and documented safeguards. The notice does not identify the relevant legal condition, categories of special-category data, retention periods or safeguards. “May capture” could also imply a broader collection capability than the previous wording.

4. Security and hosting language

The revised text retains statements that data centres and cloud storage are located in the EU and UK, suppliers are subject to contractual controls and due diligence, and internal controls follow ISO/IEC 27001:2013 standards.

Risk: These statements may create enforceable expectations. They should be accurate, current and qualified where services, suppliers or transfers fall outside the EU/UK. The ISO reference should be checked for currency and whether certification or merely alignment is being claimed.

5. AI-model training

No express change or new provision concerning the use of customer or personal data to train, fine-tune, evaluate or improve AI models is shown in this diff. The revised data categories could nevertheless include information that might later be used for AI purposes. If AI training is intended, the notice should expressly state:

• Whether customer data is used for training or model improvement
• Which data is excluded, anonymised or de-identified
• The legal basis and opt-out/objection mechanism
• Retention, sharing and international-transfer arrangements

6. Administrative updates

A privacy contact email is added, and the notice is stated to have been last updated on 30 November 2023.

Summary

The provided diff does not include the actual amended legal language. It only states:

> “Added approximately 79 words to the document”

Because the new wording is not shown, it is not possible to determine:

• What contractual provisions changed;
• Whether any new obligations, rights, liabilities, or restrictions were added;
• Whether the changes affect confidentiality, intellectual property, data protection, security, or termination;
• Whether the customer’s data may be used to train, fine-tune, evaluate, or otherwise improve AI models;
• Whether customer data may be retained, anonymized, aggregated, shared with affiliates or vendors, or used for product development; or
• Whether the customer has any opt-out, deletion, or objection rights.

AI-Training/Data-Use Assessment

No conclusion can be reached regarding AI-model training because the relevant added text is missing. The phrase “Added approximately 79 words” does not itself create or modify any contractual right to use customer data.

Required Information

Please provide the actual 79-word addition, together with any surrounding text and the deletion/replacement markup. The analysis should specifically check for language concerning:

• “Train,” “fine-tune,” “improve,” or “develop” AI or machine-learning models;
• Use of customer content, inputs, outputs, prompts, or usage data;
• Aggregated, de-identified, or anonymized data;
• Service providers, affiliates, or third-party model providers;
• Data retention and deletion;
• Customer consent or opt-out rights; and
• Ownership or licensing of customer data and model outputs.

Summary

The supplied material only states: “Added approximately 79 words to the document.” It does not include the actual added, deleted, or replaced language.

Analysis

• Important legal changes: Cannot be determined without the text of the amendment.
• Customer data use: No conclusions can be drawn about whether customer data may be:
• Used to train, fine-tune, or improve AI models;
• Used for product development, analytics, or service improvement;
• Shared with affiliates, vendors, or AI providers;
• De-identified, aggregated, or retained for model-training purposes;
• Excluded from training by default or only excluded upon customer request.
• New risks: Cannot be assessed because the substantive wording is missing.

Information Needed

Please provide the actual redline text, including:

• Additions shown in {braces};
• Deletions shown in [square brackets];
• Replacements shown as [old text]{new text}.

Without that language, it is not possible to identify changes to data rights, confidentiality, privacy, intellectual property, retention, security, or AI-model training.

Summary

The provided diff does not include the actual amended legal language. It only states:

> “Added approximately 79 words to the document”

Accordingly, it is not possible to determine:

• What contractual provisions changed;
• Whether the additions create new obligations, rights, fees, warranties, or liability;
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether customer data may be shared with affiliates, vendors, or third parties;
• Whether the customer can opt out of AI training or data use;
• Whether confidentiality, security, deletion, or intellectual-property protections were modified.

AI Training and Data-Use Risk

No conclusion can be reached about AI-model training from the information provided. The 79 added words could potentially introduce language allowing the provider to:

• Use customer content or usage data to train or improve artificial-intelligence models;
• Create derivative data, aggregated data, or de-identified data;
• Retain data after termination for model-training or product-improvement purposes;
• Share data with subprocessors or model providers; or
• Use customer data without a separate opt-in or compensation.

These risks cannot be confirmed without the text of the additions.

Required Information

Please provide the full diff, including:

• Added text in {curly braces};
• Deleted text in [square brackets];
• Replacement text in []{curly braces}; and
• The surrounding original contract language where necessary for context.

Once provided, the changes can be analyzed for legal effect, with particular attention to AI training, data ownership, confidentiality, retention, sharing, security, and termination rights.

Summary of Important Changes

1. Scope and presentation of the privacy notice

• The opening wording is corrected from “Privacy Notice. This” to “Privacy Notice. This” without a substantive change.
• The notice now describes information collected when individuals visit clients’ websites or interact with the provider’s services, rather than focusing on the provider’s use of data centres and supplier due diligence.
• The revised text is substantially reorganised and includes additional headings and explanatory material, although the diff contains apparent formatting and editing errors that should be corrected before publication.

2. Expanded categories of customer data

The revised notice gives a more detailed list of information that may be collected, including:

• Salutation, name, email address and phone number;
• IP address and device information;
• Information about products and services of interest;
• Order and transaction information, including order ID, subtotal, title, currency, discounts, shipping, items, product ID, client product ID, URL, single-item price, category and tax information.

Risk: This is a materially broader and more specific description of personal data processing. The organisation should verify that every listed data category is actually collected, necessary for the stated purposes, and covered by an appropriate lawful basis and retention period.

