Regulation (EU) 2024/1689 · EU AI Act Transparency

EU AI Act Transparency & Governance

Formal disclosure regarding AI system classification, formative learning purpose, absence of automated employment decisions, and our human review request protocol.

Formative Training Purpose

Dehurdle is an educational simulator for skill rehearsal. When used as intended, we assess it as outside the EU AI Act's high-risk employment categories.

No Automated HR Actions

Dehurdle scores are developmental metrics. Our Terms of Service prohibit using them as the sole or primary basis for disciplinary actions, terminations, or pay decisions (see GDPR Article 22).

Human Review on Request

Any employee or user can dispute an AI scorecard and request a review by a member of the Dehurdle team.

Regulatory Classification

Classification Under EU Regulation 2024/1689 (EU AI Act)

The European Union Artificial Intelligence Act establishes transparency and governance requirements based on risk tiering. Here is how we assess Dehurdle against them:

1. Exclusion from High-Risk Employment AI (Annex III, Point 4)Formative L&D

Annex III(4) of the EU AI Act classifies as “high-risk” AI systems used for recruitment, selection, promotion, task allocation, or performance monitoring that directly impact employment status. Dehurdle is not designed or offered for these purposes, and our Terms of Service prohibit such use. Dehurdle is a formative practice tool where employees rehearse complex communication scenarios.

2. Transparency Obligations (Article 50 EU AI Act)Full Disclosure

Simulations are presented as roleplay with an AI persona (Gemini Live). Every evaluation report states that scores, pacing analysis, and rationale are AI-generated and links to a human review request.

3. Prohibition on Punitive UseBinding Terms

Our Terms of Service prohibit using Dehurdle scorecards and competency reports as the sole or primary basis for high-stakes employment decisions, including hiring, terminations, promotions, or performance-based disciplinary actions.

Model Architecture & Data Flows

AI Models and Processing Pipeline

Here is the model architecture powering Dehurdle:

Gemini 2.5 Pro

Post-Interaction Evaluation & Scorecards
Google Cloud Platform

Performs deep contextual reasoning across conversation transcripts to grade 5 targeted atomic competencies, identify key moments, and formulate constructive behavioral coaching tips.

Input Data:Session transcript text, scenario blueprint, chosen competencies
Retention Policy:Not used for model training. Text report stored in Dehurdle's database, scoped to the customer organization.

Gemini Live API

Real-Time Conversational Roleplay
Google Cloud Platform

Powers conversational AI personas responding in <300ms latency via bi-directional WebSockets, simulating real-world objections, direct Dutch communication, and emotional nuance.

Input Data:Ephemeral audio chunks streamed via TLS 1.3 WebSockets
Retention Policy:Dehurdle does not store audio. The audio stream is processed in memory for the live conversation only.

Gemini 2.5 Flash

Speech Biometrics & Telemetry
Google Cloud Platform

Calculates speaking pace (words per minute), filler word density (detecting Dutch disfluencies like 'zeg maar' and 'eigenlijk'), pause efficiency, and vocal conviction.

Input Data:Ephemeral audio buffers submitted for diagnostic telemetry
Retention Policy:Not used for model training. Output metrics stored in the structured scorecard.

No Model Training on Your Data: Dehurdle runs these models on Google Cloud Vertex AI, whose service terms do not permit Google to use customer transcripts, audio, or simulation context to train its models.

Human Review

Human Review & Appeal Protocol

Every employee and participating professional can request a human review of any AI scorecard generated on Dehurdle.

1

Initiate Request

Click “Request Human Review” at the bottom of any scorecard in the platform, or email reach@dehurdle.com with your Interaction ID.

2

Human Assessment

A member of the Dehurdle team reviews the conversation transcript, scenario requirements, and competency rationale.

3

Written Response

You receive a written response by email that either confirms the assessment or explains any correction.

Submit a Review Request Directly

Are you an employee seeking a human evaluation review for a completed simulation session?

Email Review Request

Enterprise AI Governance Inquiries

For procurement risk questionnaires or questions for our privacy team about EU AI Act alignment:

Contact reach@dehurdle.com