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AI You Can Trust:
VWO's Responsible AI Policy

Our Commitment

Wingify Software Pvt. Ltd. and its subsidiaries and sister companies including Wingify Inc. (hereinafter “Wingify”; “We” or “Us” which expression, unless repugnant to the context hereof, shall mean and include its successors, subsidiaries and assigns) are steadfastly committed to conducting business with the highest standards of ethics, compliance, and integrity. Protecting the privacy and rights of individuals is at the core of our values whether they are visitors to the VWO website or platform(s) (“Users”), Users who register to use the Services (“Customers”; “You” or “Your”) and personal data belonging to Users, herein referred as “Customer Personal Data”.

We are a technology company that consistently stays ahead of innovation, harnessing the full potential of emerging technologies while simultaneously guaranteeing and ensuring the highest levels of compliance.

We are excited about the possibilities Artificial Intelligence (“AI”) offers to improve our products and services. We want you to feel confident that we use AI responsibly, ensuring privacy, security, and fairness as our top priorities before we deliver anything to you. Whether it is our own AI technology or trusted third party tools, we are committed to doing things the right way.

This Responsible AI Policy reflects our belief that Artificial Intelligence must be developed, deployed, and governed with transparency, fairness, accountability, and human centric values. It sets out the principles and practices. We ensure that all AI driven capabilities across our organization are developed and governed to be safe, trustworthy, privacy preserving, and aligned with global best practices. By embedding Responsible AI into every aspect of our products, services, and operations, we aspire to set a benchmark for the industry, one that not only complies with international standards but also leads the way in building AI systems the world can trust.

Non-legalese Summary:

  1. AI that helps, not replaces: VWO AI features (Copilot) assist users with tasks like generating text, images, design variations, and summaries — but all outputs require human review.
  2. Privacy first approach: All processing activities are done in compliance with applicable privacy and AI laws, VWO privacy policy and the Data Protection Addendum executed with the Customers. Consent is taken from the Users, wherever applicable.
  3. No AI model training using Customer Personal Data: Customer Personal Data is never used to train any AI or large language model.
  4. Human accountability: No automated decision making that affects individuals occurs without human oversight. Final control always rests with people, unless the User has explicitly provided consent for certain automated actions.
  5. Full transparency: Detailed articles are available for all AI features, covering functionality, privacy, compliance, and IP considerations.

What does this mean for You?

Your Data, Your Control - Always

We are deeply committed to respecting your privacy and keeping your data secure.

VWO generative AI features generate ideas, suggestions, reports, summaries, and other outputs based on non personal inputs, ensuring that your use of the platform remains compliant with applicable data privacy regulations. VWO platform empowers you to leverage its AI capabilities to their fullest potential, delivering creative insights, performance enhancing recommendations, and campaign intelligence while maintaining a privacy conscious approach that aligns with your legal and organizational obligations.

The AI system in the VWO application enables AI powered enhancements within the VWO platform. These features assist users in performing tasks such as:

  1. Generating and recommending website text using AI
  2. Generating alternate images for website elements
  3. Recommending design makeovers for A/B testing
  4. Summarizing survey responses, session recordings, heatmaps, etc.

VWO Copilot is powered by third party AI models, including OpenAI’s large language models, Google Gemini, and image generation models, which are integrated securely within the VWO application.

You decide when and how to use these AI features, ensuring that every output supports your goals while maintaining a privacy-first, compliance-aligned approach tailored to your legal and organizational obligations.

Your data security is our top priority. VWO’s AI features are safeguarded using Privacy-Enhancing Technologies (PETs) and robust Technical and Organisational Measures (TOMs). These include strong encryption in transit and at rest, anonymization and pseudonymization techniques, strict access controls, continuous monitoring, and regular security testing. By embedding PETs and TOMs into our AI lifecycle, we ensure that every insight generated through VWO remains secure, confidential, and fully aligned with global standards. In addition, we operate under globally recognized security and privacy frameworks, including ISO 27001:2022 ISMS, ISO 27701:2019 PIMS, SOC 2 Type II, and other applicable standards. These certifications validate that our practices are not only robust in design but independently audited for effectiveness.

Our Responsible AI Principles

We are committed to responsible and ethical use of Artificial Intelligence across our products and services. Our AI systems are governed by the following principles to ensure trust, safety, and fairness for all our customers:

Fairness First

Our AI systems are developed with a strong emphasis on fairness and ethical responsibility. We do our best efforts to minimize risks of bias across attributes such as gender, race, religion, caste, or geography, and ensure our AI systems are regularly tested and reviewed to uphold impartiality, inclusiveness, and ethical integrity in every use case. VWO Copilot is designed to treat all users and use cases equitably. Fairness is embedded in how our systems are tested, validated, and improved, so every customer benefits from impartial AI powered insights.

