AI Transparency Disclosure
Last updated: February 27, 2026Version: 1.0
Summary
This page explains how Bubba uses artificial intelligence, including our AI-powered chat assistant, search ranking, and content moderation. We comply with the EU AI Act transparency obligations and ensure human oversight of all AI-generated content.
This page explains how MB Bubba ("Bubba", "we", "us") uses artificial intelligence ("AI") within the platform. This disclosure is provided in accordance with the EU AI Act (Regulation (EU) 2024/1689), Articles 50 and 52, as well as our commitment to transparency about automated systems that interact with our users.
- Overview of AI Use on Bubba
Bubba integrates AI functionality to enhance the user experience. We are committed to responsible AI use, transparency about when and how AI is employed, and ensuring human oversight of AI-generated content.
Summary of AI Systems
| AI Feature | Purpose | Risk Classification (EU AI Act) | Users Affected |
|---|---|---|---|
| AI-Assisted Chat (Bubba Assistant) | Provides informational assistance during chat conversations between pet owners and service providers | Limited risk (Art. 50 — transparency obligation) | Pet owners, service providers |
| Search Ranking | Algorithmic sorting of service provider search results | Minimal risk | Pet owners |
| Content Moderation Assistance | Flagging potentially inappropriate reviews or listings for human review | Minimal risk | All users |
- AI-Assisted Chat ("Bubba Assistant")
2.1 What It Is
Bubba offers an AI-powered chat assistant ("Bubba Assistant") that can participate in conversations between pet owners and service providers. The assistant can:
- Conduct initial intake interviews to gather pet and symptom information before a veterinary consultation.
- Provide helpful pet care information when summoned by a user via the
@bubbamention. - Look up relevant pet profile data and booking information to assist the conversation.
2.2 AI Interaction Labeling
In accordance with EU AI Act Article 50(1), all interactions with the Bubba Assistant are clearly labeled:
- AI-generated messages are visually distinguished from messages sent by human participants (different message styling, avatar, and clear labeling).
- The AI assistant is identified by name ("Bubba") with an AI indicator so that users know they are interacting with an AI system, not a human.
- Users are informed at the start of any AI interaction that the responses are generated by an artificial intelligence system.
2.3 How It Works
| Aspect | Detail |
|---|---|
| AI Model Provider | OpenRouter (openrouter.ai) — an EU-based LLM routing service |
| Model Routing | OpenRouter routes requests to appropriate language models hosted on EU-based infrastructure |
| Data Processed | Chat messages within the conversation context, pet profile data (species, breed, age, medical notes), and booking information relevant to the conversation |
| Data Retention | Conversations are stored in our database as part of the chat session record. Chat messages sent to the LLM provider are processed transiently and are not retained by the LLM provider for model training |
| Human Oversight | Service providers can enable or disable AI assistance in their chat sessions at any time. The AI assistant augments — it does not replace — human communication |
2.4 Limitations & Disclaimers
The Bubba Assistant is not a substitute for professional advice.
- AI-generated responses are informational only and do not constitute veterinary, medical, legal, or professional advice of any kind.
- The AI assistant may produce inaccurate, incomplete, or outdated information. Users should verify any important information with a qualified professional.
- The AI assistant does not make decisions on behalf of users — all booking, payment, and service decisions remain with the human participants.
- The AI assistant does not have access to real-time external data sources beyond the information stored on the Bubba platform.
- AI responses are not used for automated decision-making that produces legal or similarly significant effects on users (GDPR Article 22).
2.5 Opting Out
- Service providers can disable AI assistance for their chat sessions through the chat interface.
- Pet owners are never forced to interact with the AI — they can communicate directly with the service provider.
- Disabling AI assistance does not affect any other platform functionality.
- Search Ranking Algorithm
3.1 What It Is
Bubba uses an algorithmic system to rank pet service providers in search results. This is not a machine learning or generative AI system — it is a deterministic algorithm based on defined parameters.
3.2 Ranking Parameters
The ranking algorithm and its parameters are fully disclosed in our Business Terms & Conditions, Section 2 ("Ranking Parameters"), in compliance with the P2B Regulation. In summary:
- Average rating (highest importance) — Providers with ratings appear before those without.
- Service type match — Filter by requested service category.
- City / location match — Filter by geographic area.
- Text query relevance — Filter by business name match.
- Availability — Displayed but does not currently affect sort order.
- Account status — Only active providers are shown.
