ARTIFICIAL INTELLIGENCE USE POLICY

1.1. This Policy sets out how artificial intelligence systems (the "AI systems") are used on the Edline online education platform (the "Platform"), what data is processed, how results are marked, what rights Users have, and how their enquiries are handled.

1.2. The owner and holder of the AI systems used on the Platform is ИП «QG Consulting» (Баймагамбетова Эльмира), registration number KZ21UWQ02673326, registered by State Revenue Department for Medeu District, Almaty, Republic of Kazakhstan (the "Operator"). The Operator is responsible for the use of AI systems on the Platform in accordance with the legislation of the Republic of Kazakhstan.

1.3. The artificial intelligence models used by the Platform are supplied by the third-party providers named in section 5 of this Policy. The Operator does not develop or train its own artificial intelligence models.

1.4. This Policy has been prepared in accordance with the Law of the Republic of Kazakhstan on Artificial Intelligence, the Law of the Republic of Kazakhstan on Personal Data and its Protection, the Digital Code of the Republic of Kazakhstan and the Law of the Republic of Kazakhstan on Consumer Rights Protection.

1.5. The set of Platform tools that operate using AI systems is referred to as "Edline Intelligence".

2.1. As at the date of publication of this Policy, the following AI systems are used on the Platform:

• essay review — at the User's request, the system produces a written commentary on the strengths and weaknesses of the essay submitted;
• profile assessment — the system produces a written description of the User's academic profile based on the information they have provided;
• application report — the system produces the written explanations and recommendations accompanying the User's report on their preparation for admission;
• translation assistance — the system is used to prepare translations of the Platform's informational content, which are then checked and edited.

2.2. All of the tools listed are started by an action of the User. The exception is the initial production of the application report, which is carried out when the User completes the questionnaire (onboarding) and with their consent; the User may refuse to use AI systems in the manner provided for in section 7 of this Policy.

2.3. The Edline Index, the university fit indicators and the Platform's other numerical indicators are calculated arithmetically under the Operator's deterministic methodology, without recourse to artificial intelligence systems. AI systems play no part in calculating these indicators and do not affect their values. The calculation methodology is described in the document "Methodology, data sources and disclosures".

2.4. The list of AI systems used on the Platform may change in the manner provided for in section 13 of this Policy.

3.1. In accordance with the requirements of the Law of the Republic of Kazakhstan on Artificial Intelligence, the Operator has determined the degree of risk of the AI systems used and their level of autonomy.

3.2. All AI systems listed in section 2 have been classified by the Operator as systems of a medium degree of risk with a low level of autonomy.

3.3. The grounds for that classification are:

• the outputs of the systems are informational and advisory in nature;
• the systems do not take decisions in respect of Users and do not give rise to legal consequences for them;
• each call to a system is initiated by the User, and the final decision is in every case taken by the User themselves;
• the systems are not used for biometric identification, assessment of emotional state, social scoring or profiling for advertising purposes;
• the Platform's Users include minors aged between 14 and 18, which has been taken into account in determining the degree of risk and the control measures.

3.4. The Operator manages the risks of using AI systems on an ongoing basis, maintains technical documentation for each system, records changes to the models and instructions used, and verifies the correctness of results before making such changes.

3.5. The classification is subject to review if the purpose of the AI systems changes, if their functions are extended, and if the legislation of the Republic of Kazakhstan changes.

4.1. When the "Edline Intelligence" tools are used, the following data provided by the User is processed:

• the text of the essay submitted by the User for review, and the wording of its assignment;
• the names and levels of the activities, achievements and awards stated by the User;
• academic indicators: grade point average (GPA), standardised test results, intended fields of study;
• the names of the universities selected by the User.

4.2. The following data is not transferred to AI systems or their providers under any circumstances:

• surname, given name and any other information permitting direct identification of the User;
• email address;
• date of birth;
• the User's account identifier on the Platform;
• information about the family's financial situation, including information about the expected family contribution;
• documents uploaded by the User to the "Documents" section;
• payment data.

4.3. The restriction in paragraph 4.2 is implemented by technical means of the Platform: the composition of the data transferred is determined programmatically and does not depend on the actions of individual staff.

4.4. Providing the information listed in paragraph 4.1 is voluntary. The Operator does not require it; a User's refusal to provide such information does not restrict access to the rest of the Platform's functionality.

4.5. Users are prohibited from entering into the "Edline Intelligence" tools the personal data of third parties without their consent, or information containing an individual identification number, passport data or biometric data.

5.1. In order to produce a result, the data listed in paragraph 4.1 is transferred to the following persons located outside the Republic of Kazakhstan:

5.2. Requests are sent to the routing service provider OpenRouter, Inc. (USA), which passes them to the model provider. As at the date of publication of this Policy, data is transferred to the following model providers: Anthropic PBC (USA), Google LLC (USA).

5.3. The Operator has additionally identified the model providers to whom data may be transferred in future: OpenAI, L.L.C. (USA). As at the date of publication of this Policy, no data is transferred to those providers.

5.4. The United States of America is not among the states recognised as providing protection of personal data within the meaning of Article 16 of the Law of the Republic of Kazakhstan on Personal Data and its Protection. The cross-border transfer is made on the basis of the User's (or their legal representative's) separate consent, given on registration on the Platform.

5.5. The transfer is made over secure communication channels using encryption. The Operator's relations with the recipients are governed by the commercial data processing terms of the relevant providers.

5.6. The data transferred is not used by the recipients to train artificial intelligence models.

6.1. Every output of an AI system is accompanied by a visible notice stating that it was produced by an artificial intelligence system and is informational in nature.

6.2. The notice is displayed directly above the result, is perceptible without any additional action by the User, and cannot be hidden.