Human in the Loop

AI at VWO assists but never replaces human judgment. Every suggestion — whether a text variation, image, or design recommendation — requires human validation before implementation. We maintain clear paths and oversight to ensure critical decisions remain with our users, not algorithms. We will always make sure that humans are in the loop when critical decisions are made, so you can trust that things are being handled with care and fairness. Final control always rests with people, unless the User has explicitly provided consent for certain automated actions.

Ethical Evolution and Compliance with Global Privacy Laws

AI is a rapidly evolving field, and so are its ethical challenges. We continuously review our practices to align with global regulations, ethical frameworks, and emerging standards. By staying ahead of regulatory and industry expectations, we ensure our AI remains compliant, relevant, and responsible. We regularly check that our AI systems are working as intended, both from a technological and ethical standpoint, and update them based on any feedback or changes in the law. We follow global regulations like the GDPR, CCPA, PIPEDA, LGPD, IN DPDP to protect your information. Whether you are in the EU, the US, or anywhere else in the world, we understand and respect Customer Personal Data as if it were our own.

Collaborative Innovation

Responsible AI is a shared responsibility. We engage with regulators, industry experts, customers, and the wider community to shape a future where AI enhances experimentation without compromising trust. Customer feedback plays a central role in how we design, refine, and evolve AI features. We constantly improve our AI features to make them better, safer, and more efficient. And we do this with feedback from you, so we can evolve with your needs.

Transparency

We are committed to ensuring that the use of AI is always clear, accessible, and appropriately disclosed to Users and other data subjects. Customers retain full choice and control — they may elect to use or not use AI features. Where third-party AI models or training content are used, such information is disclosed to maintain openness and trust, wherever applicable.

Clear Accountability

We define ownership, responsibilities, and governance processes for AI across its lifecycle. This includes monitoring usage, auditing outcomes, and promptly addressing unintended consequences. Accountability is shared across our engineering, product, compliance, and leadership teams to ensure AI remains trustworthy and reliable.

End-to-End Security

Security is integral to our AI lifecycle. From development and deployment to monitoring and decommissioning, VWO safeguards AI systems with robust technical and organization security controls, encryption, and regular testing.

Privacy by Design

VWO AI features are built to protect privacy from the ground up. We have leveraged privacy enhancing technologies like anonymization and pseudonymization in our platform to enhance data subject’s privacy. We collect and process only the minimum data needed to provide value.

Eco-Conscious AI

We acknowledge the environmental footprint of AI. We consider energy efficiency, optimized infrastructure, and sustainable practices when scaling AI capabilities, ensuring that innovation does not come at the expense of the planet.

Our alignment with the EU AI Act

We are committed to building and using AI that is safe, transparent, and aligned with evolving global standards, including the European Union’s AI Act. Across our products, services, and internal operations, our AI use cases are designed and implemented as minimal-risk systems: we do not engage in biometric identification, emotion recognition, or automated decisions that affect individuals’ rights or safety. By default, our AI does not learn from or train on Customer Personal Data. Each AI feature has a clear, documented purpose; we explain what it does, how it works, and its limits, and we provide user-facing articles and notices wherever required. Customers retain control to enable or disable AI features, and we disclose the use of third-party models where applicable.

Our governance program incorporates human oversight, periodic internal audits and assessments, and rigorous vendor due diligence for third-party AI providers (including contractual safeguards such as “no training on customer data,” data-use limitations, and security obligations). We maintain technical documentation and traceability for AI features, conduct testing for robustness and bias, and operate logging, monitoring, and rollback procedures to address issues quickly. Where relevant, we perform risk and impact assessments, implement content provenance/watermarking for AI-generated media when feasible, and train stakeholders on responsible AI use. These controls help ensure ongoing compliance with the EU AI Act’s transparency and accountability expectations while keeping customer trust at the center of our AI lifecycle.

Reference articles

The details around VWO AI features are described in our product documentation and can be reviewed at the following resources:

Contact us

We have appointed a Global Data Protection Officer who is responsible for Data Privacy and AI Governance Operations at Wingify.

DPO Name: Keshav Kumar, AIGP, CIPP/E, CIPM, FIP

For any clarification or information related to VWO AI Practices, please feel free to reach out to our Global Data Privacy and AI Governance Team at privacy@vwo.com.

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