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    AI GOVERNANCE

    AI Policy

    How NeuronPathway uses artificial intelligence, what data is processed, and your rights under the EU AI Act and applicable data protection law.

    v1.2 — Effective: April 14, 2026
    EU AI Act Art. 18 — Transparency to UsersEU AI Act Art. 22 — Automated Decision RightsEU AI Act Art. 50 — AI-Generated Content LabellingGDPR Art. 22 — Human OversightUK AI Principles
    All AI features are powered by Claude by Anthropic — training plans, nutrition, form analysis, AI Coach, and support triage
    EU AI Act Art. 18: full transparency on which AI features run, what data they use, and what model powers them
    EU AI Act Art. 22: you can request human review of any AI decision, opt out of AI coaching, and always see whether content is AI-generated or human-authored
    All AI-generated content carries a visible AI label in the interface (EU AI Act Art. 50)
    Your fitness data is never used to train AI models — governed by our Data Processing Agreement with Anthropic
    1

    Overview

    NeuronPathway is an AI-powered fitness and health platform. We use large language models (LLMs) and generative AI to provide personalised training programmes, meal plans, and coaching conversations to personal trainers, athletes, and their clients.

    We are committed to the responsible and transparent use of AI. This policy sets out the AI systems we operate, how they interact with your data, and the safeguards we have in place to ensure AI outputs are clearly identified and that human oversight is always available.

    NeuronPathway's AI is classified as a limited-risk system under the EU AI Act, providing general fitness and wellness recommendations. AI is never used for medical diagnosis, treatment, clinical decision-making, or any decisions that produce legal or similarly significant effects. All AI outputs are advisory and subject to human review.

    2

    What AI Does on NeuronPathway

    Training Plan Generation

    AI analyses your fitness goals, experience level, available equipment, injuries, and weekly schedule to generate a structured training programme. Plans are generated by Claude by Anthropic and orchestrated by Claude agents.

    Meal Plan Generation

    AI generates personalised meal plans based on your calorie targets, macronutrient goals, dietary restrictions, and training load. Plans are designed to support your fitness objectives and are not clinical dietary prescriptions.

    AI Coach Chat

    The AI Coach is a conversational assistant that can answer fitness and nutrition questions, provide motivation, and help you understand your training data. It is clearly labelled as AI-powered in the chat interface. It does not provide medical diagnoses or clinical advice.

    Progress Insights

    AI analyses your check-in data, compliance scores, and performance trends to surface insights for you and your personal trainer. These are analytical summaries and not clinical assessments.

    3

    Autonomous AI Agents (EU AI Act Art. 50)

    NeuronPathway operates a fleet of autonomous AI agents that monitor, optimise, and coordinate platform operations. These agents are internal systems that do not interact directly with end users — they assist platform administrators in maintaining service quality.

    CTO Orchestrator (Managed Agent)

    Our primary operational agent is the CTO Orchestrator, implemented as a Claude Managed Agent via the Anthropic API. It runs weekly to assess platform health across seven pillars: cost intelligence, revenue, platform health, content, user acquisition, agent fleet management, and compliance.

    • System ID: npfh-cto-orchestrator
    • Risk classification: Limited risk (no safety-critical decisions)
    • Model: Claude Sonnet 4.6 by Anthropic (executor)
    • Data processed: Aggregated platform metrics only — no user personal data
    • Human oversight: All critical recommendations require admin approval via the Approval Queue
    • Audit trail: Every agent run is logged to an audit table with full transparency metadata

    Agent Fleet

    Additional agents (health monitor, security sentinel, content pipeline, revenue intelligence) operate under the same governance framework. All agents are classified as limited-risk, process only aggregated data, and log all decisions for audit. No agent can access user personal data, execute financial transactions, or deploy code without human approval.

    Your rights

    You may request a full list of active agents, their purposes, and the data they process by contacting support@neuronpathway.app.

