GPAI Ledger The public record of EU AI Act training-data summaries

GPAI LedgerFIBO (Bria AI) › Capture 17 Aug 2026

FIBO — capture 20260817T084132Z

ProviderBria AI
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Bria  Artificial  Intelligence  Ltd.
Public  Summary  of  Training  Content

FIBO,  FIBO  Lite  and  FIBO  Edit

Required  by  Article  53(1)(d)  of  Regulation  (EU)  2024/1689  (AI  Act),  drawn  up  according  to  the  Template
annexed

to

Commission

Communication

C(2025)

5235

final

of

24

July

2025.

Version  of  the  Summary  Version  1.0.  No  previous  versions.
Last  update  02/08/2026
1.

General

information

1.1.

Provider

identification

Provider  name  and  contact  details
Bria  Artificial  Intelligence  Ltd.     10  Kremenisty  St.,  Tel  Aviv,  Israel  legal@bria.ai     https://www.bria.ai
Authorised  representative  name  and  contact  details
Vered  Horesh  Chief  AI  Strategy  Officer  legal@bria.ai
1.2.

Model

identification

Versioned  model  name(s)  FIBO,  FIBO  Lite  and  FIBO  Edit.  This  Summary  covers  all  three,  whose  training  content  is  identical.  FIBO  Model  Card:  https://huggingface.co/briaai/FIBO  FIBO  Lite  Model  Card:  https://huggingface.co/briaai/Fibo-lite Fibo  Edit  Model  Card:  https://huggingface.co/briaai/Fibo-Edit
Model  dependencies  FIBO  is  the  product  of  Bria's  own  pre-training  run  and  is  not  a  modification  or  fine-tune  of  another  provider's  general-purpose  AI  model.  Bria  discloses  on  a  voluntary  basis  that  the  model  incorporates  two  third-party  open-weight  components  which  Bria  did  not  train  and  does  not  modify,  and  which  are  used  with  their  published  weights  held  frozen:  •  Wan2.2-VAE,  provided  by  the  Wan  Team  at  Alibaba  Group  under  the  Apache  License  2.0,  used  as  the  variational  autoencoder.  Source:  https://github.com/Wan-Video/Wan2.2.  Wan2.2  was  placed  on  the  market  before  2  August  2025  and  falls  within  the  transitional  period  in  Article  111(3)  AI  Act;  its  provider  has  not  published  a  summary  of  training  content.
 1
  •  SmolLM3-3B,  provided  by  Hugging  Face  under  the  Apache  License  2.0,  used  as  the  text  encoder.  Source:  https://huggingface.co/HuggingFaceTB/SmolLM3-3B.  Pretrained  by  its  provider  on  11.2  trillion  tokens  of  web,  code,  mathematics  and  reasoning  data.  Its  provider  has  published  a  summary  of  training  content  on  the  model  card,  to  which  reference  is  made.  The  data  used  to  train  these  components  lies  outside  Bria's  content  licensing  programme  and  Bria  makes  no  representation  as  to  its  provenance.  Statements  elsewhere  in  this  Summary  concerning  the  exclusive  use  of  commercially  licensed  content  and  the  absence  of  crawling  relate  to  the  data  on  which  Bria  trained  the  model.
Date  of  placement  of  the  model  on  the  Union  market
FIBO  on  or  about  29  October  2025;  FIBO  Lite  on  or  about  1  December  2025;  FIBO  Edit  on  or  about  16  January  2026.
1.3.

Modalities,

overall

training

data

size

and

other

characteristics
 Reported  for  the  data  on  which  Bria  trained  the  model.  Data  used  by  the  third-party  providers  of  the
components

identified

in

Section

1.2

is

not

included

and

is

not

known

to

Bria.

Modality  Training  data  size  Types  of  content
Image  479  million  images  Fully  licensed  images  provided  by  Bria  data  partners  under  transactional  commercial  licensing  agreements  with  rightsholders  globally.
Text  Up  to  120  billion  tokens  Captions  describing  the  licensed  images  in  the  training  set.  Fewer  than  100  million  images  carry  long  structured  JSON  captions  covering  attributes  including  subject,  composition,  lighting,  colour  and  camera  parameters;  the  remainder  carry  shorter  captions.  All  captions  are  generated  as  metadata  to  enrich  the  licensed  image  data.
Audio  /  Video  /  Other
Not  selected.  N/A