6.3. Alongside the visible notice, the result carries machine-readable marking in the technical data of the page and of any files produced.

6.4. The marking is applied wherever the result is displayed, including exported files and email messages in which the result is included.

6.5. The form of the machine-readable marking is determined by the Operator pending approval by the authorised body of the corresponding procedure, and will be brought into line with it once adopted.

7.1. The User has the right to:

• read this Policy before beginning to use the "Edline Intelligence" tools;
• obtain confirmation that a particular result was produced by an artificial intelligence system;
• obtain a clear explanation of a result, including information about the data on which it was based, without disclosure of source code or algorithms;
• require a result to be reviewed by a human in the manner set out in section 8 of this Policy;
• require the protection of their personal data when it is processed by AI systems;
• refuse to interact with artificial intelligence systems entirely — the relevant setting is available in the account settings; such refusal does not restrict access to the rest of the Platform's functionality;
• require the deletion of AI system outputs produced for their account.

7.2. Enquiries are sent to info@myedline.com marked "AI", or through the corresponding form in the account settings.

7.3. For Users aged between 14 and 18, the rights under this section may be exercised either by the User themselves or by their legal representative.

8.1. The User may object to any output of an AI system and require it to be reviewed by a human.

8.2. An objection is sent to info@myedline.com marked "AI", or submitted through the account settings section. The objection states the result objected to and the substance of the objection.

8.3. The objection is considered by an authorised member of the Operator's staff within 3 working days of receipt. The User is notified of the outcome at the email address given in their account.

8.4. Following consideration, the Operator may confirm the result, correct it, produce it again, or delete it. The User is notified of the decision taken and the reasons for it.

8.5. Users' enquiries, the date of receipt, the applicable time limit and the date of the reply are recorded by the Operator.

9.1. In order to keep the Platform running and to prevent abuse, the following limits apply to use of the "Edline Intelligence" tools:

9.2. The limits apply per account. The current limit values are shown in the Platform's interface.

9.3. It is prohibited to use the "Edline Intelligence" tools to obtain results in respect of texts and data not belonging to the User, or to circumvent the limits by technical means.

9.4. The Operator may change the limit values, giving notice to Users in the manner provided for in section 13.

10.1. The Platform's AI systems do not take decisions in respect of Users and do not give rise to legal consequences for them. Decisions on access to the Platform, tariffs, discounts and terms of service are taken by the Operator without the use of AI systems.

10.2. AI systems are not used to calculate the Edline Index, the university fit indicators or the Platform's other numerical indicators.

10.3. Users' personal data is not used to train artificial intelligence models — neither by the Operator nor by the model providers.

10.4. The AI systems do not employ manipulative techniques, do not exploit vulnerabilities associated with Users' age, do not carry out social scoring, do not determine emotional state, and do not perform biometric identification or classification.

10.5. The essay review tool does not create or rewrite essays for the User. The User remains the author of the essay and is responsible for its content, including compliance with the academic integrity requirements set by educational institutions.

10.6. The outputs of AI systems do not constitute advice on admissions, nor legal, financial, medical or other professional advice.

10.7. The Operator does not guarantee that following the outputs of AI systems will lead to admission to an educational institution, to financial aid, a scholarship, a visa or any other outcome. The final decision is in every case taken by the User.

11.1. The text of requests sent to model providers is not stored by the Operator. Any technical records containing such text are destroyed once 30 days have passed.

11.2. The outputs of AI systems (reviews, assessments, explanations accompanying reports) are stored in the User's account and kept until the User deletes them or the account is deleted.

11.3. The Operator retains technical information about the use of AI systems: the date and time of the call, its purpose, the model used, the volume of data processed and the cost of the call. This information contains no request or result text and is used to enforce the limits, to maintain security and to account for costs.

11.4. Personal data retention periods are set out in the Platform's Privacy Policy.

12.1. The Operator is responsible for the use of AI systems on the Platform to the extent established by the Law of the Republic of Kazakhstan on Artificial Intelligence and by other legislation of the Republic of Kazakhstan.

12.2. The Operator is not liable for decisions taken by the User on the basis of AI system outputs, except where such limitation of liability is not permitted by the legislation of the Republic of Kazakhstan on consumer rights protection.

12.3. Enquiries concerning the use of AI systems are sent to info@myedline.com. The Operator considers enquiries within the periods established by section 8 of this Policy and by the legislation of the Republic of Kazakhstan.

12.4. The User may challenge the Operator's actions concerning the use of artificial intelligence systems and the processing of personal data before the Ministry of Artificial Intelligence and Digital Development of the Republic of Kazakhstan (https://www.gov.kz/memleket/entities/mdai) or in court.

13.1. The Operator may change the list of AI systems, the models used, the model providers and the usage limit values.

13.2. An updated edition of this Policy is published on the Platform stating its version and date of entry into force.

13.3. Users will be notified on the Platform and by email at least 14 calendar days before personal data begins to be transferred to a new model provider. Where necessary, the Operator will request fresh consent to the cross-border transfer of personal data.

13.4. Continued use of the "Edline Intelligence" tools after the changes take effect signifies the User's agreement to the updated edition. A User who does not agree with the changes may refuse to use AI systems in the manner provided for in paragraph 7.1 of this Policy.

Operator and owner of the artificial intelligence systems: ИП «QG Consulting»

Surname, given name: Баймагамбетова Эльмира

Registration number: KZ21UWQ02673326

Registering body: State Revenue Department for Medeu District

Address: 124 Aimanov Street, office 507, Almaty, Republic of Kazakhstan

Telephone: +7 (747) 403-73-53

Email: info@myedline.com

Working hours: The Platform is available 24/7. Enquiries are handled on working days from 10:00 to 19:00 (UTC+5).

Platform: myedline.com