ALFRED AI FEATURE ADDENDUM
This Alfred AI Feature Addendum (the “Addendum”) supplements and forms part of the agreement governing the Service between Mitigram AB (“Mitigram” or “Provider”) and the Client, being either Mitigram’s Terms of Service or a separate written agreement governing the Service between those parties (the “Terms”), and, where applicable, their Data Processing Agreement (the “DPA”).
Mitigram has developed an AI-powered assistant feature called Alfred (“Alfred”), which is made available to Clients as an optional feature within the Service. Alfred is built on Microsoft Azure AI Foundry and operates entirely within Mitigram’s existing Azure tenant infrastructure.
This Addendum sets out the specific terms governing the Client’s use of Alfred, including data handling, intellectual property, liability, and regulatory compliance. Capitalised terms not defined in this Addendum have the meanings given to them in the Terms or the DPA.
In the event of conflict between this Addendum and the Terms, this Addendum shall prevail with respect to the Client’s use of Alfred. In the event of conflict between this Addendum and the DPA on matters of personal data processing, the DPA shall prevail.
1. DEFINITIONS
“Alfred” means Mitigram’s AI-powered assistant feature, integrated within the Service and built on Microsoft Azure AI Foundry, which enables natural-language interaction with the Client’s data within the platform.
“AI Infrastructure Provider” means Microsoft Operations Ireland Ltd. (through its Azure AI Foundry platform), which provides the underlying AI model hosting and inference services used by Alfred.
“AI Output” means any text, data, analysis, recommendation, or other output generated by Alfred in response to a Prompt.
“Prompt” means any input, query, instruction, or data submitted to Alfred by a User.
“Conversation History” means the record of Prompts and AI Outputs within a User’s session with Alfred, retained for session continuity and quality purposes.
“Activation” means the process by which the Client requests and Mitigram enables Alfred for the Client’s Users, following the Client’s acceptance of this Addendum.
2. ACTIVATION AND SCOPE
2.1 Opt-In Only
Alfred is an optional feature. The Client must expressly request Activation before Alfred is made available to its Users. No Client data is processed by Alfred prior to Activation.
2.2 Acceptance
Activation is conditional upon the Client’s acceptance of this Addendum. Acceptance may be evidenced by, without limitation, execution of an Order Form referencing this Addendum, a written confirmation in any form (including email), acceptance through a mechanism provided within the platform, or any other act that clearly indicates the Client’s intent to be bound by this Addendum.
2.3 Scope of the Feature
Alfred is a general-purpose AI assistant that operates within the Service to help Users interact with their data through natural-language queries. Alfred does not make autonomous decisions, execute transactions, or take binding actions on behalf of the Client or any Entity. Alfred’s AI Outputs are informational only and do not constitute financial, legal, regulatory, or professional advice.
2.4 Feature Availability
Alfred is provided as part of the Service and is subject to the same availability and maintenance standards as the Service. Mitigram may update, modify, or enhance Alfred from time to time.
3. DATA HANDLING AND PROCESSING
3.1 No Model Training on Client Data
Neither Mitigram nor its AI Infrastructure Provider uses Client Data (including Content, Prompts, AI Outputs, or Conversation History) to train, retrain, fine-tune, or improve any AI or machine learning models. This commitment applies to all data processed through Alfred.
3.2 Processing Within Azure
Alfred uses Microsoft Azure AI Foundry through Mitigram’s Azure environment. Prompts and AI Outputs are processed by Mitigram and its AI Infrastructure Provider for the purpose of providing Alfred, subject to the data protection and confidentiality obligations applicable under the Terms and the DPA.
3.3 EU/EEA Data Residency
All data processed by Alfred, including Prompts, AI Outputs, and Conversation History, is processed and stored exclusively within the European Union / European Economic Area (EU/EEA), in accordance with Mitigram’s Data Processing Agreement and Privacy Policy.
3.4 Conversation History
Conversation History may be retained for session continuity and service quality purposes. Conversation History is subject to the same data handling obligations as other Client data within the Service and, to the extent it contains Personal Data, is governed by the DPA. Mitigram shall delete or anonymise Conversation History in accordance with its retention policies and the DPA.
3.5 Processing Under the DPA
To the extent that Alfred processes Personal Data on behalf of the Client, such processing is governed by the DPA. The Client remains the controller; Mitigram remains the processor. The categories of data processed through Alfred are limited to those already described in the DPA and Privacy Policy, supplemented by Prompts and AI Outputs to the extent they contain Personal Data.