Latest  date  of  data  acquisition  /  collection  for  model  training
June  2025.  The  model  is  not  continuously  trained  on  new  or  dynamic  data  after  that  date.
Description  of  the  linguistic  characteristics  of  the  overall  training  data
The  structured  JSON  captions  are  in  English.  The  SmolLM3-3B  text  encoder  identified  in  Section  1.2  natively  supports  English,
 2
  French,  Spanish,  German,  Italian  and  Portuguese,  which  bears  on  the  model's  effective  prompt  language  coverage.
Other  relevant  characteristics  of  the  overall  training  data
Bria's  model  weights  are  trained  exclusively  on  content  obtained  through  commercial  licensing  agreements  with  data  partners  globally,  ensuring  diverse  representation  across  cultures,  ethnicities,  ages,  genders  and  geographical  locations,  with  balanced  coverage  across  domain  categories  and  content  from  multiple  international  markets.  All  such  training  data  consists  of  human-created  content  with  explicit  commercial  use  releases,  deliberately  excluding  public  figures,  harmful  material  and  copyrighted  fictional  characters.  This  description  relates  to  the  data  Bria  licensed  and  trained  on.  It  does  not  extend  to  the  unmodified  third-party  components  identified  in  Section  1.2.
2.

List

of

data

sources

2.1.

Publicly

available

datasets

Have  you  used  publicly  available  datasets  to  train  the  model?
No.  All  training  data  is  sourced  exclusively  through  transactional  commercial  licensing  agreements  that  expressly  authorise  the  use  of  licensed  content  for  generative  AI  model  training.  Each  agreement  includes  warranties  and  representations  from  the  licensor  confirming  its  full  legal  right,  title  and  authority  to  license  the  data  objects  and  to  grant  the  rights  necessary  for  AI  training  applications.
2.2.

Private

non-publicly

available

datasets

obtained

from

third

parties

2.2.1  Have  you  concluded  transactional  commercial  licensing  agreement(s)  with  rightsholder(s)  or  their  representatives?
Yes.
Modality(ies)  covered  Image.
2.2.2  Have  you  obtained  private  datasets  from  third  parties  that  are  not  licensed  as  described  in  Section  2.2.1?
No.
General  description  All  content  is  sourced  from  rightsholders  or  their  authorised  representatives,  who  have  obtained  all  necessary  model
 3
  releases,  property  releases  and  intellectual  property  clearances.
2.3.

Data

crawled

and

scraped

from

online

sources

Were  crawlers  used  by  the  provider  or  on  their  behalf?
No.  Bria  does  not  engage  in  web  crawling  or  scraping.  Accordingly  no  crawler  identifiers,  collection  period  or  domain  name  list  falls  to  be  disclosed.
2.4.

User

data

Was  data  from  user  interactions  with  the  AI  model  used  to  train  the  model?
No.
Was  data  collected  from  user  interactions  with  the  provider's  other  services  or  products  used  to  train  the  model?
No.
2.5.

Synthetic

data

Was  synthetic  AI-generated  data  created  by  the  provider  or  on  their  behalf  to  train  the  model?
No.  Note:  in  accordance  with  the  AI  Office's  instructions,  this  Section  does  not  refer  to  the  use  of  AI  models  to  clean  or  enrich  data,  for  example  AI-generated  metadata  to  enrich  or  modify  a  dataset  such  as  creating  text  descriptions  of  images.  Bria  does  use  captions  generated  with  third-party  AI  models  for  enrichment  of  its  data.
2.6.

Other

sources

of

data

Have  data  sources  other  than  those  described  in  Sections  2.1  to  2.5  been  used  to  train  the  model?
No.  No  offline  or  self-digitised  sources,  no  datasets  labelled  by  human  subjects  commissioned  by  the  provider,  and  no  human-generated  data  obtained  through  reinforcement  learning  have  been  used.
3.

Data

processing

aspects

3.1.

Respect

of

reservation

of

rights

from

the

TDM

exception

or

limitation

Are  you  a  Signatory  to  the  Code  of  Practice  for  general-purpose  AI  models
Yes.  Bria  is  a  signatory  to  the  General-Purpose  AI  Code  of  Practice.
 4
  that  includes  commitments  to  respect  reservations  of  rights  from  the  TDM  exception  or  limitation?
Describe  the  measures  implemented  before  model  training
Bria  performs  no  crawling  or  scraping  and  does  not  rely  on  the  text  and  data  mining  exception  or  limitation  for  the  acquisition  of  training  data.  All  training  content  is  acquired  under  transactional  commercial  licensing  agreements  with  rightsholders  or  their  authorised  representatives,  each  including  warranties  as  to  the  licensor's  right,  title  and  authority  to  license  the  content  for  generative  AI  model  training.  Bria  maintains  legal  verification  of  all  licensing  agreements,  detailed  data  cataloguing  systems,  and  regular  audits  of  data  source  compliance.  Bria  nonetheless  acknowledges  and  respects  reservations  of  rights  expressed  pursuant  to  Article  4(3)  of  Directive  (EU)  2019/790  and  maintains  systems  to  identify  and  comply  with  such  reservations  where  applicable.  Bria's  Copyright  Policy  under  Article  53(1)(c)  AI  Act  is  published  here.
3.2.

