AI Transparency Notice

Campley Holdings Ltd (United Kingdom) · Contact: legal@pitchnoir.agency · Last updated: 11 August 2026

The short version. Almost everything you see and hear in PitchNoir is generated by artificial intelligence. Marlowe Frost is not a real person — she is a synthetic character, and her face and voice were created with AI. No real person is depicted, and nothing in the game is a recording of a real event. The whole thing is fiction, and it is machine-made fiction.

This notice explains where AI is used, what is synthetic, and how we label it. It is written to meet the transparency obligations in Article 50 of Regulation (EU) 2024/1689 (the EU AI Act), which applies from 2 August 2026, and to be straight with you regardless of where you live.

1. You are interacting with an AI system

PitchNoir's characters — Marlowe Frost, the clients, your staff — are software. When Marlowe interviews you, judges your pitch or refuses your funding, no human is on the other side. Her questions, her reactions and her verdict are produced by a rules engine and generative models, not by a person watching you play.

We tell you this before the interview starts, not only here. If you ever cannot tell whether something in PitchNoir is a person or a machine, assume it is a machine — it is.

2. What is AI-generated

What	How it is made
Marlowe Frost — face, performance, voice	Synthetic. Generated with Higgsfield image and video models from a fictional reference, not from footage of a real person.
Other characters — candidates, staff, clients	Synthetic portraits and clips, generated the same way. Names, biographies and personalities are invented.
Environments and film — offices, pitch rooms, the world	AI-generated stills and video, some composited or edited by us afterwards.
Music and sound	AI-generated (Lyria and similar models).
In-game text — briefs, client feedback, events, verdicts	A mix of hand-written copy and text assembled or generated by models.
Game logic — scores, cheques, outcomes	Conventional deterministic code. Not a model, and not a prediction about you.

3. How synthetic media is marked

Article 50(2) asks that synthetic output be marked in a machine-readable way, and 50(4) that content resembling real people, places or events be disclosed. We do both:

In the file. Every AI-generated video and audio file we ship carries metadata recording that it is artificially generated, what produced it, and that it depicts no real person.
In a public manifest. /ai-content-manifest.json lists every synthetic asset in the build, machine-readable, so anyone — a researcher, a platform, a regulator — can check without playing the game.
On screen. The game says so before Marlowe's interview begins, and this notice is linked from the footer of every page and from the sign-up form.

Metadata can be stripped when files are re-uploaded elsewhere. If you see PitchNoir footage outside pitchnoir.agency without a label, it is still synthetic.

4. What we do not do

Stated plainly, because these are the practices the AI Act cares most about and it should be easy to confirm we are not doing them:

No emotion recognition. Marlowe's face reacts to the answer you clicked, and the confidence meter is scored from your choices. We do not read your face, your voice or your typing to infer how you feel. We never access your camera or microphone.
No biometric categorisation or identification. We do not process biometric data at all.
No real person is depicted. No character is based on, trained on, or intended to resemble a specific real individual, living or dead. If you believe a character resembles you or someone you know, write to us and we will look at it.
No AI decisions about you as a person. Nothing in the game profiles you, scores you as an individual outside the fiction, or feeds any decision with legal or similar effect.
Your data does not train models. What you write and do in PitchNoir is used to run the game, not to train generative models — ours or anyone else's. See the Privacy Policy.

5. Satire, and why the fiction is obvious

PitchNoir is a satire of the advertising industry. Its clients, brands and awards are invented. Where a fictional brand resembles a real one, it is parody, not a claim about that company. The creative work "your agency" produces in the game is generated on the spot and is not a real campaign by any real advertiser.

6. Which models we use

We use third-party generative models to produce assets before release — principally Higgsfield (image and video), Google Gemini and Lyria (text and music). Assets are generated during production and shipped as ordinary media files. This list changes as tools change; the manifest in §3 is always the current record of what is in the build.

7. Your rights and how to complain

You can ask us what is synthetic in any part of the game, ask us to remove a character you believe depicts a real person, or complain about how AI is used here. Write to legal@pitchnoir.agency and we will answer within 30 days.

If you are in the EU you may also complain to your national market surveillance authority for AI; if you are in the UK, to the ICO for data-protection matters.

8. Changes

We will update this notice whenever what we generate, or how we label it, changes materially — and we will move the "last updated" date at the top when we do.