3. Special category and additional personal data

• The previous wording said the provider “may be able to determine” additional personal data, including special category data, but described this as rare.
• The revised wording says the provider may “capture” additional information and that special category data may be captured through the services. It still states that this is rare and that additional safeguards will be implemented where identified.

Risk: “Capture” is stronger and potentially broader than “determine,” suggesting actual collection or receipt rather than merely inference. Special category data requires additional legal conditions and stronger controls under data protection law. The notice should explain the circumstances, legal basis, safeguards and roles of the provider and client clearly.

4. Security and hosting statements

• References to EU/UK data centres, contractual controls with suppliers, supplier due diligence and ISO/IEC 27001:2013 security standards are retained but moved and reframed.
• The revised wording states that the provider maintains its own security controls in accordance with ISO/IEC 27001:2013.

Risk: These statements may create expectations or representations about certifications, geographic hosting and supplier controls. They should be factually accurate and aligned with actual processing locations, certifications and international-transfer arrangements.

5. Source of information and client responsibility

• The revised notice states that information is obtained directly from clients’ websites.
• It continues to direct individuals to the relevant Data Controller for complete information and says collection varies depending on the client’s setup.

6. AI model training

• The diff contains no express provision authorising, describing or restricting the use of customer data to train, fine-tune, evaluate or improve AI models.
• It also does not state that customer data will not be used for AI training.

Risk: If AI training or model improvement is intended, the notice is incomplete and should expressly address the purpose, data categories, legal basis, retention, safeguards, opt-out rights (if applicable), and whether data is shared with AI providers.

Summary

The provided diff does not include the actual amended contractual language. It only states:

> “Added approximately 79 words to the document”

Because no text is shown, it is not possible to determine:

• What provisions were added, deleted, or replaced;
• Whether customer data may be used to train, fine-tune, test, or improve AI models;
• Whether data may be shared with affiliates, vendors, or third parties;
• Whether customer data is anonymized, aggregated, or de-identified before use;
• Whether the customer can opt out of AI training or withdraw consent;
• Whether new data-retention, confidentiality, security, or deletion obligations apply;
• Whether liability, indemnity, intellectual-property ownership, or regulatory risks have changed.

AI-Training Assessment

No AI-related contractual change can be identified from the supplied diff. The actual 79 added words are required to assess whether the provider receives any new rights to use customer data for model training or related purposes.

Information Needed

Please provide the underlying redline or the 79-word addition, including any deleted or replacement language. Once supplied, the changes can be analyzed for:

1. Scope of permitted data use

2. AI training and model-improvement rights

3. Customer consent or opt-out rights

4. Data ownership and intellectual-property effects

5. Confidentiality, security, and retention

6. Third-party disclosures and subprocessors

7. Compliance, indemnity, and liability exposure

Summary of Important Changes

1. Expanded description of data collected

The notice now states that information may be collected when individuals:

• Visit clients’ websites; or
• Interact with the company’s services.

The listed information has been expanded or clarified to include:

• Salutation, name, email address and phone number;
• IP address and device information;
• Information about products and services of interest;
• Client and transaction-related data, including:
• Order ID;
• Subtotal, title, currency and discounts;
• Shipping and items;
• Product ID and client product ID;
• Product URL, single-item price, category and tax information.

Risk: This is a material expansion in the apparent scope and granularity of personal and transactional data collected. The notice should clearly explain the purposes, lawful bases, retention periods and categories of recipients for each type of data.

2. Special category and additional personal data

The previous wording said the company *may be able to determine* additional personal data, including special category data, but that this was rare. The revised wording says the company may *capture additional information* and that it is “also possible” that services may capture additional personal data, including special category data.

The revised text retains that this is rare and says the company will work with clients to implement additional safeguards.

Risk: “Capture” is broader and more direct than “determine,” potentially implying actual collection rather than incidental inference. Special category data carries heightened obligations under data protection law, including an additional legal condition, enhanced transparency and appropriate safeguards. The notice does not specify what categories may be captured, why, on what legal basis, or what safeguards apply.

3. Greater reliance on clients and client websites

The revised notice places more emphasis on data being collected from clients’ websites and directs individuals to contact the relevant Data Controller for further details. It also says the information collected varies depending on the client’s service configuration.

Risk: Users may be unclear whether the company or the client is responsible for particular processing activities. The controller/processor allocation, responsibilities for responding to data-subject requests, and relevant client privacy notices should be clearly explained.

4. Security and hosting language

The revised wording states that:

• Data centres and cloud storage are based in the EU and UK;
• Appropriate contractual controls are maintained with suppliers;
• Supplier security controls are subject to due diligence; and
• The company maintains its own controls in accordance with ISO/IEC 27001:2013 security standards.

This replaces more general wording about security controls.

Risk: These statements may create contractual or regulatory expectations regarding hosting location, supplier oversight and ISO compliance. They should be accurate, current and qualified where exceptions or international transfers exist.

5. AI-model training

No express change concerning the use of customer data to train, fine-tune, evaluate or improve AI models is visible in the supplied diff. The revised categories of website, device, product and transactional information could nevertheless be relevant to AI processing if such use occurs elsewhere.

The notice should expressly state whether customer data is used for AI-model training, whether it is shared with AI providers, whether prompts or outputs are retained, and whether customers can opt out or impose contractual restrictions.