3.6 Prohibited Inputs
The Client shall instruct its Users not to submit special categories of personal data (as defined under GDPR Article 9) or any data that the Client is not authorised to process through the Service. Mitigram is not liable for any consequences arising from the Client’s or its Users’ submission of prohibited data categories through Alfred.
3.7 Client’s Authority Over Submitted Data
The Client is solely responsible for ensuring that it has a valid legal basis to submit data to Alfred, including data relating to the Client’s own customers, counterparties, or other third parties. Where the Client submits third-party personal data through Alfred (including by forwarding communications), the Client warrants that such submission is permitted under its own agreements, privacy notices, and applicable data protection law. Mitigram processes such data solely as processor on the Client’s instructions and accepts no liability for the Client’s failure to obtain any required authorisation or consent.
4. SUBPROCESSORS
Microsoft Operations Ireland Ltd. (through Azure AI Foundry) is a subprocessor for the purposes of Alfred. By accepting this Addendum, the Client expressly approves the engagement of the subprocessors listed in the table below for the processing of Client data through Alfred. Microsoft is also listed on Mitigram’s published subprocessor register at https://mitigram.com/subprocessors/.
Microsoft’s processing of data within Azure AI Foundry is governed by the Microsoft Products and Services Data Protection Addendum (DPA) and Microsoft’s contractual commitments on AI data use, which confirm that customer data is not used for model training.
The following table lists the subprocessors engaged for the purposes of Alfred, using the same format as Mitigram’s published subprocessor register:
| Sub-Processor | Services | Location |
|---|---|---|
| Microsoft Operations Ireland Ltd. (Azure AI Foundry) | AI model hosting, inference, and natural-language processing for Alfred. No Client data is used for model training. | Europe |
The complete and current list of all Mitigram subprocessors is maintained at https://mitigram.com/subprocessors/.
5. INTELLECTUAL PROPERTY
5.1 Ownership of Alfred
Mitigram retains all rights, title, and interest in and to Alfred, including its algorithms, prompts, configurations, models, and all related intellectual property. Nothing in this Addendum transfers any ownership interest in Alfred or the Service to the Client.
5.2 Client Data and AI Outputs
The Client retains ownership of all data, content, and information it uploads to or generates within the Service (“Client Data”). AI Outputs generated by Alfred in response to the Client’s Prompts are treated as Client Data for the purposes of ownership. For the avoidance of doubt, Mitigram does not claim ownership of AI Outputs specific to the Client. The Client grants Mitigram a royalty-free, worldwide, non-exclusive license to use Client Data processed through Alfred solely for the purposes of operating, maintaining, enhancing, improving, and providing Alfred and the Service.
5.3 Aggregated and Anonymised Data
Mitigram may collect, analyse, and use data generated through use of Alfred, including Prompts, AI Outputs, and Conversation History, in aggregated, anonymised, or de-identified form for purposes including market analysis, benchmarking, product development, predictive analytics, and industry reporting. To the extent permitted under applicable data protection law, such data shall not constitute Personal Data. Mitigram has a perpetual, irrevocable, worldwide, royalty-free right to create, commercialise, and otherwise exploit derivative data, including insights, models, scores, benchmarks, and indices, generated from such data. This right survives termination of this Addendum and the Terms. Published outputs will be sufficiently aggregated or anonymised to prevent identification of the Client, its Users, or individual transactions. Mitigram shall not attempt to re-identify any anonymised data.
5.4 Feedback
The Client grants Mitigram an irrevocable, worldwide, royalty-free licence to use, modify, and incorporate any feedback, suggestions, or recommendations the Client or its Users provide in relation to Alfred, without obligation or compensation.
6. LIMITATIONS AND DISCLAIMERS
6.1 No Guarantee of Accuracy
AI Outputs are generated by machine learning models and may be inaccurate, incomplete, or unsuitable for a particular purpose. The Client acknowledges that Alfred does not provide guaranteed, verified, or auditable outputs. Users should independently verify AI Outputs before relying on them for any purpose.
6.2 No Professional Advice
Alfred does not provide financial, legal, tax, regulatory, or other professional advice. AI Outputs should not be treated as a substitute for qualified professional judgment. Mitigram accepts no liability for decisions made or actions taken in reliance on AI Outputs.
6.3 External Agreements
Mitigram has no liability arising from or related to any external agreements, transactions, or dealings entered into by the Client or any Entity, whether or not informed by AI Outputs. Any agreements formed following interaction with Alfred occur externally and independently of Mitigram.
6.4 Warranty Disclaimer
Alfred is provided “as-is” and “as-available” as part of the Service. To the maximum extent permitted by applicable law, Mitigram disclaims all warranties, express or implied, including warranties of accuracy, fitness for a particular purpose, merchantability, and non-infringement, with respect to Alfred and AI Outputs.
