Intercom (Fin) and Article 50: the AI notice to show

Intercom sells conversational support, often with Fin or other bots. A first name, an avatar and fluent replies do not make the AI “obvious” under Article 50(1). If a visitor might think they are talking to a person, an explicit notice is due at the first interaction.

Putting it only in Intercom Help or at the bottom of the site terms is too late and too easy to miss. A line next to Messenger (“You are chatting with an automated assistant”) is the useful minimum, in the visitor’s language.

Intercom can document its own models. That is not your site register or display log: you are the deployer toward the French and EU public.

Clairia recognises the Intercom script on the homepage, looks for a visible notice, and can attach its own to the widget. Help with compliance, not an Intercom certification.