Summary of Important Changes

1. Expanded description of data collected

The notice changes from a general statement about using data centres and collecting data to a more detailed list of information collected when individuals visit clients’ websites or interact with the services. The listed information may include:

• Salutation, name, email address and phone number
• IP address and device information
• Products and services of interest
• Order and transaction information, including:
• Order ID and subtotal
• Title, currency and discounts
• Shipping and items
• Product ID, client product ID and URL
• Single-item price, category and tax

Risk: The notice now describes a substantially broader and more specific range of personal and transactional data. The organisation should ensure that all listed data is actually collected, necessary for the stated purposes, supported by an appropriate lawful basis, and covered by retention and security controls.

2. Possible collection of additional and sensitive data

The revised wording states that the organisation may capture additional information depending on how the services are configured by each client. It now expressly acknowledges that this may include:

• Additional personal information
• Special category data

The wording says this is “rare and where identified” and that additional safeguards will be implemented in cooperation with clients.

Risk: Mentioning special category data creates significant compliance implications under data protection law. The notice does not identify what types of special category data may be processed, the applicable Article 9 condition, or the specific safeguards used. Those matters should be documented and agreed with the relevant client/data controller.

3. Clarification of roles and responsibility

The revised text repeatedly directs individuals to the relevant Data Controller for further information and explains that the information collected varies according to the client’s service configuration.

Risk: This may make the organisation’s role clearer, but it also increases the importance of consistent controller/processor allocation, client instructions, privacy notices, and responsibility for handling data-subject requests.

4. Security and hosting statements

The revised notice states that:

• Data centres and cloud-based storage are located within the EU and UK
• Appropriate contractual controls are maintained with suppliers
• Supplier security due diligence is conducted
• The organisation maintains its own controls in accordance with ISO/IEC 27001:2013

Risk: These are potentially binding or reliance-inducing representations. They should remain accurate, particularly where suppliers, backups, support access, or data transfers involve locations outside the EU or UK. The reference to ISO/IEC 27001:2013 should also be checked against the organisation’s current certification or security framework.

5. AI model training

No express change concerning the use of customer data to train AI models is visible in this diff. The revised wording does not state whether personal data, transaction data, or special category data may be used to train, fine-tune, evaluate, or improve AI models.

Risk: If AI training or model improvement is intended, this notice does not clearly disclose it. A separate, explicit provision should address purposes, data categories, legal basis, safeguards, opt-out or objection rights where applicable, retention, supplier use, and whether data is de-identified or shared with AI providers.

6. Administrative updates

The notice adds contact details—privacy@salecycle.com—and states that it was last updated on 30 November 2023. The address formatting appears corrupted around “NE8 3DFFor,” and should be corrected before publication.

Summary

The diff only states that approximately 79 words were added; it does not include the actual added language or identify where it appears in the agreement.

AI Training and Customer Data

• It is not possible to determine whether the changes permit, restrict, or otherwise affect the use of customer data to train AI models.
• The available diff does not reveal whether customer data may be:
• Used to train, fine-tune, or improve artificial-intelligence or machine-learning models;
• Combined with other customers’ data;
• De-identified, anonymized, or pseudonymized before use;
• Retained after the customer relationship ends; or
• Shared with affiliates, vendors, or model providers.

Other Legal Risks

Because the added 79 words are not provided, it is also impossible to assess changes involving:

• Ownership or licensing of customer data;
• Confidentiality and permitted-use restrictions;
• Data retention and deletion;
• Security obligations;
• Subprocessors or third-party service providers;
• Warranties, indemnities, or liability limits; or
• Customer consent and opt-out rights.

Conclusion

No substantive legal comparison can be performed from the information supplied. The exact 79 added words—and, ideally, their location in the agreement—are needed to identify new obligations, permissions, or risks, particularly regarding the use of customer data for AI model training.

Summary of Important Changes

1. Broader and more detailed data collection

The revised notice replaces general references to collecting “data” with more specific categories of “information.” It now expressly lists:

• Salutation, name, email address and phone number
• IP address and device information
• Products and services of interest
• E-commerce and transaction-related information, including:
• Order ID and subtotal
• Title, currency and discounts
• Shipping and items
• Product ID, client product ID, URL, single-item price, category and tax

Risk: This is a significant expansion in the transparency and apparent scope of collection. Customers may now understand that the service processes detailed purchase, browsing and device data. The notice should clearly identify the legal basis, retention periods, purposes and categories of recipients for each type of data.

2. Possible collection of additional and sensitive data

The wording changes from the provider potentially being able to “determine” additional personal data, including special-category data, to stating that it may “capture” additional information through its services. The revised language says this is possible, that special-category data is rare, and that additional safeguards will be implemented where identified.

Risk: “Capture” may imply more direct and routine collection than “determine.” The revised wording remains broad and does not explain:

• What special-category data may be collected
• The applicable legal condition for processing it
• Whether the provider or the client is responsible for compliance
• What the promised safeguards actually are

The notice continues to direct individuals to the relevant client/Data Controller, which may leave responsibility unclear.

3. Data storage and security wording retained or clarified

The revised text continues to state that data centres and cloud storage are located in the EU and UK, with contractual controls for suppliers and due diligence over supplier security. It also retains reference to ISO/IEC 27001:2013 security standards and the provider’s own security controls.

Risk: These statements may create commitments regarding geographic location, supplier oversight and security standards. They should be accurate and consistent with actual infrastructure, subcontracting and international-transfer arrangements.

4. AI model training

No express change concerning AI, machine learning or use of customer data to train AI models appears in the supplied diff.

The revised collection language is broad enough to cover substantial customer, transaction and device information, but it does not state whether that information may be:

• Used to train, fine-tune or evaluate AI models
• Shared with AI providers
• Used in aggregated, anonymised or identifiable form
• Excluded from model training by default or by customer choice

Risk: If AI training or model improvement is intended, the notice should address it expressly, including purpose, data categories, legal basis, opt-out rights, retention and third-party AI providers.

