Artificial Intelligence Use Policy

1. Overview

• Intellum, Inc. (“Intellum” or “us” or “we” or “our”) embraces and is committed to the responsible use of artificial intelligence (AI) to enhance the functionality of our Services, improve customer experience, and continue to deliver innovative educational solutions. This Artificial Intelligence Use Policy (“Policy”) outlines how and where AI is used in our business and in our learning management and customer education products and services (“Services”), the safeguards we apply, and how we ensure our compliance with applicable legal requirements.
  
  This Policy supplements our Privacy Policy (https://www.intellum.com/privacy-policy) and Platform Terms of Service (https://www.intellum.com/terms-of-service). Capitalized terms not defined here have the meanings given in those documents. If there is any conflict between this Policy and our Privacy Policy, this Policy governs with respect to AI-related data processing.

2. Purpose

• This Policy is intended to: (i) inform and describe to our customers about how AI is integrated into Intellum’s Services; (ii) identify the types of data AI may process; (iii) provide transparency regarding third-party AI service providers; and (iv) inform customers of our security, privacy and human oversight practices.

3. Intellum’s Use of AI

• We incorporate AI technologies into our Services to augment, but not replace, human decision-making across specific features of our Services and to enhance your productivity, improve the quality of your content, and deliver AI enabled features. We currently utilize  AI-enhanced functionality to: (i) enhance, summarize, create, and refine educational content; (ii) make context recommendations and provide personalization support for learners; (iii) process, record, store, analyze, and evaluate video, audio, image, and related data and information from our customers and their users and other individuals who interact with the Services; (iv) provide automated customer support, such as chatbot interactions; (v) review software code and to monitor our systems for violations of our policies and terms, including security threats and misuse; and (vi) increase and enhance internal productivity and efficiency.  Your data is not shared or comingled information from our other customers, and your data is not shared with or transmitted to any third-party AI provider (unless you provide express written consent). We may introduce additional AI features over time. When we do, we will update this Policy and, where required by applicable law, provide advance notice to our customers.

4. Intellum’s Commitment to Responsible Use

• Intellum adheres to the following responsible AI principles:
  
  ‍Transparency – Clear communication of AI usage and purpose.
  
  ‍Accountability – Human-in-the-loop governance for AI features prior to release. Human oversight is embedded in Intellum’s design, development and testing of AI features.
  
  ‍Security & Privacy – Strong safeguards to protect customer data.
  
  ‍Non-discrimination – Regular testing and tuning to avoid bias or unfair outcomes.
  
  Logging & Auditing – AI interactions are securely logged and subject to periodic audit by Intellum’s AI team to ensure adherence to these principles.
  
  ‍Testing & Monitoring - Adherence to a testing and monitoring framework for our AI features, including bias and fairness assessments, response-quality scoring, and regular performance reviews to detect and correct any anomalies or drift.
  
  ‍Review & Approval – Internal IT and security review and approval is required for all new AI solutions to be utilized by Intellum; security and AI diligence for new vendors; and regular and periodic security and AI reviews and assessments of existing vendors.
  
  ‍Training – Regular and periodic AI and security related training for our employees to ensure awareness of and adherence to best practices and regulatory requirements.