3.3 AI Act Classification
This system is classified as minimal risk under the EU AI Act because:
- It does not fall within the categories of prohibited or high-risk AI systems.
- It uses transparent, deterministic ranking logic.
- It does not employ machine learning, profiling, or behavioral prediction.
- The ranking parameters are fully disclosed.
- Content Moderation
4.1 Current Approach
Content moderation on Bubba (reviews, listings, reports) is primarily human-driven. The process is described in detail in our DSA Transparency page and Reviews & Ratings Policy.
- AI Act Risk Assessment
5.1 Classification
Under the EU AI Act's risk-based framework, our AI systems are classified as follows:
| Category | Applicability to Bubba |
|---|---|
| Prohibited AI (Art. 5) | Not applicable — we do not deploy subliminal, exploitative, social scoring, or biometric categorization systems |
| High-risk AI (Annex III) | Not applicable — our AI systems do not fall within the high-risk categories (not used for recruitment, credit scoring, law enforcement, migration, or critical infrastructure) |
| Limited risk (Art. 50) | Applicable to the Bubba Assistant — transparency obligation (users must be informed of AI interaction) |
| Minimal risk | Applicable to search ranking and future content moderation flagging |
5.2 Compliance Measures
For our limited-risk AI system (Bubba Assistant), we implement the following measures:
- Transparency (Art. 50(1)): Users are clearly informed when they interact with the AI system. AI messages are visually labeled and distinguished from human messages.
- No emotional manipulation: The AI assistant does not employ techniques to exploit vulnerabilities or manipulate user behavior.
- No deception: The AI assistant is clearly identified as artificial intelligence and does not impersonate humans.
- Data protection: AI processing complies with GDPR as detailed in our Privacy Policy, Section 7 (Automated Decision-Making and Profiling).
- Record-keeping: We maintain records of AI processing activities as part of our GDPR processing records.
- Data Protection & AI
6.1 Legal Basis
The processing of personal data by AI systems on Bubba is conducted under the following legal bases:
| AI System | Legal Basis | GDPR Article |
|---|---|---|
| Bubba Assistant (authenticated users) | Contract performance | Art. 6(1)(b) |
| Bubba Assistant (guest users, if applicable) | Consent | Art. 6(1)(a) |
| Search ranking | Contract performance | Art. 6(1)(b) |
6.2 Sub-Processor
AI chat data is processed by OpenRouter (openrouter.ai), which acts as a sub-processor under contractual data protection obligations compliant with GDPR Article 28. OpenRouter uses EU-based infrastructure for data processing. For full details, see our Data Processing Agreement, Section 2 (Sub-Processors).
6.3 Your Rights
You have the right to:
- Not be subject to automated decision-making — Our AI systems do not make decisions with legal or similarly significant effects. Search ranking is informational only.
- Object to AI processing — You can opt out of AI chat interactions (see Section 2.5).
- Access AI-processed data — Your chat conversations (including AI interactions) are included in data export requests via the Privacy Settings.
- Erasure — AI interaction data is covered by the data erasure process described in our Privacy Policy and GDPR Rights pages.
- Accountability & Contact
7.1 Oversight
AI systems on Bubba are subject to regular internal review to ensure continued compliance with the EU AI Act, accuracy of disclosures, and alignment with our values of transparency and user safety.
7.2 Reporting Issues
If you experience issues with an AI system on Bubba, including inaccurate AI-generated content, lack of transparency, or concerns about AI behavior:
- In-app: Report via the chat interface or contact support.
- By email: legal@bubba.pet or privacy@bubba.pet.
7.3 National Authority
The competent national authority for AI Act enforcement in Lithuania is:
Ryšių reguliavimo tarnyba (Communications Regulatory Authority — RRT) Mortos g. 14, LT-03219 Vilnius, Lithuania https://www.rrt.lt
- Changes to This Disclosure
We will update this disclosure when:
- New AI features are introduced or existing ones are significantly changed.
- The EU AI Act implementing measures or guidance require updates.
- Our AI providers or processing arrangements change.
Material changes will be communicated at least 30 days in advance via email and/or in-app notification.
Related Documents
- Privacy Policy — Section 7 (Automated Decision-Making and Profiling)
- Business Terms & Conditions — Section 2 (Ranking Parameters)
- Data Processing Agreement — Section 2 (Sub-Processors)
- DSA Transparency — Content moderation practices
- Reviews & Ratings Policy — Review moderation
- GDPR Rights — Your data protection rights