    4

    Transparency & Identification (EU AI Act Art. 18, 50 & 52)

    The EU AI Act (Regulation (EU) 2024/1689) imposes layered transparency obligations on AI providers and deployers. Under Article 18, providers must give deployers and users clear, accessible information about the AI system's purpose, capabilities, limitations, and the data it processes — which this page and our in-app disclosures fulfil. Under Article 50, deployers of AI systems that interact with natural persons must inform those persons that they are interacting with an AI system. Under Article 52, AI-generated content must be clearly identifiable as such. We comply with all three obligations through the following measures:

    • All AI-generated training plans and meal plans are marked with anAI-generatedbadge (rendered via the AIBadge component) directly within the UI.
    • The AI Coach chat interface displays a persistent subtitle — "Powered by AI · NeuronPathway" — and a disclaimer that AI advice is not a substitute for professional guidance.
    • Users see an AI disclosure during onboarding before using any AI feature.
    • A persistent in-app banner reminds users that recommendations are AI-generated and not medical advice.
    5

    How We Use Your Data with AI

    When generating plans or coaching responses, we transmit a minimal subset of your data to our AI sub-processors. We never send your name, email address, payment information, or login credentials to AI providers.

    Data sent for plan generation

    • Fitness goals and experience level
    • Body weight and target metrics (if provided)
    • Available equipment and training days
    • Injuries and restrictions
    • Dietary preferences and restrictions (for meal plans)

    Data sent for AI Coach chat

    • The message you type
    • Recent conversational context (last N messages) to maintain coherence
    • Your role (personal trainer, client, or athlete) to tailor responses

    AI model training

    Our data processing agreements with Anthropic explicitly prohibit the use of your personal fitness data to train or improve their foundation models. Your data is used solely to generate your specific outputs.

    For full details, see our Privacy Policy (AI processing and EU AI Act compliance).

    6

    AI Limitations & Disclaimer

    AI content is not a substitute for professional advice. NeuronPathway's AI-generated training plans, meal plans, and coaching responses are informational tools to support — not replace — the guidance of a qualified personal trainer, nutritionist, or medical doctor. Always consult a professional before starting a new exercise programme, particularly if you have pre-existing health conditions, injuries, or specific medical requirements.

    AI systems on our platform may:

    • Occasionally produce outputs that are inaccurate, incomplete, or not appropriate for your specific circumstances
    • Lack the contextual judgement of a qualified human professional
    • Not be aware of recent medical or scientific developments published after their training data cutoff
    • Make assumptions based on the data you provide — the quality of outputs depends on the accuracy of your inputs

    We continuously monitor AI outputs and update our models and prompts. If you receive a response that seems incorrect or harmful, please use the feedback mechanism or contact us directly.

    7

    Human Oversight & Automated Decision Rights (EU AI Act Art. 22 / GDPR Art. 22)

    Under EU AI Act Article 22, users of AI systems have the right to meaningful human oversight over AI outputs that affect them. In accordance with GDPR Article 22, no decision that produces legal or similarly significant effects is taken solely by automated means on NeuronPathway. You have the right to:

    • Request human review of any AI-generated training plan, meal plan, or coaching response.
    • Opt out of AI coaching entirely and use manually-created plan templates instead.
    • Understand when AI is making recommendations versus when content has been authored or approved by a human trainer — all AI-generated content carries a clear label (see Section 4).

    Personal Trainer Review

    All AI-generated plans assigned to clients are reviewed and approved by the personal trainer before being presented to the client. Trainers can edit, regenerate, or replace any AI-generated content.

    Athlete Self-Review

    Self-managed athletes and independent users may edit any AI-generated plan in full before saving it. AI suggestions are never applied automatically.

    Opt-Out from AI Features

    You may opt out of AI-powered features at any time by contacting support@neuronpathway.app. Manual plan templates remain available to all users on any plan.

    8

    Your Rights Regarding AI

    • Right to explanation — You may request an explanation of how a specific AI-generated plan or response was produced. Contact us at the email below.
    • Right to human review — You may request that any AI output be reviewed by a human (your personal trainer or our support team).
    • Right to opt out — You may opt out of AI-powered features entirely. This does not affect your access to the rest of the platform.
    • Right to data portability — You may export all your personal data, including data used to generate AI outputs, at any time via Settings or by contacting us. See our Terms of Service (data portability and export) for details.
    • Right to object — You may object to the processing of your special category health data for AI plan generation under GDPR Article 21. Objection may limit personalisation features but will not affect core platform access.

    To exercise any of these rights, contact us at support@neuronpathway.app. We will respond within 30 days.

    9

    Contact & Feedback

    If you have questions about this AI Policy, would like to report a harmful AI output, or wish to exercise your rights, please contact us:

    support@neuronpathway.app

    We welcome feedback on our AI systems. If you receive a response that is inaccurate, inappropriate, or potentially harmful, please report it and we will investigate and take corrective action.

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