5. Drafting and publication issues

The diff contains apparent formatting and wording defects, including “Notice.This,” “phone numberYour,” and a malformed closing address. These errors could reduce clarity and undermine the notice’s credibility or transparency.

Summary

The provided diff does not include the actual amended contract language. It only states:

> “Added approximately 79 words to the document”

Because the additions, deletions, and replacements are not shown, it is not possible to determine:

• What contractual rights or obligations changed;
• Whether liability, indemnity, confidentiality, termination, or data-security provisions were modified;
• Whether the customer’s data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether such use requires customer consent or is subject to an opt-out;
• Whether data may be shared with affiliates, vendors, or model providers;
• Whether customer data is anonymized, aggregated, retained, or deleted;
• Whether the provider obtains ownership or broad license rights in customer content; or
• Whether the changes create new compliance, confidentiality, or intellectual-property risks.

AI Training Risk Assessment

No conclusion can be reached regarding AI-model training because the relevant 79 words were not provided. The amended language should be reviewed specifically for terms such as:

• “train,” “fine-tune,” “improve,” “develop,” or “evaluate” models;
• “customer data,” “content,” “inputs,” “outputs,” or “usage data”;
• “de-identified,” “aggregated,” or “anonymized” information;
• “perpetual,” “irrevocable,” “worldwide,” or “royalty-free” licenses;
• opt-in, opt-out, or consent requirements; and
• data retention, deletion, or third-party disclosure rights.

Information Needed

Please provide the full redline showing the added text in {}, deleted text in [], and replacement text in []{}. Without the actual language, no reliable legal-risk analysis can be performed.

Summary

The supplied diff does not include the actual amended language. It only states that approximately 79 words were added. As a result, it is not possible to identify:

• The legal or commercial changes;
• New obligations, rights, or liabilities;
• Changes to confidentiality, security, ownership, or permitted uses;
• Any changes concerning the customer’s data; or
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models.

AI Training and Data-Use Analysis

No conclusions can be drawn from the information provided about whether:

• Customer data may be used to train or improve artificial-intelligence models;
• Customer prompts, inputs, outputs, or usage data may be retained;
• Data may be anonymized, aggregated, or shared with affiliates or third parties;
• The provider may use customer data for product development or model evaluation; or
• The customer has any opt-out, deletion, or consent rights.

Information Needed

Please provide the actual redlined text, including the 79 added words and any surrounding provisions. The analysis should focus particularly on terms such as:

• “train,” “fine-tune,” “improve,” “develop,” or “evaluate” models;
• “customer data,” “content,” “inputs,” “outputs,” or “usage data”;
• “anonymized,” “aggregated,” or “de-identified” information;
• Data-retention and deletion rights;
• Consent or opt-out mechanisms; and
• Rights granted to affiliates, vendors, or other third parties.

Summary of Important Changes

1. Major expansion and clarification of data collected

The notice changes from a general statement that data may be collected to a detailed list of information collected when individuals visit clients’ websites or interact with the services. This may include:

• Salutation, name, email address and telephone number
• IP address and device information
• Information about products and services of interest
• Order and transaction information, including:
• Order ID
• Subtotal, title, currency and discounts
• Shipping and item information
• Product ID, client product ID and URL
• Single-item price, category and tax information

Risk: The revised wording is substantially broader and more specific. It may permit collection of detailed browsing, purchasing and behavioural data. The privacy notice should clearly explain the purposes, lawful bases, retention periods and sharing arrangements for each category.

2. Potential collection of sensitive personal data

The wording changes from saying the business “may be able to determine” additional personal data, including special-category data, to saying it may “capture” additional information. It now states that special-category data may be captured, although this is described as rare and subject to additional safeguards implemented with clients.

Risk: “Capture” suggests direct collection rather than merely inference or determination. Special-category data requires a separate legal condition under data-protection law, as well as appropriate safeguards. The notice does not identify the specific types of sensitive data, legal condition, retention period or safeguards.

3. Client-specific variation and controller responsibility

The notice now states that the information collected varies depending on the client’s service configuration and directs individuals to contact the relevant Data Controller for further details.

Risk: This may make transparency less clear for individuals. The relevant client should be identified where possible, and the notice should explain the respective responsibilities of the service provider and each client, particularly for data-subject rights and complaints.

4. Security and hosting wording

The revised text states that data centres and cloud storage are located in the EU and UK, with contractual controls for suppliers and due diligence on supplier security. It also refers to the company’s own ISO/IEC 27001:2013-aligned security controls.

Risk: This is a security and hosting representation, but it does not explain whether transfers outside the UK/EEA can occur, what contractual controls are used, or whether ISO certification (rather than alignment with standards) exists. The reference to ISO/IEC 27001:2013 may also be outdated.

5. AI model training

No express change concerning the use of customer data to train, fine-tune, evaluate or improve AI models is visible in the supplied diff. The revised wording does not grant an explicit AI-training right, but it also does not expressly prohibit such use.

Recommended action: Confirm separately whether customer data, prompts, outputs, behavioural data or special-category data may be used for AI development or training. If so, this should be disclosed expressly, with purpose limitations, opt-out rights where applicable, retention rules and safeguards.

6. Administrative changes

The notice adds a privacy contact email address and states that it was last updated on 30 November 2023. The formatting appears corrupted in places and should be legally and editorially reviewed before publication.

