Artificial Intelligence Use Policy

1. Overview

• At Intellum, we embrace 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 Policy outlines how and where AI is used in our learning management and customer education products and services (“Services”), the safeguards we apply, and how we ensure compliance with applicable legal requirements.

2. Purpose

• This Policy is intended to: (i) inform 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 use AI technologies to augment, but not replace, human decision-making across specific features of our Services. Current AI-enhanced use cases include: (i) content enhancement and summarization to assist in creating and refining educational content; (ii) personalization support for learners (e.g., content recommendations); (iii) customer support automation, such as chatbot interactions; (iv) software code review and enhanced system monitoring; and (v) various internal productivity and efficiency tools.

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.

5. Data Security and Privacy

• 5.1 Third Party Models. Where Intellum’s AI features invoke external third-party AI models, processing is performed securely and in accordance with Intellum’s Data Processing Agreement, Privacy Policy, applicable laws, and key safeguards including: (i) customer data is excluded from third-party model training and enhancement;  (ii) only the minimum necessary prompts or metadata are sent to enable the AI feature; and (iii) external AI outputs are assistive and 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 these internal models process customer data for feature functionality, processing is performed in accordance with Intellum’s Data Processing Agreement (DPA), Privacy Policy and applicable laws. Internal AI outputs are assistive and subject to human oversight and review.
• 5.3 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.  AI-enabled features are designated in-product and subject to opt-in or opt-out preferences where applicable.

6. Customer Responsibilities

• 6.1 Customers 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.
• 6.2 Users of Intellum’s AI features are solely responsible for applying human oversight 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 outputs as-is without appropriate human review; (iii)  use Intellum’s Services, including AI-generated content, 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 content for any purpose. Users are advised to independently verify all AI-generated outputs before publication or reliance.

8. Compliance with the EU Artificial Intelligence Act

• 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 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.

10. Questions

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