AI Transparency & Compliance
Formal disclosure regarding the deployment, risk classification, and data governance of Artificial Intelligence systems across Divamea Academy, pursuant to the EU AI Act (Regulation (EU) 2024/1689) and GDPR (Regulation (EU) 2016/679).
Transparency First
Clear and conspicuous disclosure whenever users interact with or consume AI-generated content (Art. 50 EU AI Act).
Human-in-the-Loop
All AI-generated assessments and educational materials must be reviewed and approved by human faculty members.
Data Privacy (GDPR)
User prompts and proprietary course materials are never used to train public foundation models. Strict isolation by tenant.
EU AI Act Risk Classification & Demarcation
Under Regulation (EU) 2024/1689 (EU AI Act), artificial intelligence systems are categorized into four risk tiers: Prohibited Practices (Art. 5), High Risk (Art. 6 & Annex III), Specific Transparency Risk (Art. 50), and Minimal/No Risk.
- No Prohibited Practices (Article 5): The Platform does not deploy subliminal manipulation, social scoring, biometric categorization of protected traits, or predictive policing.
- Non-High-Risk Demarcation (Annex III, point 3): Point 3 of Annex III covers AI used in educational and vocational training. To ensure our tools remain purely advisory authoring and tutoring tools and do not trigger High-Risk designation:
- The AI Tutor serves exclusively as a study companion answering queries grounded in approved course text.
- The AI Quiz Generator assists instructors in drafting questions, but final publication and grading rules require mandatory human validation (Human-in-the-Loop).
- No fully autonomous AI algorithm awards final course certifications or professional accreditations.
- Transparency Obligations (Article 50): The Platform adheres strictly to transparency requirements: notifying users of AI interaction (Art. 50(1)) and marking synthetic materials with machine-readable headers and metadata (Art. 50(2)).
Inventory of AI Engines & Functions
Divamea Content Generator
Drafts lesson outlines, slide decks, and summaries from instructor-provided notes or documents. Output is marked as AI-assisted and requires instructor review before publication.
Divamea Quiz Generator (Vision AI)
Generates multiple-choice questions, plausible distractors, and educational explanations from lesson material and de-identified clinical diagrams.
Divamea Translator
Real-time multi-language translation engine preserving specialized aesthetic medicine terminology across course materials.
Divamea Tutor (Conversational Agent)
Course-scoped conversational agent retrieving information via semantic vector search strictly from authorized lesson content.
Data Protection, Sub-Processors & GDPR Compliance
In accordance with Articles 13, 14, and 28 of the GDPR, DISINDEX S.R.L. provides full disclosure on third-party cloud infrastructure involved in AI processing:
| Sub-Processor | Role & Feature | Location / Transfer Safeguards | Training on Customer Data |
|---|---|---|---|
| Google Cloud / Google Generative AI | LLM inference, Vision analysis & text generation | EU / US (EU-U.S. Data Privacy Framework & SCCs) | NO (Zero-retention training policy) |
| Pinecone Inc. | Vector database for tenant-isolated semantic search | AWS / GCP EU Regions (SCCs) | NO (Index storage only) |
Under no circumstances may users or instructors submit un-anonymized medical records, patient names, or identifiable clinical photographs (e.g., recognizable facial portraits) into any AI tool. All images uploaded for quiz analysis must be strictly de-identified.
Human Oversight, Inquiries & Rights
In line with the right to human intervention and contestability under the EU AI Act and GDPR:
- Students who believe an AI response is inaccurate or confusing may report the content directly to the course instructor or via the feedback controls in the learning player.
- To exercise your data subject rights (access, rectification, erasure, restriction of processing) regarding AI-processed queries, contact the Data Protection team at divamea@disindex.com.
- For complete general terms and conditions, consult our Terms of Service.