Brazil AI Framework Statement

This Statement sets out the position of Prodia Systems Ltd ("Prodia") in relation to Brazil's emerging legal framework for artificial intelligence, including Federal Bill PL 2338/2023 (Marco Legal da Inteligência Artificial) and related sectoral guidance, together with the Lei Geral de Proteção de Dados Pessoais (Law No. 13.709/2018, "LGPD").

1. Risk-Based Approach

Prodia aligns the prodia.dev Service with the risk-based logic foreseen in the Brazilian framework, including the distinction between excessive-risk and high-risk AI systems. In its standard configuration, the Service is not provided as an excessive-risk or high-risk AI system within the meaning of those proposals.

2. Governance & Documentation

• Risk-management process, technical documentation and post-market monitoring.
• Logging of agent actions and decisions, with replay and rollback capability.
• Human-oversight design enabling natural persons to supervise and intervene.
• Algorithmic impact assessment capability for customers acting as deployers of high-risk systems.

3. LGPD Compliance

Personal data of data subjects in Brazil is processed in accordance with the LGPD. Customers act as controllers and Prodia as operator (operador) within the meaning of Article 5 LGPD. Cross-border transfers are made on lawful bases under Article 33 LGPD.

4. Foundation Models

Where the Service incorporates generative or foundation models supplied by third parties, Prodia selects providers that publish information sufficient to meet applicable Brazilian transparency expectations.

5. Customer Responsibilities

Customers are responsible for determining whether their specific use case falls within an excessive-risk or high-risk category under Brazilian law and for implementing the corresponding deployer obligations.

6. Contact

Brazil AI enquiries may be sent to legal@prodia.dev.