This policy explains how Mint66 uses artificial intelligence within our platform services, why we use it, and the safeguards that apply. It has been written with the EU Artificial Intelligence Act (Regulation (EU) 2024/1689) and the General Data Protection Regulation (GDPR) in mind. It should be read together with our platform Privacy and Data Protection Policy.
You can also read this policy on the Mint66 platform website.
Our principles
- Human oversight: AI assists people; it does not make decisions about them.
- Transparency: where practical, we seek to make AI-generated content identifiable to users.
- Privacy and anonymity by design: anonymous contributions remain anonymous. We design our services and AI features to minimize the risk that individuals can be identified from anonymous feedback or aggregated reporting.
- Fairness: we aim to avoid unfair bias and discrimination.
- Security and accountability: we protect the data we process and take responsibility for how AI is used in our service.
How we use AI
Our service may use AI to analyze feedback text and aggregated results, to summarize themes, and to offer suggestions to support the development of individuals, teams and organizations. AI features may be added, changed or removed over time, and this policy applies to all of them.
We use third-party AI models provided through Microsoft Azure OpenAI Service. We do not develop or train our own foundation models.
What we do not use AI for
We do not use AI in our service to:
- make or inform decisions about hiring, promotion, pay, discipline, dismissal, redundancy selection or any other career or employment decision;
- identify, or attempt to identify, anyone who has contributed anonymously;
- infer emotions from biometric data, categorize people by biometric data, or score people socially.
Suggestions are for development only
Where AI provides suggestions, for example in relation to 360 feedback or team and organizational performance, they are intended to be positive and developmental. They are advisory only, may be inaccurate or incomplete, and should be reviewed by a person. They must not be used as the sole or main basis for any decision about an individual.
Data we send to AI services
Text and results sent to AI models are provided without direct identifiers wherever possible. While users may sometimes include personal information within free-text comments, we take reasonable steps to minimize this and encourage users not to include personal information about themselves or others. Anonymous comments and ratings are never linked to the identity of the person who gave them. Because free-text comments are written by users, please avoid including personal information about yourself or others in them.
Where and how data is processed
AI processing takes place using Azure OpenAI Service in a European Union region. Under Microsoft's terms for this service, your data is not used to train the underlying models and is not made available to other customers. Microsoft acts as one of our sub-processors.
Data protection roles and your rights
As described in our platform Privacy and Data Protection Policy, your employer is the controller of your personal data and we act as processor. We do not take decisions based solely on automated processing that have legal or similarly significant effects on individuals. To exercise your data protection rights, or to ask a question about our use of AI, contact us at privacy@mint66.com. You also have the right to complain to your data protection supervisory authority.
Our approach under the EU AI Act
We use general-purpose AI models provided by others and deploy them in features designed to support transparency and development rather than to make decisions about people. We make sure AI-generated content is identifiable, and we provide guidance and training so that our staff understand the capabilities and limits of AI. Customers are responsible for determining whether their intended use of outputs falls within any regulated or high-risk use case under applicable law.
Accuracy, bias and limitations
AI can produce errors and reflect biases in the data it has learned from. We test and monitor our AI features and welcome reports of problems at the address above.
AI-generated content should be treated as guidance rather than fact and should be independently reviewed where appropriate.
Customer responsibilities
Organizations using our service remain responsible for keeping a person in the loop when considering AI-generated suggestions, for informing their people about the use of AI, and for complying with their own legal obligations. Customers are responsible for ensuring that AI-generated content is reviewed appropriately before being relied upon and for complying with applicable employment, data protection and AI-related laws.
Prohibited use of AI outputs
Customers must not use outputs generated by our service:
- as the sole basis for decisions affecting an individual's employment, remuneration or career;
- to identify or attempt to identify anonymous respondents;
- in a manner that unlawfully discriminates against individuals or groups; or
- for any purpose prohibited by applicable law.
Security
We protect data with encryption in transit and at rest and with access controls, and we rely on the security controls of the Microsoft Azure platform.
Changes to this policy
We may update this policy from time to time. The latest version will always be available on this page.