Removal

of

illegal

content

General  description  of  measures  taken
Bria's  training  data  sourcing  methodology  inherently  limits  the  inclusion  of  illegal  content  through  the  exclusive  use  of  commercially  licensed  datasets  obtained  from  verified  professional  data  partners  and  established  image  bank  providers.  Each  licensing  agreement  requires  the  licensor  to  warrant  that  the  licensed  content  is  original  and  human-created,  does  not  infringe  third-party  copyright,  trademark  or  other  intellectual  property  rights,  does  not  feature  public  figures,  harmful  material  or  copyrighted  fictional  characters,  and  is  subject  to  all  necessary  model  and  property  releases  where  identifiable  persons  or  property  are  depicted.  Bria  operates  an  automated  cataloguing  pipeline  that  records  each  asset  with  a  clear  link  to  its  origin,  applies  content  moderation  filtering  to  exclude  harmful  material,  and  subjects  data  partners  to  periodic  compliance  audits  and  remediation  procedures.  Training  datasets  are  fully  anonymised  through  removal  of  naming  and  identifying  metadata.
3.3.

Other

information

(optional)

Other  relevant  information  about  data  processing
Bria  applies  C2PA  Content  Credentials  to  model  outputs  and  holds  a  root  on  the  C2PA  trust  list.  Bria  operates  a  patented  attribution  technology  that  measures  each  data  licensor's
 5
  contribution  to  generated  content  and  provides  recurring  compensation  on  that  basis.  Rightsholders  may  submit  precise  and  substantiated  complaints  to  legal@bria.ai;  this  mechanism  complements  and  does  not  limit  any  legal  remedies  available  under  Union  or  national  copyright  law.

 6
  Bria  Artificial  Intelligence  Ltd.
Public  Summary  of  Training  Content

Bria  3.2

Required  by  Article  53(1)(d)  of  Regulation  (EU)  2024/1689  (AI  Act),  drawn  up  according  to  the  Template
annexed

to

Commission

Communication

C(2025)

5235

final

of

24

July

2025.

Version  of  the  Summary  Version  2.0.  Supersedes  the  version  first  published  with  effect  from  1  September  2025  and  last  updated  6  January  2026.
Last  update  02/08/2026
1.

General

information

1.1.

Provider

identification

Provider  name  and  contact  details
Bria  Artificial  Intelligence  Ltd.     10  Kremenisty  St.,  Tel  Aviv,  Israel  legal@bria.ai     https://www.bria.ai
Authorised  representative  name  and  contact  details
Vered  Horesh  Chief  AI  Strategy  Officer  legal@bria.ai
1.2.

Model

identification

Versioned  model  name(s)  Bria  3.2  (briaai/BRIA-3.2).  https://huggingface.co/briaai/BRIA-3.2
Model  dependencies  Bria  3.2  is  the  product  of  Bria's  own  pre-training  run  and  is  not  a  modification  or  fine-tune  of  another  provider's  general-purpose  AI  model.  Bria  discloses  on  a  voluntary  basis  that  the  model  incorporates  two  third-party  open-weight  components  which  Bria  did  not  train  and  does  not  modify,  and  which  are  used  with  their  published  weights  held  frozen:  •  T5  version  1.1  XXL,  provided  by  Google  under  the  Apache  License  2.0,  used  as  the  text  encoder.  Bria  uses  the  t5-v1_1-xxl  variant.  As  documented  by  its  provider,  T5  version  1.1  was  pretrained  on  the  Colossal  Clean  Crawled  Corpus  (C4),  a  dataset  derived  from  Common  Crawl  web  data.  T5  was  placed  on  the  market  well  before  2  August  2025  and  falls  within  the  transitional  period  in  Article  111(3)  AI  Act;  its  provider  has  not  published  a  summary  of  training  content.
 7
  •  An  open-source  variational  autoencoder  with  an  f8  spatial  compression  factor,  used  for  encoding  images  to  and  decoding  images  from  latent  representations.  The  data  used  to  train  these  components  lies  outside  Bria's  content  licensing  programme  and  Bria  makes  no  representation  as  to  its  provenance.  Statements  elsewhere  in  this  Summary  concerning  the  exclusive  use  of  commercially  licensed  content  and  the  absence  of  crawling  relate  to  the  data  on  which  Bria  trained  the  model.
Date  of  placement  of  the  model  on  the  Union  market
10  June  2025.
1.3.

Modalities,

overall

training

data

size

and

other

characteristics
 Reported  for  the  data  on  which  Bria  trained  the  model.  Data  used  by  the  third-party  providers  of  the
components

identified

in

Section

1.2

is

not

included

and

is

not

known

to

Bria.