Summary of Important Changes

1. Expanded description of data collected

The notice now states that information may be collected when individuals:

• Visit clients’ websites; or
• Interact with the company’s services.

The listed data has been expanded substantially to include:

• Salutation, name, email address and phone number;
• IP address and device information;
• Products and services of interest; and
• Detailed transaction or order information, including order ID, subtotal, title, currency, discounts, shipping, items, product ID, client product ID, URL, single-item price, category and tax.

Risk: The broader list may increase transparency, but it also confirms collection of commercially sensitive and potentially personal purchasing information. The notice should clearly explain the purposes, lawful bases, retention periods and sharing arrangements for these data categories.

2. Broader and less specific wording about additional information

The previous wording said the company might be able to determine or capture “additional personal data, including special category data,” although this was rare and additional safeguards could be implemented.

The revised wording says the company may capture “additional information” and refers users to the Data Controller for further details. It now says it is also possible that services may involve such information and that the company works with clients to implement additional safeguards.

Risks:

• Removing the express reference to “personal data” and “special category data” may reduce clarity about the possibility of processing sensitive data.
• The revised wording appears broader while providing less detail about what sensitive data may be involved, the applicable legal basis, safeguards, access controls and retention.
• Referring individuals primarily to the client/Data Controller may be insufficient if the company itself acts as a processor, controller or joint controller for any processing.

3. Storage, supplier and security language reorganised

The notice now states that the company:

• Uses data centres and cloud-based storage located in the EU and UK;
• Maintains contractual controls with suppliers;
• Conducts due diligence on supplier security controls; and
• Maintains its own security controls in accordance with ISO/IEC 27001:2013 standards.

This is generally more structured and clearer, although it should not imply that EU/UK hosting eliminates all international-transfer risks, particularly where suppliers or support personnel are located elsewhere.

4. Sources of information

The revised text expressly states that information is obtained directly from clients’ websites. This clarifies the collection method but should be reconciled with the roles of the website operator, the company and any other service providers.

5. AI-model training

No express change relating to AI, machine learning or training models appears in the supplied diff. The revised wording does not grant or remove an explicit right to use customer or website-visitor data to train AI models.

However, the broader “additional information” wording could potentially be interpreted as covering new uses unless purposes are tightly defined elsewhere. The notice should expressly state whether customer data, transaction data, prompts, outputs or telemetry may be used for AI training, and whether such use is prohibited, opt-in, anonymised or subject to contractual restrictions.

6. Administrative changes

The notice adds a privacy contact email and states that it was last updated on 30 November 2023. The address formatting and punctuation should be checked before publication.

Key Changes

1. Notice introduction and formatting

• The opening reference changes from “Website Privacy Notice” to “Website Privacy Notice. This,” with additional wording explaining that the notice covers:
• Information collected
• How information is used
• Privacy settings and controls
• The revised text appears to contain formatting and spacing problems, including missing spaces and merged headings. This could make the notice difficult to read and may weaken transparency under data-protection laws.

2. Broader and more specific description of data collected

The revised wording replaces a general statement about using data centres and security controls with a much more detailed list of information that may be collected, including:

• Salutation and name
• Email address
• Phone number
• IP address and device information
• Information about products and services of interest
• Order and transaction information, including:
• Order ID
• Subtotal
• Title
• Currency
• Discounts
• Shipping information
• Items and product IDs
• Client product ID and URL
• Single-item price
• Category
• Tax and similar information

This is a significant expansion in the apparent scope and specificity of the personal data described. Customers may therefore have a stronger basis to expect the notice to explain the purposes, legal bases, retention periods, recipients and data-subject rights relating to each category.

3. Greater emphasis on client-specific collection

• The revised wording states that the information collected varies depending on the client and the setup of the services.
• It directs individuals to contact the relevant Data Controller for full details.
• This makes the company’s role appear more closely connected to processing data on behalf of clients, but the notice should clearly distinguish the company’s own processing from processing carried out as a processor or service provider.

4. Special-category and sensitive data

• The earlier wording said the company “may be able to determine” additional personal data, including special-category data.
• The revised wording says it may “capture” additional information and that it is “also possible” that services may capture personal data, including special-category data.
• Although the revised text still describes this as rare and refers to additional safeguards, “capture” is more direct and may imply actual collection rather than merely inference or determination.
• The revised notice should identify the circumstances, purposes, lawful conditions and safeguards applicable to special-category data.

5. Security and hosting language

• The revised text retains references to EU and UK data centres, contractual controls with suppliers, due diligence and ISO/IEC 27001:2013 security standards.
• However, the wording changes from describing controls maintained in connection with suppliers to stating that the company maintains its own security controls. The allocation of responsibility should be verified and accurately stated.

6. AI model training

• No express provision concerning artificial intelligence, machine learning, generative AI, model training, model improvement, or use of customer data for training appears in the supplied diff.
• The revised data categories could potentially include information that might be used for analytics or model development, but the diff does not authorise or describe such use.
• If customer data is intended to be used to train or improve AI models, a clear, specific disclosure and appropriate contractual permission should be added.

Summary

Key Change

• The diff indicates that approximately 79 words were added to the document.
• However, the actual text of those additions is not provided. The notation {Added approximately 79 words to the document} is only a description of the change, not the legal language itself.

Customer Data and AI Training

• It is not possible to determine whether the added language:
• Permits the customer’s data to be used to train, fine-tune, or improve AI models;
• Allows use of customer prompts, inputs, outputs, content, or personal information for model development;
• Applies data usage rights to human review, analytics, product improvement, or service monitoring;
• Includes opt-out, consent, confidentiality, deletion, or anonymization protections; or
• Grants the provider ownership or a broad license over customer data.

