EU AI Act

1. What this page is#

This page sets out how Regulation (EU) 2024/1689, the EU AI Act, applies to Agined Attestor, as amended by Regulation (EU) 2026/1744, the Digital Omnibus on AI. It covers our own role under the Act, the one AI system we operate, and what we owe you if you build Agined into an AI system of your own.

Section 5 is a binding agreement. You accept it when you create an account, together with the Terms of Service, the Privacy Policy and the Acceptable Use Policy. The other sections describe the Service and do not add obligations.

The Service is provided by Avonao, Inc., 254 Chapman Rd, Ste 208 #21918, Newark, Delaware 19702, USA ("we", "us") (legal address). Our mailing address, for general correspondence only, is Avonao, Inc. • 2261 Market Street PMB 10671, San Francisco, CA, 94114, United States. It is not our legal address: all legal correspondence must be sent to the legal address in Delaware stated above (see the Imprint).

In plain language: the tools are not AI systems, including the ones that keep records about AI systems. Number One, our assistant, is one, and it tells you so. If you use Agined to keep records for a high-risk AI system, Section 5 is the written agreement the AI Act asks the two of us to have.

2. Which part of the Service is an AI system#

The tools are not AI systems. Each tool carries out rules we wrote: relay this request and sign what came back, sign this hash with the time, deliver this webhook, fetch this page or record and compare it with the last one, verify this signature against this key, check this deadline against our clock, compute this Merkle root. None of them infers from its input how to produce predictions, content, recommendations or decisions. Recital 12 of the Act says that systems based on rules defined solely by people to execute operations automatically are not AI systems. No tool calls a machine-learning model at any point.

Tools that keep records about AI systems are records, not part of the AI system. Several tools record what your AI system or agent did, was told or ran on:

Your system decides what to do; these tools only record it, or check a signature or a key the record names. We are not the provider or the deployer of your AI system because it uses them. A receipt from any of them is not a conformity assessment, does not make your system compliant, and does not by itself show that an obligation under the Act, such as record-keeping (Article 12), transparency to deployers (Article 13), human oversight (Article 14) or transparency to people (Article 50), is met. It is evidence you can use when you show how you meet them.

Two of these deserve a word:

• disclosure.attest records that a page served a disclosure text, for example a notice that a person is interacting with an AI system, in a language, to a session, at a time. It records that the text was served, not that the person saw or understood it. Telling people under Article 50 remains your duty.
• dataset.snapshot and optout.snapshot record what a dataset contained and what a site published about text and data mining at a time. A provider of a general-purpose AI model can use them when documenting training content and respecting reservations under Article 53(1)(c) and (d). They are not a copyright policy and not the summary of training content the Act requires.

Number One is an AI system. Number One answers questions about Agined on the website and in the dashboard, where it can also look up your workspace when that is switched on. It is built on a general-purpose AI model from Anthropic, PBC (see Sub-processors), and we put it into service under our own name, so we are its provider under Article 3(3). It is not a high-risk AI system: it is not used for any purpose listed in Annex III, and it is not a safety component of a product covered by Annex I. In the dashboard it is read-only: it cannot change anything in your workspace.

What we are not. We do not place a general-purpose AI model on the market, and we do not train models on your data. Because we provide no high-risk AI system and no general-purpose AI model, the duty to appoint an authorised representative in the Union (Articles 22 and 54) does not apply to us.

3. Number One and the transparency rules#

Article 50 has applied since 2 August 2026. Number One was put into service after that date, so no transition period applies to it.

1. You are told it is an AI system (Article 50(1)). The chat panel labels Number One as an AI assistant at the top, where you see it before your first message, in the clear and distinguishable way Article 50(5) requires. In the dashboard the panel also says that it can be wrong and that it only reads.
2. Its answers are marked in a machine-readable way (Article 50(2)). Every answer Number One generates, on the website and in the dashboard, is sent with the HTTP response header AI-Disclosure: mode=ai-originated, from the AI-Disclosure header draft (draft-abaris-aicdh). Software reading the response can tell that the text was generated by an AI system without parsing it.
3. Where the marking does not reach. Text you copy out of the chat panel does not carry the header with it. Carrying it would mean hiding a watermark inside the words, which reformatting removes and which would alter text you may want to quote exactly. Article 50(2) asks for marking as far as technically feasible; this is where that ends.

Messages written by people and shown by a program, such as an error or a limit notice, are not AI-generated and carry no marking.