Modality  Training  data  size  Types  of  content
Image  479  million  images  Fully  licensed  images  provided  by  Bria  data  partners  under  transactional  commercial  licensing  agreements  with  rightsholders  globally.
Text  Up  to  19.2  billion  tokens  Captions  describing  the  licensed  images  in  the  training  set,  generated  as  metadata  to  enrich  the  licensed  image  data.
Audio  /  Video  /  Other
Not  selected.  N/A

Latest  date  of  data  acquisition  /  collection  for  model  training
June  2025.  The  model  is  not  continuously  trained  on  new  or  dynamic  data  after  that  date.
Description  of  the  linguistic  characteristics  of  the  overall  training  data
The  captions  are  in  English.
Other  relevant  characteristics  of  the  overall  training  data
Bria's  model  weights  are  trained  exclusively  on  content  obtained  through  commercial  licensing  agreements  with  data  partners  globally,  ensuring  diverse  representation  across  cultures,  ethnicities,  ages,  genders  and  geographical  locations.  The  dataset  maintains  balanced  coverage  across  domain  categories  while  incorporating  content  from  multiple  international  markets.  All  such  training  data  consists  of  human-created  content  with  explicit  commercial  use  releases,
 8
  deliberately  excluding  public  figures,  harmful  material  and  copyrighted  fictional  characters.  This  description  relates  to  the  data  Bria  licensed  and  trained  on.  It  does  not  extend  to  the  unmodified  third-party  components  identified  in  Section  1.2,  whose  training  data  lies  outside  Bria's  licensing  programme  and  is  not  known  to  Bria.
2.

List

of

data

sources

2.1.

Publicly

available

datasets

Have  you  used  publicly  available  datasets  to  train  the  model?
No.  All  training  data  is  sourced  exclusively  through  transactional  commercial  licensing  agreements  that  expressly  authorise  the  use  of  licensed  content  for  generative  AI  model  training.  Each  agreement  includes  warranties  and  representations  from  the  licensor  confirming  its  full  legal  right,  title  and  authority  to  license  the  data  objects  and  to  grant  the  rights  necessary  for  AI  training  applications.
2.2.

Private

non-publicly

available

datasets

obtained

from

third

parties

2.2.1  Have  you  concluded  transactional  commercial  licensing  agreement(s)  with  rightsholder(s)  or  their  representatives?
Yes.
Modality(ies)  covered  Image.
2.2.2  Have  you  obtained  private  datasets  from  third  parties  that  are  not  licensed  as  described  in  Section  2.2.1?
No.
General  description  All  content  is  sourced  from  rightsholders  or  their  authorised  representatives,  who  have  obtained  all  necessary  model  releases,  property  releases  and  intellectual  property  clearances.
2.3.

Data

crawled

and

scraped

from

online

sources

Were  crawlers  used  by  the  provider  or  on  their  behalf?
No.  Bria  does  not  engage  in  web  crawling  or  scraping.  Accordingly  no  crawler  identifiers,  collection  period  or  domain  name  list  falls  to  be  disclosed.
 9

2.4.

User

data

Was  data  from  user  interactions  with  the  AI  model  used  to  train  the  model?
No.
Was  data  collected  from  user  interactions  with  the  provider's  other  services  or  products  used  to  train  the  model?
No.
2.5.

Synthetic

data

Was  synthetic  AI-generated  data  created  by  the  provider  or  on  their  behalf  to  train  the  model?
No.  Note:  in  accordance  with  the  AI  Office's  instructions,  this  Section  does  not  refer  to  the  use  of  AI  models  to  clean  or  enrich  data,  for  example  AI-generated  metadata  to  enrich  or  modify  a  dataset  such  as  creating  text  descriptions  of  images.  Bria  does  use  captions  generated  with  third-party  AI  models  for  enrichment  of  its  data.
2.6.

Other

sources

of

data

Have  data  sources  other  than  those  described  in  Sections  2.1  to  2.5  been  used  to  train  the  model?
No.  No  offline  or  self-digitised  sources,  no  datasets  labelled  by  human  subjects  commissioned  by  the  provider,  and  no  human-generated  data  obtained  through  reinforcement  learning  have  been  used.
3.

Data

processing

aspects

3.1.

Respect

of

reservation

of

rights

from

the

TDM

exception

or

limitation

Are  you  a  Signatory  to  the  Code  of  Practice  for  general-purpose  AI  models  that  includes  commitments  to  respect  reservations  of  rights  from  the  TDM  exception  or  limitation?
Yes.  Bria  is  a  signatory  to  the  General-Purpose  AI  Code  of  Practice.
Describe  the  measures  implemented  before  model  training
Bria  performs  no  crawling  or  scraping  and  does  not  rely  on  the  text  and  data  mining  exception  or  limitation  for  the  acquisition  of  training  data.  All  training  content  is  acquired  under  transactional  commercial  licensing  agreements  with  rightsholders  or  their  authorised  representatives,  each
 10
  including  warranties  as  to  the  licensor's  right,  title  and  authority  to  license  the  content  for  generative  AI  model  training.  Bria  maintains  legal  verification  of  all  licensing  agreements,  detailed  data  cataloguing  systems,  and  regular  audits  of  data  source  compliance.  Bria  nonetheless  acknowledges  and  respects  reservations  of  rights  expressed  pursuant  to  Article  4(3)  of  Directive  (EU)  2019/790  and  maintains  systems  to  identify  and  comply  with  such  reservations  where  applicable.  Bria's  Copyright  Policy  under  Article  53(1)(c)  AI  Act  is  published  here.
3.2.

