AI Disclosure
Effective date: April 15, 2026
Version: 2.0
You are interacting with an AI system. The Trazomo practicum uses AI to grade, score, and coach your exercise responses. The feedback you receive is generated by an artificial-intelligence model, not by a human reviewer, and is labeled "AI-generated feedback" in the product interface.
This disclosure is provided to satisfy our transparency obligations under Article 50 of the EU AI Act (Regulation (EU) 2024/1689) and comparable US state laws (including Colorado SB24-205 and Utah SB 149), as well as under GDPR Articles 13 and 14.
1. Where We Use AI
AI is used in the Services to evaluate user-submitted text and generate structured feedback, including:
- Scoring exercise responses against the lesson's evaluation criteria;
- Producing strengths and improvement suggestions;
- Generating short-form reflective feedback on quizzes;
- Auto-classifying reflection text for progress tracking.
AI is not used to make hiring, credit, licensure, disciplinary, or any other automated decision that produces legal or similarly significant effects concerning you within the meaning of GDPR Article 22.
2. Data-Flow Chain
When you submit text into a Trazomo exercise or reflection:
- Your browser transmits the text to Trazomo's servers (hosted on Cloudflare Pages) over TLS.
- Trazomo assembles a server-side prompt that includes your submission, the exercise context, and evaluation criteria.
- Trazomo forwards the prompt to an AI provider. By default, the provider is Cloudflare Workers AI (inference on Cloudflare's global network) or OpenRouter, which forwards the request to a selected third-party foundation model at request time. Models accessed via OpenRouter may include those from OpenAI, Anthropic, Google, Meta, Mistral, and others.
- The AI provider returns a score and feedback. Trazomo stores the score and structured feedback in your learning history; raw prompt text is not persisted on Trazomo servers beyond the time needed to compose and dispatch the request, except where the submission is a saved reflection, in which case your free-text response is stored in your learning history until you delete it or your account is closed.
Where the route traverses OpenRouter to a downstream model hosted outside the EEA, your submission leaves the EEA. Transfers rely on Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework. Please see our Privacy Policy for the legal bases and transfer mechanisms in detail.
3. Model Providers
We may route AI requests to one or more of the following:
- Cloudflare Workers AI — primary. Cloudflare neither creates nor trains the AI models made available on Workers AI, and does not use your inputs to train Cloudflare products. See Workers AI data usage.
- OpenRouter — primary routing gateway. OpenRouter does not store prompts or completions by default and does not train on them. We configure OpenRouter requests with Zero Data Retention (ZDR) routing where supported by the downstream model endpoint. Some downstream endpoints may retain inputs for abuse monitoring per their provider's policies. See OpenRouter privacy and logging and Zero Data Retention.
- Legacy fallbacks (only when explicitly configured): OpenAI (billed API tier — no training on your inputs by default); Anthropic (commercial API — no training on your inputs); Google Gemini (billed API tier only; free-tier AI Studio is not used because it may train on inputs); or a self-hosted local endpoint under our control.
4. Training Disclaimer
Neither Trazomo, Cloudflare Workers AI, nor OpenRouter trains AI models on your exercise submissions. We configure OpenRouter requests with Zero Data Retention routing where supported. Where a downstream model endpoint reached through OpenRouter operates its own abuse- monitoring retention window (typically 30 days or less), that provider's terms govern the interim handling of the data. We review these terms at each material revision of this disclosure.
5. Confidentiality — Do Not Submit Privileged or Client Data
The Trazomo practicum is a training environment. Text you submit into AI-assisted features is transmitted to third-party AI providers outside your direct control. You must not submit:
- information subject to the attorney-client privilege, whether your own, your firm's, or a client's;
- attorney work product, including mental impressions, legal strategy, draft pleadings, or memoranda prepared in anticipation of litigation;
- information you are obliged to keep confidential under ABA Model Rule 1.6 (or the analogous rule of your licensing jurisdiction), including information relating to the representation of a client, regardless of whether otherwise privileged;
- personally identifiable information of clients, opposing parties, witnesses, or third parties, unless fully de-identified;
- trade secrets, sealed court filings, grand jury material, data subject to a protective order, or material subject to export controls (ITAR/EAR);
- any information whose disclosure would breach a non-disclosure agreement, professional duty, regulatory obligation, or court order.
Use hypothetical facts, publicly available cases, or sanitized examples in every exercise. If in doubt, do not submit. You acknowledge this restriction at onboarding, and we display a persistent reminder next to each AI-evaluation input field.
6. Human Review Requirement
AI outputs can be inaccurate, incomplete, or outdated. You must independently review and validate all outputs before relying on them in any legal or business workflow. AI-generated feedback is a coaching signal only. It is not legal advice, not legal representation, and does not create an attorney-client relationship.
7. No Automated Decision-Making with Legal Effect
We do not use AI to make hiring, credit, licensure, disciplinary, or any other automated decision that produces legal or similarly significant effects concerning you within the meaning of GDPR Article 22. If you believe a Trazomo score has been applied to you incorrectly, contact salvador@trazomo.com and a human will review it.
8. AI Literacy Statement (AI Act Article 4)
Trazomo is, by design, an AI-literacy tool for legal professionals. Our staff who deal with the operation and use of the AI systems on our behalf receive documented training appropriate to their role, their technical knowledge, and the context of use, consistent with Article 4 of the EU AI Act.
9. Session Replay and Input Masking
If you consent to analytics cookies, we may record pseudonymous session replays for product-diagnostic purposes. Session replay is configured to mask all text inputs by default and to block recording of AI-evaluation input fields. This is designed to prevent the capture of any free-text submissions into exercises, reflections, or the in-app Messenger. See our Privacy Policy for details.
10. US State Disclosures
For users in the United States, this disclosure also serves the AI interaction-notice requirements of the Colorado Artificial Intelligence Act (SB24-205, as amended by SB25B-004) and the Utah Artificial Intelligence Policy Act (SB 149). Because Trazomo feedback is educational and not an automated consequential decision, the additional deployer obligations that apply to "high-risk AI systems" under those laws do not apply to the Services.
11. Changes to AI Processing
We may update AI providers, model versions, retention defaults, and related controls over time. Material updates will be reflected in this disclosure and, where required, in our Privacy Policy, with a new effective date and version number.
12. Questions or Concerns
For AI-processing questions, contact salvador@trazomo.com. You also have the right to lodge a complaint with your local data protection authority under GDPR, and to submit AI-related complaints to your national AI Act market-surveillance authority where such a body has been designated.