Artificial Intelligence Use and Disclosure (U.S.)

Version: 1.0

Effective Date: May 11, 2026

Last Updated: May 1, 2026

End Date (if applicable): May 11, 2027

Article 1: Purpose of This Disclosure

Fluence International, Inc. (“Fluence,” “we,” “us,” or “our”) uses artificial intelligence (“AI”) and automated tools as part of the Services. The “Services” are Fluence’s websites, online services, and training products (including any associated mobile applications), including Services provided directly by Fluence and Services provided through or in connection with Fluence’s business-to-business (B2B) or business-to-consumer (B2C) partners, that link to or display this notice. 

This disclosure explains:

• how AI may be used in the Services;

• the role of human oversight;

• what choices and rights may be available to you; and

• how to contact us with questions or requests.

This disclosure is intended to help you understand when you are interacting with AI-enabled features and how Fluence approaches responsible AI use.

Article 2: What We Mean by “AI”

For purposes of this disclosure, “AI” includes machine-learning models and other automated systems that can generate content, classify information, make predictions or recommendations, personalize experiences, or assist with analytics and operational decisions.

Article 3: How AI Is Used in the Services

Depending on the Service and features you use, Fluence may use AI to:

• Provide learning and training experiences. For example, AI may:

  • assist in the creation of course materials;

  • generate or help draft practice scenarios, quizzes, summaries, study plans, or coaching tips;

  • provide interactive tutoring, feedback, or suggested next steps;

  • evaluate your responses to training prompts to provide scoring, guidance, or suggested improvements.

• Personalize content and recommendations. AI may tailor learning materials, pace, difficulty level, or suggested content based on your interactions, progress, and preferences.

• Support safety, integrity, and security. AI may be used to detect spam, fraud, policy violations, abusive behavior, or attempts to misuse the Services.

• Improve and maintain the Services. AI may be used to analyze usage trends, help diagnose issues, improve feature performance, and support product development.

• Support customer support and operations. AI may assist our support team by routing inquiries, summarizing requests, drafting responses for human review, or helping identify relevant help materials.

• Business and administrative analytics. AI may help generate aggregated insights about product performance, training outcomes, user engagement, and operational metrics.

Important: AI-generated outputs can be incorrect, incomplete, or inappropriate. You should not rely on AI outputs as professional advice (including legal, medical, financial, or employment advice). If you need professional advice, consult a qualified professional.

Article 4: Data Inputs AI May Use

AI features may analyze one or more of the following categories of information, depending on what you choose to provide and how you use the Services:

• Account and profile information (e.g., name, email address, organization, role, partner/enterprise affiliation), if you create an account;

• Training activity data (e.g., courses completed, quiz results, interaction history, time spent, progress);

• User-provided content (e.g., text you type into prompts, video/audio recordings or transcripts, questions you ask, uploads you submit where enabled);

• Partner-provided information (where applicable) (e.g., enrollment/roster information, learning assignments, completion requirements, or identifiers provided by your employer, school, program sponsor, or other partner offering access to the Services);

• Device and usage information (e.g., browser type, device identifiers, IP address, logs, and similar information);

• Feedback and support communications (e.g., messages to support).

When you access the Services through a computer or mobile app, device permissions (such as camera, microphone, or notifications) may apply only if you enable those features and grant permissions. Any such permissions will be described in the Services.

Article 5: AI Outputs and Consequential Decisions

AI may generate outputs (such as training feedback, summaries, suggested responses, or recommendations) that you can view and use within the Services.

By default, Fluence does not use AI to make “consequential decisions” about you without human involvement. For purposes of this notice, a “consequential decision” means a decision that has a material legal or similarly significant effect on a person’s access to, or the provision, denial, cost, or terms of educational, healthcare, employment, legal, financial or lending, government service, housing, or insurance opportunities.

The Services may be offered through partners (for example, an employer, program sponsor, training provider, or platform partner). Partners may use training results and analytics provided through the Services (such as course completion, assessments, or progress) as part of their own programs and decisions. Fluence does not control partners’ decision-making and encourages you to review the partner’s applicable policies.

If Fluence uses AI in connection with a consequential decision in the future, we will provide any additional disclosures and choices required by applicable law.