Removal

of

illegal

content

General  description  of  measures  taken
Bria's  training  data  sourcing  methodology  inherently  limits  the  inclusion  of  illegal  content  through  the  exclusive  use  of  commercially  licensed  datasets  obtained  from  verified  professional  data  partners  and  established  image  bank  providers.  Each  licensing  agreement  requires  the  licensor  to  warrant  that  the  licensed  content  is  original  and  human-created,  does  not  infringe  third-party  copyright,  trademark  or  other  intellectual  property  rights,  does  not  feature  public  figures,  harmful  material  or  copyrighted  fictional  characters,  and  is  subject  to  all  necessary  model  and  property  releases  where  identifiable  persons  or  property  are  depicted.  Bria  operates  an  automated  cataloguing  pipeline  that  records  each  asset  with  a  clear  link  to  its  origin,  applies  content  moderation  filtering  to  exclude  harmful  material,  and  subjects  data  partners  to  periodic  compliance  audits  and  remediation  procedures.  Training  datasets  are  fully  anonymised  through  removal  of  naming  and  identifying  metadata.
3.3.

Other

information

(optional)

Other  relevant  information  about  data  processing
Bria  applies  C2PA  Content  Credentials  to  model  outputs  and  holds  a  root  on  the  C2PA  trust  list.  Bria  operates  a  patented  attribution  technology  that  measures  each  data  licensor's  contribution  to  generated  content  and  provides  recurring  compensation  on  that  basis.  Rightsholders  may  submit  precise  and  substantiated  complaints  to  legal@bria.ai;  this  mechanism  complements  and  does  not  limit  any  legal  remedies  available  under  Union  or  national  copyright  law.
 11
  Bria  Artificial  Intelligence  Ltd.
Copyright  Policy

Article  53(1)(c)  of  Regulation  (EU)  2024/1689

Version  Version  2.0.  Supersedes  the  version  dated  September  2025.
Last  update  02/08/2026
Models  covered  All  general-purpose  AI  models  placed  on  the  Union  market  by  Bria,  including  the  Bria  3.x  family  and  the  FIBO  family.
1.

Copyright

Compliance

Framework

at

Bria

Our  commitment  to  copyright  compliance  is  fundamental  to  our  responsible  AI  development.  We
recognise

that

true

accountability

in

AI

requires

rigorous

adherence

to

intellectual

property

rights

and

legal

standards.

Our  copyright  policy  reflects  our  core  principles:
•  Respecting  rightsholders  •  Ensuring  full  legal  compliance  •  Maintaining  the  highest  standards  of  ethical  AI  development  •  Providing  equitable  compensation  to  all  data  licensors  through  our  proprietary  and  patented
algorithmic

attribution

technology

that

measures

and

rewards

each

contributor's

impact

on

generated

content
 This  document  outlines  our  comprehensive  approach  to  copyright  compliance  for  our  general-purpose
AI

models

placed

on

the

market.

We  have  developed  this  policy  to  demonstrate  our  commitment  to:
•  Fully  complying  with  laws  and  regulations  on  copyright  and  related  rights,  specifically  Article
53(1)(c)

of

the

EU

AI

Act,

and

Article

4(3)

of

Directive

(EU)

2019/790

on

copyright

and

related

rights

in

the

Digital

Single

Market.
 •  Identifying  and  respecting  the  rightsholder's  reservations  of  rights.  •  Utilising  state-of-the-art  technologies  for  copyright  protection,  ensuring  that  the  model  weights
Bria

trains

are

trained

only

on

fully

licensed

training

data.

Where

a

Bria

model

incorporates

an

unmodified

third-party

open-weight

component

that

Bria

did

not

train,

that

component

is

identified

in

the

Public

Summary

of

Training

Content

for

the

model

concerned,

and

section

4.2

below

sets

out

the

controls

Bria

applies

to

such

components.
 •  Being  committed  to  advancing  AI  technology  while  adhering  to  principles  that  prioritise  societal
benefit

and

accountable

development.
 Our  approach  goes  beyond  mere  legal  compliance.  It  represents  an  intrinsic  commitment  to  integrity,
transparency,

and

responsible

innovation

in

our

AI

model

development

and

deployment

processes.

By  successfully  building  high-quality  models  through  sustainable  data  partnerships,  Bria  demonstrates
that

responsible

innovation

and

respect

for

intellectual

property

are

not

only

possible

but

also

 12
  commercially  viable.  This  evidence  is  crucial  for  policymakers,  regulators,  and  courts,  showing  there  is
no

need

to

choose

between

fostering

AI

progress

and

protecting

creators.

