EU AI Act — Transparency Disclosure

Regulation (EU) 2024/1689 (the AI Act) — Edition: 2026-05-26

1. Provider identification

Provider of the AI system: Project Line, emil.mamadov@projectlineil.com.

2. AI components present in the Service

Voice receptionist — natural-language audio agent that answers calls for the clinic.
Drug-safety helper — surfaces potential interactions based on stored patient medication list.
Form auto-fill — pre-fills routine appointment templates based on patient history.
Clinical-decision suggestions — non-binding suggestions for follow-up (PHQ-9 / GAD-7 thresholds, refill timing).

3. Risk classification under Annex III

The Service is positioned as a documentation and workflow tool. Clinical-decision-support functions surface information to the licensed clinician for their independent review and decision. The treating clinician retains exclusive medical authority; the Service does not autonomously triage, diagnose, prescribe, or refuse care. On that basis the Service is operated as NOT a high-risk AI system under Annex III(5)(a).

If a clinic elects to use AI output to make autonomous clinical decisions, the clinic itself becomes the מפעיל (deployer) of a high-risk AI system under Art. 26 AI Act and assumes the corresponding obligations. The Service Agreement prohibits this use.

4. Art. 50 transparency obligations met

Patients calling the AI voice agent hear an audible disclosure at the start of each call (Art. 50(1)).
Calls to the AI voice agent are NOT recorded — the conversation is processed in real time (speech-to-speech) with no audio or transcript stored.
Synthetic voice output is identified as such on first contact.
The clinic's medical records explicitly tag any AI-generated text in the appointment notes.

5. General-purpose AI model sources

Component	Provider	Model	Status
Voice + chat	OpenAI	GPT-Realtime family	GPAI provider — see openai.com/policies
Image OCR	OpenAI	GPT-Realtime family (vision)	GPAI provider

6. Quality management

Internal quality-management system covers data governance, log retention, change management, and post-market monitoring. Incidents are recorded in Project Line's internal log and material AI-related incidents are reported to clinic controllers within 72 hours.

7. Right to human intervention

Every AI output is reviewable and editable by the treating clinician. Patients always reach a human contact through the clinic; the AI voice agent transfers to a human on request.

8. Updates

This disclosure is updated whenever a new AI capability is added or a model provider changes. Material changes are announced under the sub-processor change procedure.