Risk Assessment

• No substantive legal risks can be reliably identified without the actual 79 added words.
• If the addition concerns AI training or product improvement, important issues to check include:
• Whether data use is mandatory or optional;
• Whether the provider may use data across customers or for commercial model development;
• Whether de-identified or aggregated data may still be used indefinitely;
• Whether sensitive or personal data is covered;
• Whether the customer can opt out or withdraw consent;
• Whether the provider may share data with affiliates, vendors, or model partners; and
• Whether deletion obligations apply to training data, backups, and derived models.

Conclusion

The supplied diff is insufficient for a meaningful contract analysis. The exact added language is needed to identify changes to data rights, AI training permissions, confidentiality obligations, and customer risk.

Summary of Important Changes

1. Major expansion and clarification of data collected

The notice changes from a general statement about using “data” to a detailed list of information collected when individuals visit clients’ websites or interact with the services, including:

• Salutation, name, email address and phone number;
• IP address and device information;
• Information about products and services of interest; and
• Transaction or order information, including order ID, subtotal, title, currency, discounts, shipping, items, product ID, client product ID, URL, single-item price, category and tax.

Risk: This materially expands the apparent scope of personal data processing and may require corresponding updates to privacy notices, records of processing, lawful bases, retention policies and data-processing agreements. The phrase that collection varies depending on the client’s setup leaves the scope potentially open-ended.

2. Broader statement regarding additional information

The revised text states that the service may “capture additional information” and directs individuals to contact the relevant Data Controller for further details. It also says that additional personal data, including special-category data, may be captured.

The previous wording suggested that special-category data was rare and that safeguards could be implemented where identified. The new wording still describes it as rare, but more clearly acknowledges that the service may capture it.

Risk: Processing special-category data requires an Article 9 UK GDPR condition and heightened safeguards. The notice does not identify the conditions, purposes, safeguards or allocation of responsibility between the parties. Referring individuals to the Data Controller may not sufficiently explain the service provider’s own role.

3. Changes to data sources and purposes

The revised wording focuses on collecting information when users visit clients’ websites or interact with the services. It replaces some earlier wording concerning data centres, supplier due diligence and security controls.

Risk: The revised notice appears less explicit about the purposes of processing and may create ambiguity about whether the provider acts as controller, processor or both. The statement should clearly distinguish client-controlled processing from the provider’s independent processing.

4. Security and hosting wording

The notice now states that data centres and cloud-based storage are based in the EU and UK, with contractual controls for suppliers, due diligence and ISO/IEC 27001:2013-aligned security controls.

Risk: These statements may create contractual or regulatory expectations. They should be accurate, current and consistent with actual hosting locations, international transfers, certifications and supplier arrangements.

5. AI-model training

No express change concerning use of customer data to train AI models was identified. The diff does not add or remove language authorising model training, machine learning, model improvement, or use of customer data for AI development.

Nevertheless, the broadened wording—particularly “additional information”—could be interpreted expansively. If customer data may be used for AI training, that purpose should be stated expressly, with limits, legal basis, opt-out rights and safeguards.

6. Drafting and formatting concerns

The diff contains apparent corruption and missing spacing, including “Notice.This,” duplicated sections, and an incomplete contact/address ending. The revised notice should be technically cleaned up and reviewed for GDPR transparency compliance before publication.

Summary of Important Changes

1. Major expansion and clarification of data collected

The notice changes from a general statement that the company uses data centres and cloud storage to a detailed description of information collected when individuals visit clients’ websites or interact with the services.

Newly listed data includes:

• Salutation, name, email address and phone number
• IP address and device information
• Products and services of interest
• E-commerce and transaction information, including:
• Order ID and subtotal
• Title, currency and discounts
• Shipping and items
• Product ID and client product ID
• Product URL, single-item price, category and tax

Risk: The scope of processing is materially broader and more specific. The notice should clearly explain the purposes, lawful bases, retention periods and data-controller responsibilities for each category, particularly transaction and behavioural data.

2. Broader description of collection through clients’ websites

The revised wording states that information is collected when individuals visit clients’ websites or interact with the services. It also says the information collected varies depending on how each client has configured the services.

Risk: Individuals may not understand which entity is responsible for their data or what information a particular client has enabled the company to collect. The notice relies more heavily on directing individuals to the relevant client/Data Controller.

3. Special-category and additional personal data

The text continues to acknowledge that the services may capture additional information, including personal data and special-category data. However, the wording is reorganised and now states that this may occur through the services, rather than describing it primarily as something the company may be able to determine.

The notice says special-category data is rare and that additional safeguards may be implemented with clients where identified.

Risk: “May capture” is broad and potentially uncertain. The notice should identify the types of special-category data concerned, the applicable legal condition, who determines the processing, and what safeguards are used. “Rare” does not remove regulatory obligations.

4. Security and hosting language

The revised text retains references to:

• EU and UK-based data centres and cloud storage
• Appropriate contractual controls with suppliers
• Supplier security due diligence
• The company’s own ISO/IEC 27001:2013-aligned security controls

This is more clearly presented as the company’s own security framework rather than merely a general description of its suppliers.

Risk: These statements could create compliance or contractual expectations if hosting locations, supplier controls or ISO alignment are not consistently maintained. The ISO reference should accurately describe certification or alignment, as applicable.

