AI Use Notice

Last updated: April 20, 2026 Effective date: April 20, 2026 Version: 2.0.0

1. Purpose of This Notice

This AI Use Notice (the "Notice") explains how Xiom OÜ ("Xiom," "we," "our," or "us") uses artificial intelligence ("AI") in the Prosperify application and related services (the "Service"), what data the AI processes, what its limitations are, and the choices you have.

This Notice is provided in line with transparency expectations under Regulation (EU) 2024/1689 (the "EU AI Act"), the Council of Europe Framework Convention on Artificial Intelligence, and similar emerging frameworks worldwide. It supplements — and should be read together with — our Privacy Policy, Terms of Service, and Financial Disclaimer.

If you only read one section of this Notice, read Section 4 (What the AI Cannot Do).

2. What AI Does in Prosperify

Prosperify uses AI to help you understand and organize the financial information you record in the Service. AI features ("AI Features") in Prosperify may include:

  • Insights — short observations about patterns, trends, or anomalies in the data you have entered (for example, a change in your spending category, a portfolio allocation shift, or a milestone toward a goal)
  • Summaries — natural-language summaries of your tracked accounts, holdings, or recent activity
  • Categorization assistance — suggested categories or tags for entries you create
  • Q&A about your own data — natural-language answers to questions you ask about the financial information you have entered
  • Educational explanations — definitions and general explanations of financial concepts when you tap a help icon or ask a question
  • Generated text for reports, summaries, or notes you can edit and save

The exact AI Features available may vary by tier, region, language, and stage of product rollout.

You will see a clear visual indicator (e.g., an "AI" tag or sparkle icon) wherever an output has been generated by AI, in line with the labeling expectations of the EU AI Act and similar laws.

3. How the AI Works

3.1 Inputs

When you use an AI Feature, the AI may receive:

  • The financial data you have entered into the Service relevant to the request (e.g., recent entries, account balances, holdings, goals)
  • Your explicit query, if you typed one
  • Limited context such as your selected currency, language, and the AI Feature you are using

The AI does not receive:

  • Your account credentials, passwords, or authentication tokens
  • Data from other Prosperify users
  • Data from external sources we do not control (we do not connect to your bank, broker, or other financial accounts)

3.2 Models and Providers

AI Features in Prosperify are powered by:

  • Large language models and other AI systems accessed through the Lovable AI Gateway, which routes requests to underlying foundation-model providers (currently Google, via the Gemini model family). The list of underlying providers may evolve over time and is reflected in the processor list in our Privacy Policy.
  • Pre-processing and post-processing steps performed by Xiom

Where third-party AI providers are involved, they act as data processors acting on our instructions under written agreements compliant with GDPR Article 28. The current list of AI providers is in section 7.1 of our Privacy Policy and is updated when changes occur.

3.3 No Use of Your Content for Model Training

We do not use the data you enter into the Service to train third-party foundation AI models, except where you have given explicit, separate consent.

Our standard contracts with AI providers prohibit them from:

  • Using your data to train, fine-tune, or improve their general models
  • Retaining your data beyond what is necessary to process your request
  • Using your data for any purpose other than providing the requested output to us

Where we use AI features for our own internal evaluation (for example, to test whether AI outputs are accurate or safe), we use anonymized, aggregated, or synthetic data, not personal data tied to identifiable users.

3.4 Data Retention by AI Providers

AI providers may temporarily retain your inputs and outputs for short periods for security, abuse-prevention, and reliability purposes — typically no more than 30 days, depending on the provider. After that period, the data is deleted from their systems. Specific retention terms are governed by our agreements with each provider.

3.5 International Transfers

Some AI providers process data outside the EU/EEA, including in the United States. Where this occurs, we rely on the safeguards described in Section 10 of our Privacy Policy, including European Commission adequacy decisions and Standard Contractual Clauses.

4. What the AI Cannot Do

This section is the most important part of this Notice. Please read it carefully.

4.1 The AI Does Not Give Advice

AI Features are decision-support tools that surface observations and answer questions about data you have entered. They are not:

  • Investment advice or recommendations to buy, sell, or hold any security, cryptocurrency, asset, or financial product
  • Personalized investment recommendations within the meaning of MiFID II, the U.S. Investment Advisers Act, or equivalent regulation
  • Financial planning, tax advice, legal advice, or accounting advice
  • Predictions of future market movements, returns, or outcomes
  • A substitute for advice from a licensed and regulated professional

4.2 The AI Can Be Wrong

AI systems are known to produce outputs that look confident but are inaccurate. This is sometimes called "hallucination." AI outputs in Prosperify:

  • May contain factual errors, including about general financial concepts
  • May misinterpret or misrepresent the data you have entered
  • May produce outputs that look plausible but are not supported by your actual data
  • May be inconsistent across sessions (the same question may produce different answers)
  • May reflect biases or limitations present in the underlying training data

You should always verify any AI output before relying on it for any decision, particularly any decision involving real-world financial action. Treat AI outputs as a starting point for your own thinking, not as a conclusion.