7. LIABILITY
7.1 Liability Cap
Mitigram shall have no liability whatsoever arising from or in connection with Alfred, AI Outputs, or the Client’s use of or reliance on either. For the avoidance of doubt, Alfred is provided as an informational convenience and the Client’s sole remedy for dissatisfaction with Alfred is deactivation under Section 10.2. This limitation does not apply to liability arising from gross negligence, intentional misconduct, or fraud.
7.2 Exclusion of Indirect Damages
Neither Party shall be liable to the other for any loss of profits, sales, business, agreements, anticipated savings, goodwill, data corruption, or any indirect, special, or consequential loss or damage arising from or related to Alfred, including claims based on AI Output accuracy, completeness, or fitness for purpose, regardless of the form of action or theory of liability.
7.3 Client Responsibility
The Client is responsible for its use of AI Outputs and for ensuring that such use complies with applicable law and the Client’s own internal policies. Mitigram shall not be liable for any loss or damage arising from the Client’s reliance on AI Outputs without independent verification.
8. REGULATORY COMPLIANCE
8.1 EU AI Act
Mitigram monitors and takes steps to comply with Regulation (EU) 2024/1689 (the EU Artificial Intelligence Act) to the extent applicable. Based on Mitigram’s current assessment, Alfred is not classified as a high-risk AI system under Annex III of the EU AI Act. Alfred is a general-purpose AI assistant used to facilitate natural-language interaction with platform data and does not fall within the high-risk use cases enumerated in the regulation.
8.2 Transparency
In accordance with applicable transparency requirements, Mitigram ensures that Users interacting with Alfred are informed that they are communicating with an AI system. Alfred is clearly identified as an AI assistant within the platform interface.
8.3 GDPR Compliance
The processing of personal data through Alfred complies with the General Data Protection Regulation (EU) 2016/679. The Client’s and Mitigram’s respective obligations as controller and processor are set out in the DPA.
8.4 Ongoing Compliance
Mitigram shall monitor regulatory developments affecting AI features within the Service and shall take commercially reasonable steps to maintain compliance with applicable laws. Material changes to Alfred’s compliance posture will be communicated to the Client in accordance with Section 11.2.
9. DATA BREACH NOTIFICATION
In the event of a data breach affecting data processed through Alfred, the notification obligations set out in the DPA (Section 8) apply. For the avoidance of doubt, Mitigram shall notify the Client in writing by email immediately upon becoming aware and no later than 24 hours after becoming aware of a breach affecting data processed through Alfred.
10. TERM AND TERMINATION
10.1 Term
This Addendum enters into force upon Activation and remains in effect for as long as Alfred is activated for the Client and the Terms are in force.
10.2 Deactivation
The Client may request deactivation of Alfred at any time by written notice to Mitigram. Following deactivation, Mitigram shall cease processing Client data through Alfred. Conversation History will be deleted or anonymised in accordance with Mitigram’s retention policies and the DPA.
10.3 No Refund
Deactivation of Alfred does not entitle the Client to any refund, credit, or pro-rata adjustment of Fees already paid or committed under the Terms or any applicable Order Form.
10.4 Survival
Sections 5 (Intellectual Property), 6 (Limitations and Disclaimers), 7 (Liability), and any other provisions which by their nature should survive, shall survive termination or expiry of this Addendum.
11. GENERAL PROVISIONS
11.1 Precedence
This Addendum supplements the Terms and the DPA. In the event of conflict: (a) on matters of personal data processing, the DPA prevails; (b) on commercial matters, including fees, invoicing, trial periods, subscription terms, renewal and cancellation, the applicable Order Form prevails; (c) on all other matters relating to Alfred, this Addendum prevails over the Terms.
11.2 Amendments
Mitigram may update this Addendum from time to time by publishing an updated version. Material changes shall be notified to the Client with at least 30 days’ advance notice. Continued use of Alfred following such notice constitutes acceptance of the updated Addendum.
11.3 Governing Law
This Addendum is governed by Swedish law. Disputes arising from or in connection with this Addendum shall be resolved exclusively by the competent courts of Sweden.
11.4 Entire AI Terms
This Addendum constitutes the entire agreement between the Parties with respect to Alfred and supersedes any prior or contemporaneous communications, representations, or agreements relating to the Client’s use of AI features within the Service. For the avoidance of doubt, this Addendum does not supersede the commercial terms set out in any applicable Order Form, including fees, invoicing, trial periods, subscription terms, renewal and cancellation.