5. AI-model training

No express change concerning the use of customer data to train AI models is visible in the supplied diff. The revised text does not state that customer data is used—or not used—for training, fine-tuning, evaluating or improving AI models.

Risk: If the services use AI, the notice remains silent on a potentially material purpose of processing. A separate, explicit provision should address whether customer data, prompts, outputs, website data or personal information may be used for AI training, whether data is de-identified, and whether customers can opt out.

6. Administrative updates

The revised notice adds:

• A privacy contact email: privacy@salecycle.com
• A “last updated” date of 30 November 2023
• Corrected/updated postal-address formatting

Summary

The provided diff does not include the actual amended contractual language. It only states:

> “Added approximately 79 words to the document”

As a result, it is not possible to determine:

• What provisions were added, deleted, or replaced;
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models;
• Whether the customer’s data may be combined with other data or shared with affiliates or third parties;
• Whether any consent, opt-out, or deletion rights were changed;
• Whether confidentiality, ownership, security, or liability provisions were affected; or
• Whether the changes create new risks for the customer.

AI-Training Review

No substantive language concerning AI training or model development appears in the supplied diff. Accordingly, no conclusion can be reached about whether the contract:

• Permits use of customer content for AI training;
• Limits training to de-identified, aggregated, or anonymized data;
• Allows human review or vendor access to customer data;
• Gives the provider ownership or license rights over inputs, outputs, or derived models; or
• Provides assurances that customer data will not be used for training.

Required Information

Please provide the actual text of the additions, deletions, and replacements—for example:

• {new language}
• [deleted language]
• [old language]{new language}

Without the underlying wording, the legal and commercial impact of the change cannot be reliably assessed.

Summary of Important Changes

1. Expanded description of data collected

The notice now describes collection of information when individuals:

• Visit the client’s websites; or
• Interact with the provider’s services.

The listed information includes:

• Salutation, name, email address and phone number;
• IP address and device information;
• Information about products and services of interest; and
• Detailed order and transaction information, including order ID, subtotal, currency, discounts, shipping, items, product IDs, URLs, prices, categories and tax information.

Risk: The new wording substantially expands and specifies the categories of personal data collected. The notice should ensure that these categories accurately reflect actual processing and are sufficiently clear for transparency and data-minimisation purposes.

2. Potential collection of additional and sensitive data

The revised wording states that the provider may capture “additional information” depending on how the services are configured by each client. It also states that the provider may capture personal data, including special category data, although this is described as rare and subject to additional safeguards.

Risk: This is a significant privacy risk. Special category data requires heightened safeguards and a valid legal condition under applicable data protection law. The notice does not identify:

• What types of special category data may be collected;
• The legal basis or special-category condition;
• The applicable retention periods;
• The safeguards used; or
• How individuals can exercise their rights concerning such data.

The wording also shifts responsibility toward contacting the relevant Data Controller, which may not be sufficient if the provider itself processes the data as a processor or otherwise determines processing purposes.

3. Security and hosting statements changed

Previous wording referred to:

• EU/UK-based data centres and cloud storage;
• Contractual controls with suppliers;
• Due diligence on supplier security; and
• The provider’s own security controls.

The revised wording retains these concepts but presents them in a reorganised form and refers to ISO/IEC 27001:2013 standards.

Risk: The revised text should be checked for accuracy, particularly whether all processing and subprocessors are actually hosted in the EU/UK and whether ISO/IEC 27001:2013 remains the correct certification or standard reference. Avoiding an absolute EU/UK hosting impression is important if international transfers occur.

4. AI-model training

No express provision concerning AI, artificial intelligence, machine learning, model training, model improvement, or use of customer data to train models appears in the supplied diff.

Accordingly, the diff does not appear to introduce, remove or clarify any right to use customer data for AI training. If AI training is intended, it should be addressed expressly, including the data categories involved, purpose, legal basis, opt-out or objection rights, retention, de-identification, vendors and whether data is used to train general-purpose or customer-specific models.

5. Administrative changes

The notice adds a privacy contact email and states that it was last updated on 30 November 2023. It also corrects or reformats the postal address.

Risk: The update date should reflect the actual effective date, and the contact details should remain current.

Summary

The provided diff does not include the actual contractual language. It only states that approximately 79 words were added.

Legal and Risk Analysis

• AI training and data use: No conclusions can be drawn because the added wording is not provided. It is therefore impossible to determine whether customer data may be:
• Used to train, fine-tune, or improve AI models;
• Combined with other customers’ data;
• De-identified or anonymized before use;
• Shared with third-party AI providers;
• Retained after termination; or
• Used for commercial or product-development purposes.

• Other contractual changes: The substance of any changes to confidentiality, intellectual property, security, privacy, liability, warranties, or termination rights cannot be assessed.

Information Needed

Please provide the actual 79-word addition and any surrounding deleted or replacement language, using the stated notation:

• {added text}
• [deleted text]
• [old text]{new text}

Without the underlying wording, no reliable legal-risk analysis is possible.

Key Changes and Risks

1. Broader and more specific data collection

The revised notice changes the description from using “data centres” and general information to expressly stating that the service may collect information when individuals:

• Visit clients’ websites; or
• Interact with the provider’s services.

The listed data now expressly includes:

• Salutation, name, email address and phone number;
• IP address and device information;
• Products and services of interest; and
• E-commerce/order information, including order ID, subtotal, title, currency, discounts, shipping, items, product ID, client product ID, URL, single-item price, category and tax information.

Risk: This is a significant expansion and clarification of the categories of personal data covered. The notice should explain the purposes, lawful bases, retention periods and relevant recipients for each category. The wording “varies from client to client” leaves the scope potentially open-ended and makes transparency more difficult.