4.3 The AI Has Limited Context

The AI only sees the data you have entered into the Service for the specific request. It does not know:

  • Your full financial situation outside of Prosperify
  • Your goals, preferences, risk tolerance, or time horizon (unless you explicitly state them)
  • Your tax situation, jurisdiction-specific rules, or legal context
  • Recent market events that occurred after the underlying model's training cutoff
  • Information from other users or external databases

A licensed professional who knows your full situation will always have a more complete picture than the AI.

4.4 The AI Does Not Make Decisions for You

AI Features are automated assistance, not automated decision-making within the meaning of GDPR Article 22. AI outputs in Prosperify do not produce legal effects or similarly significant effects on you. Any action taken on the basis of an AI output is your decision, not the AI's.

We do not use AI to make decisions about you — for example, AI is not used to determine your eligibility for features, pricing, or service.

5. Your Rights and Choices

5.1 Opting Out of AI Features

You can disable AI Features at any time at Settings → AI Features. When AI Features are disabled:

  • You will continue to have full access to manual tracking and core Service functionality
  • AI insights, summaries, categorization suggestions, and Q&A will not be generated
  • We will not send any of your data to AI providers
  • Some functionality (specifically AI-powered features) will not be available, but the rest of the Service is unaffected

You can re-enable AI Features at any time using the same setting.

5.2 Reporting AI Issues

If an AI output appears wrong, harmful, biased, or misleading, you can report it by:

  • Tapping the "Report this output" option that appears alongside AI-generated content
  • Emailing support@prosperify.ai with a description of the issue

We use reports to improve our AI Features, identify safety issues, and decide whether to disable a particular feature pending investigation.

5.3 Withdrawing Consent

Where AI Features are provided on the basis of your consent (rather than as part of the core Service), you can withdraw consent at any time, with the same effect as opting out described in Section 5.1. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

5.4 Rights Under GDPR and Similar Laws

The privacy rights set out in Section 11 of our Privacy Policy apply equally to data processed through AI Features. This includes your rights to access, rectification, erasure, restriction, portability, and objection.

6. Risk Categorization Under the EU AI Act

We have assessed our AI Features against the risk categories of the EU AI Act:

  • Prohibited AI practices (Article 5): Prosperify does not engage in any prohibited AI practice (e.g., social scoring, manipulative techniques, biometric categorization for sensitive attributes)
  • High-risk AI systems (Annex III): Prosperify's AI Features are not high-risk. They are not used for credit scoring, eligibility assessments for essential services, employment decisions, or any other Annex III use case
  • Limited-risk AI (transparency obligations): AI Features that interact with users or generate content are subject to transparency obligations. We comply by labeling AI-generated outputs and providing this Notice
  • Minimal-risk AI: the remaining AI Features fall into this category, for which the AI Act does not impose specific obligations beyond general accountability

This assessment is documented internally and is updated as the Service and the AI Act's interpretation evolve.

7. Human Oversight

We exercise meaningful human oversight over AI Features through:

  • Pre-deployment review of new AI Features for accuracy, safety, and appropriate behavior
  • Ongoing monitoring of aggregate AI outputs for safety and quality issues
  • Response to user reports of problematic outputs (Section 5.2)
  • Ability to disable any AI Feature globally if a serious issue is identified
  • Regular review of our AI providers, contracts, and safeguards

We do not monitor individual users' AI conversations on a routine basis. Where investigation of a specific report is necessary, access is limited to authorized personnel and logged.

8. Children

The Service is not intended for individuals under the age of 18, and AI Features are not directed at minors. See our Privacy Policy for further information.

9. Changes to This Notice

AI is a fast-moving field. We may update this Notice to reflect changes in the AI Features we offer, the AI providers we use, applicable law, or our internal practices.

For material changes:

  • We will update the "Last updated" date at the top of this Notice
  • We will provide notice in the Service or by email
  • We will request fresh consent where the change materially affects your rights or the data sent to AI providers

10. Contact

If you have questions about this Notice or our use of AI:

Xiom OÜ Sepapaja tn 6, 15551 Tallinn, Harju maakond, Estonia Email: privacy@prosperify.ai General support: support@prosperify.ai

You may also reach us through the in-app feedback system at Settings → Help & Support, selecting "Privacy Request" or "Legal Inquiry" as the category.

This Notice is provided in English. If translations are made available, the English version prevails in the event of any conflict, except where mandatory local law requires otherwise.

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