EU AI Act Statement

This Statement sets out the position of Prodia Systems Ltd ("Prodia") under Regulation (EU) 2024/1689 of the European Parliament and of the Council laying down harmonised rules on artificial intelligence (the "EU AI Act"). It is governed by the laws of Ireland and the law of the European Union and supplements our AI Transparency & Governance Statement.

1. Role under the EU AI Act

Prodia acts as a "provider" of the prodia.dev Service within the meaning of Article 3(3) of the EU AI Act. The Service is a general-purpose AI-enabled software-engineering platform and, in its standard configuration, is not placed on the Union market as a high-risk AI system within the meaning of Article 6 and Annex III.

Customers act as "deployers" within the meaning of Article 3(4). Where a customer configures or integrates the Service in a manner that brings their use within the scope of a high-risk AI system, the customer is responsible for the corresponding deployer obligations under the EU AI Act.

2. Prohibited Practices (Article 5)

The Service must not be used to develop, deploy or operate any AI practice prohibited under Article 5 of the EU AI Act, including but not limited to social scoring by public authorities, untargeted scraping of facial images, emotion recognition in workplaces and educational institutions (subject to the exceptions in the Act), and exploitative manipulation of vulnerable persons. Any such use is a material breach of the Terms of Service.

3. Transparency Obligations (Article 50)

• Users are clearly informed that they interact with an AI system.
• Output generated or substantially modified by the Service is identifiable as artificially generated.
• Customers using the Service to produce content for the public are responsible for any further labelling or disclosure obligations applicable to them.

4. General-Purpose AI Models

Where the Service incorporates general-purpose AI models supplied by third parties within the meaning of Article 51, Prodia selects providers that publish the information required under Article 53 and, where applicable, comply with the obligations for general-purpose AI models with systemic risk under Article 55.

5. Risk-Management, Logging and Documentation

Prodia maintains a risk-management process, technical documentation, automatic logging and post-market monitoring aligned with the structure of Articles 9, 11, 12 and 72 of the EU AI Act, scaled to the actual risk profile of the Service. Customers may request a summary of relevant documentation under the confidentiality terms of the Terms of Service.

6. Human Oversight

The Service is designed so that natural persons can effectively oversee its operation, in line with Article 14. Customers control oversight levels, approval gates and execution scopes, and can suspend or roll back agent actions.

7. Cooperation with Authorities

Prodia will cooperate, in good faith and within the limits of applicable law, with the European AI Office, national competent authorities and market-surveillance authorities, including by providing documentation and information lawfully requested under Articles 21 and 74.

8. Customer Responsibilities

• Determining whether their specific use case falls within the scope of a high-risk AI system under Annex III.
• Implementing deployer obligations under Article 26, including human-oversight measures, monitoring and record-keeping.
• Conducting a fundamental rights impact assessment under Article 27 where applicable.
• Ensuring lawful processing of personal data under Regulation (EU) 2016/679 ("GDPR") and the Irish Data Protection Act 2018.

9. Contact

EU AI Act enquiries may be sent to legal@prodia.dev.