4. If you use Agined for your own AI system#

Using Agined does not make your AI system compliant. Classifying your system, building its logging, managing its risks and assessing its conformity are your obligations, and we cannot take them on. What Agined gives you is a record of your system's actions and model calls that anyone can check without trusting you or us. The EU AI Act record-keeping page explains how customers use it.

Dates. Under the Digital Omnibus, the obligations for high-risk AI systems apply from 2 December 2027 for systems listed in Annex III and from 2 August 2028 for systems covered by Annex I.

Keep logs for long enough. Article 19 (for providers) and Article 26(6) (for deployers) require automatically generated logs of a high-risk AI system to be kept for at least six months, unless other law says otherwise. We delete receipts when they leave your plan's retention window. Team (365 days) and Scale (730 days) keep receipts for at least six months, and so does Enterprise unless your contract sets a shorter window. On every other plan, including Pro+ at 180 days, export your receipts and keep them yourself. A receipt you have kept stays verifiable offline with our published keys after we delete our copy.

5. Article 25(4) value-chain agreement#

5.1 Why this agreement exists#

Article 25(4) of the AI Act applies when a third party supplies tools, services, components or processes that are used or integrated in a high-risk AI system. That third party and the provider of the high-risk system must agree in writing on the information, capabilities, technical access and other assistance the provider needs to comply with the Act, based on the generally acknowledged state of the art.

If you use or integrate any part of Agined in an AI system that is high-risk under Article 6, you are that provider and we are that third party. This section is the written agreement between Avonao, Inc. and you, the customer who accepted it.

We make it part of every account, not only of accounts that tell us their system is high-risk. We cannot see how your system is classified, and an obligation we owe should not depend on our guessing correctly.

5.2 What we supply#

We supply the Agined tools (the relay, the attestations and records, the watches and captures, webhook and inbound delivery, and the monitors, in every category of the catalogue), the signed receipts they produce, the published public keys, the REST API, the MCP server, the software development kits and the GitHub Action. We do not supply an AI model.

5.3 Information we will provide#

On written request, at no extra charge, we will provide:

1. a description of the intended purpose, capabilities and known limitations of each tool you have integrated;
2. the documentation of the interfaces and of the receipt format, including the meaning of each field and which fields record what we observed and which record what you told us. Much of this is already published in the Receipt Practice Statement, Verifying receipts and Format versions;
3. what each tool records about your workspace, the fields recorded and the retention applied to them;
4. the security measures that protect the tools and the signing keys, as described in Key management;
5. notice of any change to a tool you use that could reasonably affect your compliance, before the change takes effect. A change made to fix an active security incident is the exception; we will tell you about it as soon as it is safe to.

5.4 Technical access#

You can retrieve every receipt we hold for your workspace through the API and the dashboard, and export it in a machine-readable format. You can verify every receipt yourself, offline, without contacting us, using our published keys with our libraries or your own code. That stays true after your account ends: Continuity describes how.

5.5 Assistance#

We will give you reasonable assistance and, at your direction, assist a notified body, a market surveillance authority or an auditor dealing with your system, including by answering documented technical questions about the tools you use.

We will not, and cannot, carry out your conformity assessment, sign your EU declaration of conformity or decide how your system is classified. Those acts are the provider's alone.

5.6 What this agreement does not do#

This agreement does not make us the provider or the deployer of your AI system, does not move any of your obligations to us, and does not change the role either of us has under the Act. If you put our name or trade mark on a high-risk AI system, or substantially modify one, Article 25(1) may apply on its own terms; neither of us can contract out of it.

5.7 Duration#

This agreement runs for as long as you use any Agined tool in your AI system. After your account ends, we will keep answering requests under 5.3 about the tools you used, for as long as the Act requires you to keep your documentation. We keep your receipts only as long as the Terms of Service say, so export the ones you need before then.

5.8 Relationship to the other terms#

This agreement supplements the Terms of Service and the Data Processing Addendum. Where it conflicts with them on a matter Article 25(4) governs, this agreement prevails.

5.9 Requests#

Write to support@agined.com with "Article 25(4) request" in the subject line. We aim to answer in substance within 15 working days.

6. Changes to this page#

We change this page when the Act, its guidance or the Service changes, and update the date at the top. When you create an account, we record the version of this page you accepted: its date and a fingerprint of its text. For a material change to Section 5 we tell account owners by email at least 30 days before it takes effect, as we do for the Terms of Service.