Article 6: Human Oversight and Safeguards

Fluence uses a combination of technical and organizational measures designed to help ensure AI-enabled features are fair, accurate, appropriate, and secure for their intended use, which may include:

• testing and monitoring of AI performance;

• guardrails to reduce unsafe or inappropriate outputs;

• access controls and training for personnel who manage AI-enabled features;

• human review of certain AI-assisted actions and workflows (as applicable);

• processes to receive and address user feedback.

Article 7: Your Choices and Rights

Your options and rights may vary depending on your location and how you use the Services. Some jurisdictions provide specific rights and protections regarding AI use. These rights may change over time. 

To exercise your rights, please contact info@fluencetraining.com or use the form available here. 

7.1. Access, Correction, and Deletion

You may have the right to request access to, correction of, or deletion of certain personal information we maintain about you, subject to legal exceptions.

In partner-provided deployments, certain information may be controlled by the partner (for example, your enrollment information or organizational identifiers). In those cases, Fluence may need to direct you to the partner or coordinate with the partner to fulfill your request.

7.2. Information About AI Use

You may request more information about our use of AI in the Services, including the types of AI-enabled features you used and the general logic of how those features work (to the extent appropriate and consistent with protecting security and confidential or proprietary information).

7.3. Appealing or Requesting Human Review

If an AI-enabled feature is used in connection with a decision about you that has a material impact on you (including certain eligibility or access decisions, where applicable), you may request that we:

• review the decision;

• consider additional information you provide; and/or

• provide human review, where required by applicable law or where feasible.

Where the relevant decision is made by a partner (for example, an employer, program sponsor, or training provider), you may need to contact that partner for review or appeal processes.

7.4. Opting Out of Certain Automated Processing (Where Required)

In some states, you may have the right to opt out of certain types of processing, such as targeted advertising, certain profiling in furtherance of decisions that produce legal or similarly significant effects, or the “sale” or “sharing” of personal information (as those terms are defined by applicable law).

Information on these choices is available in our Privacy Notice.

Article 8: Fairness and Risk Mitigation

Fluence takes reasonable steps to identify, assess, and reduce risks that may arise from AI use, including the risk of algorithmic discrimination and other potential harms. These steps may include evaluating training data sources where applicable, monitoring for performance issues, and adjusting features to improve reliability and reduce bias.

Article 9: Third-Party AI and Service Providers

Some AI-enabled features may be provided or supported by third-party vendors or models. When we use third parties, we seek to require appropriate contractual protections, which may include confidentiality, security measures, and limits on use of data consistent with our policies.

Article 10: Children

The Services are not directed to children under 13, and Fluence does not knowingly collect personal information from children under 13 through the Services. If you believe a child has provided personal information to Fluence, please contact us so we can take appropriate action.

Article 11: Changes to This Disclosure

We may update this disclosure from time to time. We will post the updated version in the Services and update the “Last Updated” date above. Material changes may also be communicated through the Services or by other appropriate means, and where appropriate, Fluence will seek an updated acknowledgement of the changed Disclosure. 

Article 12: Contact Us

If you have questions about this disclosure, our use of AI, or you would like to exercise your rights, please contact:

Email: info@fluencetraining.com

Mail: Fluence International, Inc.

ATTN: Data Use & Privacy Policy 

132 West 169th St #3B

Bronx, NY 10452

Webform: CONTACT

Article 13: Additional Information for Certain Jurisdictions

This Section 13 supplements the disclosure above and applies only where required by applicable law.

13.1. United States (State Privacy Laws)

Residents of certain U.S. states may have additional rights under applicable state privacy laws. Please see our Privacy Notice for information on state-specific rights, methods to submit requests, verification requirements, appeal processes (where applicable), and any authorized agent procedures.

13.2. European Union (EU AI Act) – Transparency and Information

If you access the Services in the European Union, or if the EU AI Act applies to a Fluence AI system used in the Services, Fluence will provide transparency information required by applicable law, which may include:

• notice that you are interacting with an AI system (including where content is generated or significantly modified by AI);

• information about the AI system’s intended purpose and how to use it appropriately;

• information about known limitations of the system (including the risk of inaccurate outputs);

• information about the role of human oversight, where applicable.

If an AI system used in the Services is classified as “high-risk” under the EU AI Act, Fluence will implement and maintain required risk management, governance, logging, human oversight, and technical documentation measures, and will provide additional notices as required.