EU AI Act Compliance Notice
This notice describes how Alchemy Data SRL complies with Regulation (EU) 2024/1689 — the EU Artificial Intelligence Act — in connection with our Platform.
1. Overview of AI Use
- AI-generated educational content: LLMs (Anthropic Claude via AWS Bedrock) generate explanations, examples, quizzes, and learning materials.
- Learning recommendations: AI suggests a sequence of skills and up to three practical workflows based on the role you enter. You are free to follow them or not. When your organisation turns on adaptive learning, the order of steps inside a module follows fixed rules applied to your answers — no AI model is involved in that.
We do not use AI for: decisions affecting legal rights, biometric identification, emotion recognition, social scoring, or manipulation of behaviour.
2. Risk Classification
AI-generated content: Limited risk — subject to transparency obligations under Article 50.
Learning path recommendation: Assessed as limited risk because it does not determine or restrict access, does not produce formal assessments, and recommendations are advisory only.
3. Transparency Obligations (Article 50)
- AI-generated lesson content is labelled “AI-generated” in the lesson.
- We do not generate synthetic media of real persons.
4. Prohibited Practices (Article 5)
We confirm our AI systems do not engage in: subliminal manipulation, exploitation of vulnerabilities, social scoring, real-time biometric identification, emotion recognition in sensitive contexts, facial image scraping, or political opinion manipulation.
5. Human Oversight
- AI recommendations can be overridden by you at any time.
- Course content — the lesson structure and every translation of it — is reviewed and approved by our team before it is published. Lessons generated for you are not reviewed one by one: if something looks wrong, use “Report a problem” in the lesson. Only the Ailumo team sees these reports, not your employer, and we review each one.
- You can flag inaccurate or harmful content.
- No binding AI decisions without human review.
6. Data Governance
- Your data is not used to train Anthropic models (enforced contractually with AWS).
- Only minimum necessary data is transmitted to AWS Bedrock.
- AI-generated lesson content is deleted automatically 90 days after it was generated. Your answers to exercises are part of your learning record and are kept as described in our Privacy Policy, §8.
7. Third-Party AI Provider
AI is powered by Anthropic Claude via AWS Bedrock. AWS acts as a data processor under our DPA. Customer data is not used to train base models.
8. Your Rights
- Right to explanation: AI is used in Ailumo for these purposes only: (1) generating lesson content (explanations, examples and exercises), personalised to your role, experience and organisation unless you opt out; (2) coaching — when you answer an exercise incorrectly, AI explains why and may ask a follow-up question, and it scores prompts you write in prompt exercises; (3) recommending up to three workflows that match your role; and (4) suggesting a sequence of skills based on your role. AI does not decide your organisation's access or what your administrator can see. Adaptive step ordering, when your organisation turns it on, uses fixed rules on your answers, not AI. To ask how any of these applied to you, contact us (§11).
- Right to human review: Request review of AI recommendations.
- Right to opt out of personalisation: In your profile you can turn on “Use generic (non-personalised) content”. New AI-generated lessons are then created without your role, your experience level or your organisation's context, and lessons you were shown before are not reused. This turns off personalisation, not AI: lessons are still generated by AI and stay labelled. Workflow recommendations and your suggested skill sequence still use the role you entered. You can turn the setting off again at any time.
9. Children and Vulnerable Users
The Platform is not intended for users under 18. Our AI includes no profiling directed at minors.
10. Updates
We will update this notice as the EU AI Act comes into full application and as guidance develops.
11. Contact
Alchemy Data SRL
Str. Judetului Nr. 1, Bl. 1, Ap. 806, Sector 2, Bucharest, Romania
Email: privacy@alchemygroup.net