EU AI Act — self-assessment
Why we publish this. The service is used in education, which the EU AI Act treats as a sensitive area. Rather than leave buyers to guess, we state our own assessment and the facts it rests on.
Our assessment
The service contains an AI element, but it is not a system that makes or supports decisions about people in education. We assess it as outside the high-risk category.
The facts this rests on
- No decisions about learners. The service does not admit, place, grade, certify or evaluate anyone. It gives feedback to the player, about the player's own attempt, for the player's own use.
- No reporting to institutions. A teacher can hand out an assignment link, but the service sends the institution no assessment of any individual student. There is no student record to report on.
- The estimator is statistics, not a learned model. The perception-threshold estimate is a Bayesian estimator with an explainable, published method. It has no training data and no learned weights.
- Language models are used in production of content, not in the product. Translations of the written material are produced with the help of language models and are labelled with their provenance. The games themselves contain no model inference — a page translated with a tool does not become an AI system, just as a textbook does not become one because it was typed in a word processor.
Transparency, regardless of category
Non-English written material is machine-translated unless marked otherwise, and each page carries a machine-readable provenance marker stating the translation tier and whether a native speaker verified it. Where material is not natively verified, we say so.
When this assessment is revisited
This assessment is tied to what the service does today. It is revisited before, not after, any of the following ships: an adaptive engine that alters a learner's path from a learned model; any feature that reports an assessment of an individual to an institution; or any model inference inside the product. Each of those would change the analysis.