SmartAlex EU AI Act Transparency Notice (Article 50)
1. Purpose and scope
This Notice explains how THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", or "our"), approaches the transparency duties in Article 50 of the EU AI Act (Regulation (EU) 2024/1689) in connection with the SmartAlex platform, websites, applications, and APIs (the "Services").
The Services are AI systems that interact with people by telephone and by chat, including through synthetic voices. This Notice is an overlay that applies where the Services are used in a manner that falls within the scope of the EU AI Act, for example where AI systems are placed on the market, put into service, or used within the European Union, or where their output is used in the European Union. It supplements, and does not displace, the wider SmartAlex terms, which remain governed by the laws of the Republic of Singapore.
1.1 What this Notice does and does not do
This Notice describes the transparency controls that SmartAlex makes available and the way responsibility for using them is allocated between SmartAlex and its customers. It does not constitute legal advice, and it does not warrant that any particular deployment complies with the EU AI Act. Whether and how Article 50 applies to a given use of the Services depends on the specific deployment, the role of each party, and guidance issued by competent authorities, which continues to develop.
1.2 Key terms
- AI system: a machine-based system of the kind described in the EU AI Act that, for the purposes of the Services, interacts with a natural person by voice or text.
- Provider: the party that develops an AI system, or has one developed, and places it on the market or puts it into service under its own name. For the technical means it supplies, SmartAlex generally acts as a provider.
- Deployer: the party that uses an AI system under its own authority in the course of its activity. The SmartAlex customer that configures and runs an AI voice agent or chatbot is generally the deployer.
- Synthetic content: audio, or other content, that is artificially generated or manipulated by an AI system.
2. Interacting with an AI system
Where a natural person interacts with a SmartAlex AI voice agent or chatbot, that person should be informed that they are interacting with an AI system, unless this is obvious from the circumstances and the context of use, taking into account a reasonably well-informed, observant, and circumspect person.
2.1 How disclosure is delivered
SmartAlex provides technical means for this disclosure to be made, for example a spoken statement at the start of a call or an equivalent indication in a chat interface. The disclosure is intended to be clear and to be given at the point of first interaction.
2.2 Who is responsible for enabling it
The customer that deploys the AI voice agent or chatbot is responsible for enabling and configuring the disclosure for its own use cases, including any wording required by its context and jurisdiction. SmartAlex makes the controls available; the deployer is responsible for turning them on and keeping them on where disclosure is required.
3. Synthetic audio and generated content
Article 50 addresses the marking of synthetic content. Audio that is artificially generated or manipulated through the Services, including synthetic voice output, should be disclosed or marked as artificially generated or manipulated where Article 50 requires, in a manner that is, so far as reasonably practicable, effective, interoperable, robust, and reliable, taking account of technical limitations and the state of the art.
3.1 Where marking may not be required
Certain marking obligations are subject to exceptions in the EU AI Act, for example where the use is authorised by law, or where the content forms part of an evidently creative, satirical, or analogous work or programme, subject to appropriate safeguards. Whether an exception applies depends on the specific deployment and is a matter for the deployer to assess.
3.2 Related policy
Our approach to disclosing synthetic voice and to marking generated audio is described in more detail in our Synthetic Media and AI Voice Disclosure Policy, which should be read together with this Notice.
4. Deepfakes and manipulated content
The Services must not be used to create or distribute deceptive deepfakes, meaning synthetic audio or other content that falsely appears to be an authentic recording of a real person, event, or place in a way that is intended or likely to mislead.
- Where content generated or manipulated through the Services would falsely appear to be authentic, the party deploying it is responsible for disclosing that the content has been artificially generated or manipulated, where such disclosure is required.
- Impersonating an identifiable natural person, or cloning a voice, without a lawful basis and the necessary consents is prohibited.
- Use of the Services in a way that is manipulative, deceptive, or otherwise prohibited under the EU AI Act or applicable law is not permitted.
These restrictions operate alongside, and do not narrow, the acceptable-use commitments in our AI Usage Policy.
5. Roles and responsibilities
Transparency obligations under the EU AI Act are allocated between providers and deployers, and the correct classification depends on the facts of each deployment.
5.1 What SmartAlex provides
SmartAlex provides the technical means for AI-interaction disclosure and for the disclosure or marking of synthetic audio, together with the controls needed to enable them. As the party supplying these technical means, SmartAlex generally acts in a provider capacity for that layer.
5.2 What the customer is responsible for
The customer, as the deployer of an AI voice agent or chatbot, is responsible for enabling the applicable disclosures, for configuring them appropriately, and for the compliance of its own use case, including the lawfulness of its calling and messaging activity and any consents it must obtain. SmartAlex does not control how a customer configures or operates its deployment.
5.3 Classification depends on the deployment
Nothing in this Notice fixes the legal classification of any party for a particular deployment. Whether SmartAlex or a customer is a provider, a deployer, or both for a given use, and which obligations follow, depends on the specific circumstances and on applicable guidance. Each party is responsible for assessing its own role and obligations.
6. Timing and phase-in
The EU AI Act applies in phases, and its obligations take effect on different dates. The Article 50 transparency obligations apply from their applicable date under the Regulation. SmartAlex approaches those obligations as described in this Notice and will review and update its controls and this Notice as implementing guidance, standards, and codes of practice develop. References in this Notice to obligations should be read as applying to the extent, and from the date, that they are in force for the relevant deployment.
7. Relationship to other terms
This Notice supplements our AI Usage Policy, our Synthetic Media and AI Voice Disclosure Policy, and our GDPR Article 13 Notice. Where personal data is processed in connection with the Services, our Privacy Policy also applies. Information about the infrastructure that supports the Services is set out in our Subprocessor List.
If there is a conflict between this Notice and another SmartAlex term on the specific subject of EU AI Act transparency, this Notice governs for that subject. In all other respects the wider terms continue to apply. Nothing in this Notice limits or excludes any non-waivable statutory rights, including under EU law, that a natural person may have.
8. Updates and contact
We may update this Notice from time to time to reflect changes in the Services, in applicable law, or in regulatory guidance. The current version is the one published at this address.
For questions about how we handle personal data, contact privacy@getsmartalex.com. For questions about this Notice, contact legal@getsmartalex.com.
This Notice is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.
9. Version and effective date
This EU AI Act Transparency Notice is version 1.0 and is effective from 8 July 2026.