# Acceptable Use Policy

This Acceptable Use Policy applies to access and use of the Services provided to Client by Owkin in accordance with the Agreement. Owkin reserves the right to update this Acceptable Use Policy from time to time to reflect:

* developments in Owkin’s Services;
* technological progress and evolving market standard practices, particularly in relation to artificial intelligence architecture, safety, and security; and
* changes in Applicable Laws.

Owkin will provide quarterly written notice to the Client by email, indicating the changes (if any) to the Acceptable Use Policy provided in Schedule 6 vs. the then current version of the Acceptable Use Policy.

This Acceptable Use Policy is designed to ensure the Client's lawful and responsible access to the Platform and use of the Services. By executing the Agreement, Client agrees to comply with the following undertakings.

#### 1. Prohibited uses

Client must not use the Services to engage in, facilitate, or promote unlawful, deceptive, manipulative, or abusive activities, including but not limited to the following activities:

1. Violation of any Applicable Laws (e.g., intellectual property law, data privacy and artificial intelligence regulations);
2. Engaging in illegal activities (e.g., human trafficking, real money gambling, sale or purchase of illegal drugs or any illegal or controlled substances or goods or services, design or sale of weapons or dangerous and chemical materials);
3. Promotion of violence, hate speech, harm, extremism, or terrorism (e.g., any use that glorifies or facilitates self-harm or suicide, is sexually exploitative or abusive, constitutes hate speech or promotes racism, discrimination, hatred, or abuse, against any group or individual based on protected characteristics like race, ethnicity, national origin, religion, disability, sexual orientation, gender, or gender identity, promotes any act of violence or intimidation against people or animals);
4. Child sexual exploitation and sexually or violent explicit content involving minors (e.g., any use that exploits, abuses, sexualizes or endangers children, or otherwise compromises the health and safety of children; generation, creation, sharing, or facilitation of sexually explicit content involving minors, including pornographic content, exposing minors to violent content);
5. Individuals’ surveillance and predictive activities (e.g., illegal profiling or surveillance, including spyware or communications surveillance, untargeted scraping of facial images to create or expand a facial recognition database, or predictive policing, assessing the risks of a person committing a criminal offence);
6. Compromising individuals’ privacy or identity (e.g., violation of a person’s privacy rights, unauthorized access to personal information, unlawful access to or tracking of a person’s physical location, unlawful social scoring, real-time identification of a person or inference of emotions or protected characteristics of a person such as race or political opinions based on biometric data (including facial recognition);
7. Misinformation (e.g., generating or promoting misinformation, disinformation, defamatory content, or political propaganda; manipulating public opinion on health, safety, policy, or political matters; or undermining democratic processes through misrepresentation of voting procedures or voter suppression);
8. Fraudulent, abusive, misleading, or deceptive activities (e.g., enabling counterfeiting or distribution of illegal goods; promoting spam generation or distribution; creating content for fraud, scams, phishing, or malware causing financial or psychological harm; or producing deceptive digital content such as fake reviews or media);
9. Compromising or circumventing Owkin or a third-party security, cybersecurity safeguards or computer or network systems (e.g., exploiting vulnerabilities in IT systems, networks, or applications without authorization of the IT system owner; unauthorized access to IT systems, networks, applications, or devices through technical attacks or social engineering; creating or distributing malware, ransomware, or other types of malicious code; unauthorized access to the Services through any malicious activity including cybersecurity attacks or data poisoning).

#### 2. High-Risk Uses

Unless expressly authorized by Owkin and agreed between the Parties through a separate addendum to the Agreement, Client shall not use the Services for High-Risk Uses.

"High-Risk Uses" means any use of the Services that poses a significant risk of harm to the health, safety, fundamental rights or legal interests of natural persons, including use cases classified as high-risk under:

* AI Systems that are safety components of products covered by EU harmonisation legislation as set out in Annex I of the EU AI Act (Regulation (EU) 2024/1689);
* AI Systems listed in Annex III of the EU AI Act (Regulation (EU) 2024/1689); or
* Any other applicable artificial intelligence, data protection or sector-specific legislation in force in the relevant jurisdiction.

High-Risk Uses include, but are not limited to, deployment of the Services in the following areas:

* biometric identification and categorisation;
* critical infrastructure management;
* education and vocational training (including admissions and assessments);
* employment, recruitment and workers management;
* access to essential private and public services, credit and benefits;
* law enforcement and predictive policing;
* migration, asylum and border control;
* administration of justice and democratic processes; and
* any other use case designated as high-risk by applicable legislation or competent authorities.

Client acknowledges that High-Risk Uses require compliance with applicable regulatory requirements and that unauthorized deployment may result in immediate termination of the Agreement for material breach of this Acceptable Use Policy.

#### 3. Specific Use Cases

For any deployment of the Platform in automated, integrated, or programmatic contexts (including API usage, agentic workflows, skills, or code execution features), the Client shall implement appropriate human oversight and governance controls where the Platform is used to:

* support or automate decisions affecting individual rights;
* process personal data at scale;
* generate content intended for public distribution;
* execute financial transactions;
* interact autonomously with third-party systems; or
* operate in safety-critical or regulated environments.

Such controls shall be proportionate to the risk of the use case and may include, where applicable:

* monitoring and override capabilities;
* documented human approval processes for high-impact actions;
* user training; and
* incident record-keeping mechanisms.

These obligations do not apply to standard interactive use of the Platform without autonomous or system-level integration.

#### 4. Notification

If Owkin becomes aware that Client has violated this Acceptable Use Policy or is otherwise misusing the Services, Owkin may immediately restrict, suspend or terminate Client's right to use the Services without liability.

Client shall promptly notify Owkin if it becomes aware of any violation of this Acceptable Use Policy by Client or any Use.


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