2. Potentially sensitive personal data

The revised wording states that, through the services, the provider may “capture additional information.” It retains the possibility that additional personal data, including special category data, may be involved, but changes the wording and presents this as something that may occur through the services rather than merely something the provider may be able to determine.

It also says the provider will work with clients to implement additional safeguards where such data is identified.

Risk: The revised language may imply a more direct role in collecting sensitive data. It does not identify the types of special category data, the applicable Article 9 condition, or the specific safeguards. This creates GDPR transparency and accountability risks, particularly if the provider acts as a processor and clients are controllers.

3. Allocation of responsibility

The notice more clearly directs individuals to contact the relevant Data Controller for a full understanding of the data collected. However, the provider’s own role remains unclear: it does not clearly state whether it acts solely as processor, jointly determines purposes, or independently uses the data for any purposes.

Risk: Ambiguity over controller/processor status can create uncertainty regarding responsibility for notices, lawful bases, data-subject rights, breaches and international transfers.

4. Security and hosting language

The revised text retains EU/UK data-centre and cloud-storage language, contractual controls, supplier due diligence and ISO/IEC 27001:2013 security references. It also states that additional safeguards may be implemented with clients.

Risk: These statements are general and do not specify actual security measures, transfer mechanisms, retention, subcontractors or applicable certifications. ISO 27001 references should not imply a guarantee of compliance or security.

5. AI-model training

No express change concerning AI or the use of customer data to train, fine-tune, evaluate or improve AI models is visible in the supplied diff. The revised language does not grant or remove an AI-training licence, nor does it explain whether customer or end-user data may be used for model development.

Recommendation: Confirm separately that the full privacy notice and contract contain clear terms addressing AI training, including opt-in/opt-out rights, permitted data, de-identification, retention, subprocessors and customer control.

Summary

The provided diff does not include the actual amended legal language. It only states:

> “Added approximately 79 words to the document”

Accordingly, it is not possible to determine what provisions changed or whether the changes create new legal risks.

AI Training and Customer Data

No substantive language is provided concerning:

• Whether customer data may be used to train, fine-tune, or improve AI models
• Whether prompts, outputs, files, or usage data are retained
• Whether data is shared with model providers or other third parties
• Whether customer data is anonymized, aggregated, or de-identified
• Whether the customer can opt out of AI training
• Whether the provider may use data for product development, analytics, or advertising
• Security, confidentiality, ownership, or deletion obligations relating to AI systems

Therefore, no conclusion can be reached about changes to AI training rights or the use of customer data.

Risk Assessment

The principal issue is that the actual 79-word addition is missing. A proper review requires the exact text, including any deletions and replacements. Without it, potentially significant changes—such as granting broader data-use rights, removing confidentiality protections, permitting model training, or limiting the customer’s ability to opt out—cannot be identified.

Required Information

Please provide the full diff using the stated notation:

• Additions: {new language}
• Deletions: [deleted language]
• Replacements: [old language]{new language}

Summary

The supplied diff does not include the actual amended contract language. It only states:

> “Added approximately 79 words to the document”

Because the added words are not shown, it is not possible to determine:

• What legal terms changed;
• Whether obligations, rights, liability, confidentiality, or termination provisions were modified;
• Whether customer data may be accessed, shared, retained, or disclosed differently; or
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models.

AI Training and Data-Use Review

No conclusion can be reached regarding AI-model training from the information provided. The added language could potentially address issues such as:

• Use of customer content to train or improve models;
• Whether training is enabled by default or requires consent;
• Use of data in de-identified, aggregated, or identifiable form;
• Human review or automated processing of customer data;
• Retention of prompts, outputs, logs, or uploaded content;
• Use of data by affiliates, vendors, or subprocessors;
• Customer opt-out or deletion rights; and
• Ownership or licensing of customer inputs and outputs.

Risk Assessment

The risk is currently indeterminate. The actual 79-word addition is required to assess whether it:

• Expands the provider’s rights to use customer data;
• Grants a broad, perpetual, irrevocable, worldwide, or royalty-free license;
• Allows data to be used for commercial model development;
• Overrides confidentiality or data-protection commitments;
• Creates compliance issues under privacy or sector-specific laws; or
• Conflicts with existing restrictions on customer data.

Please provide the text of the added language, using the specified {additions}, [deletions], and []{replacements} format, for a substantive legal analysis.

Summary

The provided diff does not include the actual added, deleted, or replaced contractual language. It only states:

> “Added approximately 79 words to the document”

Accordingly, it is not possible to determine:

• What legal obligations or rights changed;
• Whether liability, indemnity, confidentiality, termination, or governing-law provisions were modified;
• Whether customer data may be accessed, retained, disclosed, or shared differently; or
• Whether customer data may be used to train, fine-tune, evaluate, or improve AI models.

AI Training and Data-Use Review

No substantive language concerning AI models or customer data is included in the supplied diff. Therefore, no conclusion can be reached about whether the amendment:

• Permits training on customer prompts, inputs, outputs, or other content;
• Allows use of customer data to improve products or services;
• Applies data use to human review, benchmarking, or model evaluation;
• Uses customer data in aggregated, de-identified, or anonymized form;
• Grants the provider a broad license to customer content;
• Allows data retention after termination; or
• Provides an opt-out, consent requirement, or customer-control mechanism.

Required Information

Please provide the actual redline text, with additions, deletions, and replacements shown. The specific 79 added words are necessary to identify the legal and data-use implications.