5. Data Security and Privacy

• 5.1 Third Party Models. Where Intellum’s AI features involve the use of or otherwise integrate with external third-party AI models, processing of your data and information is performed securely and in accordance with Intellum’s Data Processing Agreement and Privacy Policy. With respect to any third-party AI models utilized by Intellum: (i) the third-party service provider is prohibited from using customer data to train or enhance its model;  (ii) Intellum will utilize only the minimum necessary prompts or metadata to enable the AI feature; and (iii) AI outputs from third-party models are intended to be assistive and are subject to human oversight and review.
• 5.2 Intellum Hosted Models. Intellum may utilize internally developed, hosted and trained AI models to power certain features within Intellum’s Services. Where internal Intellum AI models process customer data to enable feature functionality, processing of your data and information is performed in accordance with Intellum’s Data Processing Agreement (DPA) and Privacy Policy. AI outputs from internal Intellum AI models are intended to be assistive and are subject to human oversight and review.
• 5.3 Intellum Internal Productivity Tools. Intellum may utilize company managed accounts for publicly available AI solutions and platforms (e.g., Google Gemini, ChatGPT, Claude, Co-Pilot) to enhance general productivity, internal communications and content drafting, and internal analysis. Each vendor for such internal AI solutions and platforms is subject to initial security and IT diligence and periodic security and IT reviews by Intellum. Intellum will not use an internal AI solution if the solution trains on input data without a contractual opt-out right or if the solution does not have a clear Data Processing Agreement that restricts use of input and output data. Intellum prohibits its employees from utilizing personal AI accounts with customer or Intellum information, and Intellum monitors for such use on a periodic basis.
• 5.4 Common Controls. All AI interactions are logged and monitored for quality, safety and compliance purposes. Inputs and outputs are limited to what is necessary for the feature functionality and retained per Intellum’s standard data retention practices and applicable legal obligations.   Third party AI technology providers that will have access to personal data of customer or its users will be listed as a sub-processor in Intellum’s Privacy Policy.

6. Customer Responsibilities

• 6.1 Customers currently maintain control over whether AI features are used in their instance of the Intellum Services.  AI functionality is currently: (i) enabled only for select modules within the Services; (ii) clearly designated when in use; and (iii) subject to opt-in/opt-out preferences, where applicable. With respect to functionality subject  to opt-in/opt-out preferences, it is the customer’s sole responsibility to manage and control its preferences.  In the future, Intellum may enable AI functionality in a module, the platform, the solutions, and/or the Services that is not subject to opt-in/opt-out preferences. In such case, Intellum will provide reasonable advance notice (including via email) that such functionality will be enabled and Intellum will continue to clearly designate when an AI functionality is in use. It is the customer’s sole responsibility to provide all appropriate notices to and obtain all necessary consents from its users in connection with the use or enablement or any AI functionality.
• 6.2 Users of Intellum’s AI features are solely responsible for applying human oversight and complying with laws applicable to their use of AI-generated outputs. This includes ensuring that such outputs are reviewed, validated and deemed accurate, lawful and appropriate for their intended use. AI features are provided to augment, not replace user judgment.
• 6.3 Users must not: (i) use AI features to generate content that infringes third-party intellectual property rights; (ii) use or rely on AI-generated outputs as-is without appropriate human review; (iii)  use Intellum’s Services, including AI-generated outputs, to train or improve any other AI models or systems; and (iv) scrape, mine, or otherwise extract content or metadata from Intellum’s Services for AI training or analysis purposes.

7. AI Output Limitations

• Intellum does not guarantee the uniqueness, accuracy, or fitness of any AI-generated outputs for any purpose. Users are advised to independently verify all AI-generated outputs before publication or reliance.

8. Compliance with the Applicable Laws

• Intellum’s AI features may not be used by customers for any uses prohibited under any applicable law, including laws regarding use of automated decision making technology (ADMT) in high risk areas of use, including employment and workforce decisions. Additionally, Intellum’s AI features may not be used by customers for any high risk or prohibited practices under Article 5 of the EU Artificial Intelligence Act (Act), including but not limited to: (i) social scoring of natural persons; (ii) emotion recognition in workplaces or educational institutions; (iii) biometric categorization based on sensitive attributes; and (iv) untargeted scraping of facial images to build or expand face databases. These uses are strictly prohibited by the Act.  

9. Policy Updates

• Intellum may update this Policy from time to time, including as our AI use evolves within our Services. Material changes will be communicated via our legal page on our website or directly to affected customers in line with our legal and contractual obligations. Your continued use of the Services after any changes become effective constitutes acceptance of the updated Policy.

10. Questions

• If you have questions about this Policy or Intellum’s AI-related practices, please reach out to us at support@intellum.com.