Governance & AI Policy

AI-Assisted, Not Outsourced

Our research and programming are heavily dependent on AI — but we do not outsource programming services. Everything we ship is curated, directed and integrated by our own engineers.

We maintain high ethical standards: our games and tools are based on our own storytelling and system design, and we are committed to not knowingly infringing copyright laws.

Models We Use

We use a wide range of third-party AI models, including ChatGPT, DeepSeek, Claude and Grok, strictly in compliance with their respective terms of service.

These systems accelerate iteration, but they never replace human judgment, accountability or authorship.

Substantial Part, Not Vibes

Under the UK Copyright, Designs and Patents Act 1988 (CDPA), section 16, infringement occurs only where a person, without permission, reproduces the whole or a substantial part of a copyright work. The assessment is qualitative: it focuses on the importance of the copied expression, not just the quantity.

Mere resemblance in style, general ideas or overall “vibe” is not protected by copyright and does not amount to infringement. Independent creation is a full defence.

Case Law Guidance

UK case law, including Designers Guild Ltd v Russell Williams (Textiles) Ltd [2000] UKHL 58, confirms that a work infringes only if the claimant demonstrates reproduction of a substantial part of the original expression; similarity in style, theme, or unprotectable elements alone is irrelevant.

The burden of proof lies on the accuser.

Human + Computer Authorship

Where human input — detailed prompts, selection, editing and refinement — contributes to our AI-assisted works, those works qualify as original under CDPA s.9(1), with authorship and protection vesting in Ghost Citadel as the employer (s.9(2)).

For elements that are purely computer-generated, CDPA s.9(3) deems us the author as the persons by whom the necessary arrangements were undertaken, subject to the work meeting the originality threshold — an area of ongoing legal debate. Anyone who challenges that must prove otherwise.

We Publish Our Own Assets

We publish only our own games and assets. We do not operate as a neutral hosting provider for third-party content.

Because of this, the liability-limitation rules for hosting services in the Electronic Commerce (EC Directive) Regulations 2002, regulation 19, and their associated notice-and-takedown duties, do not apply to us in the same way they apply to platforms.

Independent Creation by Default

Our default position is that our works are independently created by a combination of human designers and AI tools. Similarity alone does not imply copying, and any allegation of infringement must be supported by evidence that a substantial part of protected expression was actually reproduced.

Talk to Us First

We are fully willing to discuss concerns and reach reasonable understandings. If you believe any asset in a Ghost Citadel product infringes your rights, please contact us at [email protected] with enough detail for us to investigate.

Bad-Faith Notices

However, where any submitted takedown or infringement notice is later shown to be unfounded or submitted in bad faith, we reserve the right to seek full compensation for all losses and costs in the Intellectual Property Enterprise Court.

This may include remedies under CDPA 1988 §§ 96–97 (damages, injunctions and other measures) and cost orders under Civil Procedure Rules Part 44, including indemnity costs in cases of unreasonable or abusive conduct.