2.

Training

Data

Compliance

and

Verification

Licensed  Data  Use  Policy  Bria  exclusively  uses  commercially  licensed  training  data,  explicitly  authorised  for  generative  AI  model
training,

for

the

model

weights

it

trains.

We

maintain

comprehensive

documentation

and

records

of

all

of

our

licensing

agreements

and

the

authorisations

provided

to

us

by

our

data

partners.
  Data  Source  Verification  Our  data  licensing  process  includes:
•  Legal  verification  of  all  licensing  agreements  confirming  that:    Bria  has  entered  into  valid  and  enforceable  agreements  with  all  data  licensors  that  expressly
authorise

the

use

of

licensed

data

for

generative

AI

model

training

purposes
   Each  licensing  agreement  includes  comprehensive  warranties  and  representations  from  data
licensors

confirming

their

full

legal

right,

title,

and

authority

to

license

the

data

objects

and

grant

the

rights

necessary

for

AI

training

applications
 •  Maintenance  of  detailed  data  cataloguing  systems  •  Regular  audits  of  data  source  compliance

No  Web-Crawling  Policy  Bria  does  not  and  will  not  engage  in  web-crawling  activities,  and  does  not  use  publicly  accessible  online
content

as

training

data

for

the

model

weights

it

trains.

This

approach

substantially

reduces

the

copyright

risk

associated

with

unlicensed

training

content.
 Where  a  Bria  model  incorporates  an  unmodified  third-party  open-weight  component,  the  data  used  by
that

component's

provider

to

train

it

lies

outside

Bria's

licensing

programme

and

is

not

known

to

Bria.

Such

components

are

identified

in

the

Public

Summary

of

Training

Content

for

the

model

concerned,

together

with

any

summary

of

training

content

published

by

their

provider.
  Rights  Reservation  Compliance  While  our  business  model  does  not  involve  web-crawling,  we  acknowledge  and  respect  rightsholder
reservations

expressed

pursuant

to

Article

4(3)

of

Directive

(EU)

2019/790

and

maintain

systems

to

identify

and

comply

with

such

reservations,

if

applicable.

3.

Data

Partner

Compensation

and

Attribution

Framework

Fair  Compensation  We  compensate  partners  based  on  their  measured  contribution  to  generated  content,  providing  a
recurring

revenue

stream

to

data

partners.

Bria

rejects

one-time

licence

deals

for

AI

training

data,

instead

implementing

a

fair

and

transparent

system

of

ongoing

compensation

that

ensures

creators

receive

a

share

of

the

long-term

value

their

work

generates

in

existing

and

future

AI

applications.

Attribution  Technology
 13
  Our  patented  attribution  technology  enables  Bria  to  bridge  the  gap  between  demand  for  synthetic
content

and

supply

of

authentic

training

data.

Each

synthetic

output

generated

by

our

models

is

attributed

to

the

original

content

creators

that

had

the

greatest

impact

on

its

generation.

Transparency  Bria's  attribution  technology  offers  transparency  to  both  data  contributors  and  customers.
4.

Due

Diligence

for

Third-Party

Sources

and

Components

4.1

Content

obtained

through

third-party

data

providers
 Bria  maintains  comprehensive  due  diligence  procedures  for  any  content  obtained  through  third-party
providers.

We

require

all

third-party

data

providers

to:

•  Warrant  their  full  legal  right  and  authority  to  license  content  for  AI  training  purposes  •  Provide  comprehensive  warranties  that  all  data  licensed  is  original  and  human-created  content  •  Ensure  all  data  is  subject  to  legal  releases  covering  commercial  use  and  AI  training  applications
where

identifiable

persons

or

property

are

depicted
 •  Provide  representations  confirming  non-infringement  of  third-party  copyrights,  trademarks,  or
other

intellectual

property

rights
 •  Provide  warranties  that  content  does  not  feature  public  figures,  harmful  materials,  or  copyrighted
fictional

characters
 •  Present  all  applicable  compliance  certifications  regarding  adherence  to  all  applicable  copyright
laws

and

regulations
 •  Maintain  detailed  records  and  chain-of-title  documentation  •  Be  subject  to  periodic  compliance  audits  and  remediation  procedures
4.2  Third-party  model  components  Bria  distinguishes  between  third-party  data  sources,  addressed  above,  and  third-party  model
components

incorporated

into

a

Bria

model.
 Certain  Bria  models  incorporate  open-weight  components  developed  by  third  parties,  such  as  text
encoders

and

variational

autoencoders.

Where

Bria

does

so,

those

components

are

used

with

their

published

weights

held

frozen

and

are

not

modified

by

Bria.

They

are

made

available

by

their

providers

under

open-source

licences,

which

characteristically

disclaim

all

warranties.

