AI Systems Transparency & Compliance
Last updated: October 30, 2026
Lovvai is an AI-powered software-as-a-service (SaaS) photo generation and editing platform developed by DISINDEX S.R.L. This page transparently details the underlying architectures, C2PA/IPTC digital watermarking, allocation of responsibilities regarding text prompts, and full compliance with the EU AI Act (EU Reg. 2024/1689), the Digital Services Act (EU Reg. 2022/2065), and the GDPR (EU Reg. 2016/679).
1. AI System Notification & Neutral Technological Role (Art. 50.1 AI Act & Art. 8 DSA)
All services offered on Lovvai (including Photo Studio, Photo Book, Morphify, Remix, Caption Studio, and Image Editor) utilize advanced generative artificial intelligence models invoked via API. Users are explicitly notified that every image, portrait, or caption produced constitutes a synthetic output generated or manipulated by artificial systems, not a live photograph. In open-prompt services such as Photo Studio, Lovvai operates strictly as a neutral technological tool acting on user instructions, without offering third-party catalogs and without a general obligation of preventive monitoring over text prompts (Art. 8 EU Reg. 2022/2065).
2. Technical Watermarking & Machine-Readable C2PA/IPTC Metadata (Art. 50.2 AI Act)
Pursuant to Article 50(2) of the EU AI Act and European Commission Guidelines, every media file generated and downloaded from the platform embeds machine-readable technical metadata (IPTC Photo Metadata, dedicated EXIF tags, and C2PA Content Credentials standards) certifying the synthetic origin of the image. Pursuant to Art. 50(4) for creative works, disruptive visible watermarks are not applied to the visual surface upon private download.
3. Prompt Responsibility, Image Rights & External Labeling Duty (Art. 50.4 AI Act & Art. 612-quater Italian Penal Code)
The user holds exclusive editorial control over submitted text prompts and generated images. Pursuant to Article 50(4) of the EU AI Act, if the user decides to publish, share on social media, or externally distribute an image generated on Lovvai that depicts real people or appears photorealistic (deepfake), the user assumes the legal role of public Deployer and is required by law to clearly and visibly disclose the artificial origin of the content. Using or distributing likenesses of third parties or public figures without consent for commercial, promotional, or reputationally harmful purposes remains strictly prohibited (Art. 10 Italian Civil Code and Artt. 96-97 Law 633/1941), as does the criminal offense of transferring, publishing, or distributing deceptive deepfakes causing unjust harm (Art. 612-quater Italian Penal Code, Law 132/2025).
4. Facial Data Processing, Zero Data Training & GDPR Roles (Artt. 9 & 28 GDPR)
Uploaded user selfies are processed solely to preserve the user's facial likeness during the requested generation, strictly on Explicit Consent (Art. 9.2.a GDPR). Under Recital 51 GDPR, graphic generation from a text prompt does not involve biometric identification or profiling of third parties. For B2B clients, DISINDEX S.R.L. acts as Data Processor (Art. 28 GDPR). Transient session images are deleted within 24 hours, and no user image or prompt is ever used to train public or third-party AI models (EDPB Opinion 28/2024).
5. DSA Single Point of Contact, Abuse Reporting (Notice & Takedown) & Compliance
Pursuant to Articles 11, 12, and 16 of EU Regulation 2022/2065 (Digital Services Act - DSA), to report any content believed to infringe image rights, intellectual property, or applicable law (Notice and Takedown procedure), or to exercise GDPR rights or request AI Act compliance information, please contact DISINDEX S.R.L.'s Single Point of Contact:
DISINDEX S.R.L. - Compliance & Legal Unit
Via Renzo e Lucia 9, 20142 Milano (Italy)
P. IVA: IT11611310969 | REA: MI-2614128
Email: [email protected]