The

due

diligence

framework

in

section

4.1,

which

depends

on

contractual

warranties

from

data

licensors,

cannot

therefore

be

applied

to

them.
 For  such  components  Bria  applies  the  following  controls  instead:  •  Use  is  restricted  to  components  released  under  licences  permitting  the  intended  commercial  use
and,

where

applicable,

redistribution.
 •  The  licence  of  each  component  is  reviewed  before  adoption,  and  the  applicable  notice,  attribution
and

licence-reproduction

conditions

are

complied

with

on

every

channel

through

which

Bria

redistributes

the

component.
 •  Components  are  used  without  modification.  Where  Bria  does  modify  a  component,  any  applicable
obligation

to

state

changes

is

complied

with.

 14
  •  Each  component  is  identified  in  the  Public  Summary  of  Training  Content  for  the  model  concerned,
together

with

any

summary

of

training

content

published

by

its

provider.
 •  Bria  makes  no  representation  as  to  the  provenance  of  the  data  used  by  third-party  providers  to
train

such

components,

and

its

representations

concerning

licensed

training

data

relate

to

the

model

weights

Bria

trains.
  4.3  Data  Procurement  and  Usage  In  addition,  Bria  maintains  the  following  processes  to  ensure  that  all  data  licensed  and  used  by  it  will  not
subsequently

create

harmful

implications

for

rightsholders

or

users:

Data  Quality  and  Diversity:  Bria  does  not  train  its  models  on  synthetic  data  generated  for  that  purpose,
whether

through

model

distillation,

alignment

against

another

model's

outputs,

or

otherwise.

Consistent

with

the

AI

Office's

instructions

on

the

Public

Summary

of

Training

Content,

this

is

distinct

from

the

use

of

AI

models

to

clean

or

enrich

data.

Bria

does

use

captions

generated

with

third-party

AI

models

to

enrich

its

licensed

image

data,

as

disclosed

in

the

Public

Summary

of

Training

Content

for

each

model.

Bria

does

not

acquire

data

that

will

not

lead

to

model

quality

improvement

and

would

only

dilute

the

attribution

to

existing

partners.

Dedicated  Storage  and  Access:  Training  data  for  generally  available  models  is  stored  in  dedicated
training

accounts.

Proprietary

data

provided

by

customers

for

training

private

models

is

segregated

from

general

models'

training

data

accounts.

Access

to

proprietary

data

provided

by

customers

for

training

private

models,

and

to

models

informed

by

customers'

proprietary

data,

is

restricted

to

such

customers

and

to

authorised

Bria

support

for

maintenance

functions

only,

under

a

rigorous

permissions

system.

Access

to

models

is

subject

to

periodic

penetration

tests.

Asset  Cataloguing:  An  automated  pipeline  records  each  asset  in  a  dedicated  catalogue,  maintaining  a
clear

link

to

its

origin.

5.

Output

Protection

and

Copyright

Compliance

Bria  implements  robust  technical  and  policy  measures  to  prevent  copyright-infringing  outputs  from  our
general-purpose

AI

models:

Technical  Safeguards  We  employ  state-of-the-art  technical  measures  to  prevent  our  models  from  reproducing  training
content

in

an

infringing

manner,

including:

•  Advanced  content  filtering  systems  •  Real-time  output  monitoring  •  Regular  testing  protocols  to  verify  safeguard  effectiveness  •  Detection  of  potential  copyright  violations  post-generation
Acceptable  Use  Requirements  Our  terms  and  conditions  explicitly  prohibit:
•  Using  models  to  generate  copyright-infringing  content  •  Circumventing  technical  safeguards
 15
  •  Using  our  models  to  create  any  unlawful  content
Documentation  Requirements  For  all  model  deployments,  we  provide  clear  copyright  and  acceptable-use  compliance  guidelines,
explicit

prohibition

of

infringing

uses,

and

technical

documentation

of

protective

measures.

Cross-Platform  Application  These  protective  measures  apply  consistently  across  direct  model  implementations,  on-premises
model

integrations,

API

access,

and

all

other

deployment

scenarios.

Monitoring  and  Enforcement  We  maintain  ongoing  oversight  through  regular  audits  of  model  outputs,  compliance  verification
procedures,

incident

response

protocols,

and

continuous

improvement

of

safeguards.

6.

Rightsholder

Contact

and

Complaint

System

We  maintain  accessible  communication  channels  and  procedures  for  rightsholders,  through  an  email
message

to

legal@bria.ai,

to

submit

precise

and

substantiated

complaints

regarding

non-compliance

with

copyright

commitments,

potential

infringement

concerns,

rights

reservation

violations,

and

any

other

copyright-related

matters.

This  reporting  mechanism  complements  but  does  not  replace  or  limit  any  legal  remedies  available
under

Union

and

national

copyright

law.

7.

Other

Protective

Measures

Beyond  our  copyright  compliance  framework,  Bria  maintains  additional  protective  measures  for  the
benefit

of

both

our

data

licensors

and

end

users.

Privacy  and  Data  Protection  •  We  place  strong  emphasis  on  privacy  protection  for  individuals.  We  use  human  likenesses  only  with
explicit

releases

for

commercial

use.

We

strictly

prohibit

the

use

of

public

figures'

data

in

our

models.
 •  We  implement  robust  data  protection  measures  to  safeguard  personal  information  and  comply  with
relevant

privacy

and

data

protection

regulations.

Identity  Protection  and  Training  Architecture  No  Identity  Mapping:  Bria's  training  datasets  are  anonymised  through  the  removal  of  naming  and
identifying

metadata.

Our

models

are

designed

to

prevent

any

mechanism

for

linking

visual

likenesses

to

real

person

identities.

Balanced,  Multi-Source  Training  Catalogue:  We  maintain  a  wide-ranging,  globally  sourced  dataset  that
deliberately

balances

input

across

creators,

contexts,

content

types,

and

personalities.

This

diversity

reduces

the

prominence

of

any

single

source

and

minimises

the

potential

for

overrepresentation

or

unintended

memorisation.

Architecture  Design:  Bria's  models  are  architected  to  learn  general  visual  patterns  rather  than  memorise
or

reproduce

specific

individuals.

Our

technical

architecture

and

sampling

methodology

discourage

identity

persistence

or

overfitting

to

any

single

visual

subject.

 16
  Commitment  to  Diversity,  Inclusion,  and  Bias  Mitigation  •  We  actively  seek  and  incorporate  diverse  datasets  representing  a  wide  range  of  cultures,
ethnicities,

ages,

genders,

and

geographical

locations.
 •  Our  development  process  includes  testing  and  refinement  to  identify  and  mitigate  potential  biases
in

our

AI

models.
 •  We  implement  content  moderation  filters  to  prevent  the  generation  of  harmful  or  biased  content.  •  We  consult  with  diverse  stakeholder  groups,  including  underrepresented  communities,  and
incorporate

their

feedback

into

our

AI

development

and

deployment

processes.
 •  Our  AI  models  are  designed  with  cultural  sensitivity  in  mind.  •  We  publish  reports  on  our  diversity  and  inclusion  initiatives,  including  the  composition  of  our
datasets

and

the

results

of

our

bias

mitigation

efforts.

Safety,  Provenance,  and  Mitigation  of  Harmful  Content  Bria  applies  C2PA  Content  Credentials  to  content  generated  by  its  models  and  holds  a  root  on  the  C2PA
trust

list.

Content

Credentials

are

cryptographically

signed

provenance

metadata

bound

to

the

generated

file,

allowing

recipients

to

verify

that

the

content

was

produced

by

a

Bria

model.

Provenance

metadata

of

this

kind

can

be

removed

or

lost

where

a

file

is

subsequently

re-encoded,

converted,

or

stripped

of

metadata

by

downstream

tools

that

do

not

preserve

it.

Bria

is

developing

additional

marking

techniques

intended

to

improve

the

durability

of

provenance

signals

across

such

transformations.
 •  We  enforce  strict  guidelines  against  generating  harmful  or  offensive  content.  •  We  implement  measures  to  prevent  misuse  of  our  platform.  We  do  not  accept  data  that  features
public

figures

or

harmful

content,

which

makes

it

impractical

to

use

our

models

to

generate

these

concepts.

Conclusion

This  Copyright  Policy  establishes  Bria's  framework  for  responsible  AI  development  through  five  core
pillars:

1.  Exclusive  use  of  commercially  licensed  training  data,  with  verified  legal  authorisation,  for  the
model

weights

Bria

trains,

and

disclosure

of

any

third-party

model

components

incorporated

into

a

Bria

model.
 2.  Proprietary  attribution  technology  that  provides  ongoing  compensation  to  data  licensors  based
on

measured

contribution

impact.
 3.  Robust  technical  safeguards  preventing  copyright-infringing  outputs.  4.  Rigorous  due  diligence  procedures  for  third-party  data  sources,  and  defined  controls  for
third-party

model

components.
 5.  Accessible  rightsholder  communication  channels  for  compliance  concerns.  Our  approach  encompasses  additional  protective  measures  including  privacy  protection,  diversity  and
inclusion

initiatives,

bias

mitigation

protocols,

and

safety

measures

against

harmful

content

generation.

Through  our  data  partner  empowerment  and  collaboration  framework,  we  maintain  long-term
partnerships

that

create

mutual

value

while

advancing

responsible

AI

innovation.

Many

of

our

data

licensors

leverage

our

models

to

offer

their

creator

communities

and

customers

advanced

generative

AI

capabilities

under

preferred

commercial

arrangements.

We

view

our

data

licensors

as

integral

to

our

sustainable

AI

development

approach.

 17

Contact

Information

Bria  Artificial  Intelligence  Ltd.
Email:  legal@bria.ai
Website:

https://bria.ai/security-and-compliance

 18