This Policy describes how Pansophy AI Inc. designs, deploys, and governs the artificial intelligence capabilities in the Second Opinion. It is provided in accordance with Microsoft's Responsible AI principles and applicable regulatory requirements governing AI systems used in workplace contexts.

1. Purpose and Scope

This Responsible AI and Transparency Policy applies to all users and organizations that access the Second Opinion through Microsoft Teams and the Microsoft Marketplace. It governs how AI capabilities are designed, what they can and cannot do, and the obligations of both Pansophy AI and its users in ensuring responsible use.

2. AI Transparency Disclosure

Second Opinion uses artificial intelligence to analyze language patterns in documents you submit. By using the Software, you acknowledge and understand the following:

3. Human Oversight and Decision Authority

The Human-in-the-Loop Requirement

Second Opinion does not make recommendations or judgments about the individual being analyzed — it does not decide, rank, score, or advise on hiring or any other consequential decision about that person. It may suggest how the user should approach or address them (for example, next conversational steps). All outputs require human review, and the human reviewer retains full decision authority at all times.

Intended Use

The Software is intended to:

Prohibited Uses

Second Opinion must not be used as the sole or primary basis for any consequential decision about a person; used to automate decisions without human review; or used to evaluate individuals on the basis of any protected characteristic under applicable law.

4. Bias Identification and Mitigation

Lexicon-Blind Architecture (Affirmative Design Principle)

The most significant bias mitigation in Pansophy AI is architectural. The analysis engine processes only anonymized word patterns. It receives no demographic inputs of any kind. It cannot see who is speaking. It has no knowledge of the speaker's age, gender, race, ethnicity, national origin, disability status, or any other personal characteristic. This is not a limitation of the current version; it is a deliberate design principle that will not change.

This architecture is fundamentally different from machine learning-based assessment tools that train on historical outcomes. Second Opinion has no feedback loop from past decisions and no mechanism for demographic inference. The model cannot learn to discriminate because it never sees protected class data.

The analysis methodology is a word-count-based psycholinguistic approach grounded in decades of language research. It counts word categories in text. It does not know who wrote or spoke those words.

Acknowledged Limitations

Pansophy AI acknowledges the following limitations inherent in any linguistic analysis approach:

Mitigation Measures

In addition to the lexicon-blind architecture, Pansophy AI implements the following measures to reduce bias risk:

Ongoing Monitoring

Pansophy AI commits to ongoing monitoring of its AI systems for disparate impact and bias. We review aggregated, anonymized output patterns periodically and update our interpretation frameworks where concerns are identified.

5. Data Governance and Privacy

Data Residency

All data processed by the Software is stored and processed exclusively within Microsoft Azure's United States data centers (East US 2 region). No data is transmitted to or stored in non-Microsoft cloud environments. Second Opinion is currently available to Microsoft 365 tenants based in the United States, United Kingdom, Canada, Australia, New Zealand, and Singapore.

PII Scrubbing

Personally identifiable information is identified and redacted from extracted text prior to behavioral scoring, using Microsoft Azure AI Language. This step runs automatically on every document submission. The PII-redacted text is what reaches the scoring engine and the language model.

Retention

Pansophy AI applies a split retention model. Uploaded files, extracted text, and PII-redacted text are discarded at session close and are not written to persistent storage. Derived trait scores and the written narrative are retained by Pansophy AI for legal defensibility, model refinement, and ordinary business operations. Full retention detail is in the Privacy Policy.

Data Subject Rights

Users have the right of access, deletion, correction, and portability with respect to their data. To exercise these rights, contact privacy@pansophyai.com. Requests will be actioned within seven (7) business days.

Consent

You are solely responsible for obtaining required consent from individuals whose words are contained in documents you submit. Pansophy AI does not obtain consent from subjects directly.

6. Regulatory Compliance Framework

The Software is designed to support compliance with applicable AI and data privacy regulatory frameworks. Where the Software is used in connection with employment decisions, users should additionally be aware of and ensure compliance with the following as applicable to their jurisdiction:

Second Opinion is currently available to Microsoft 365 tenants based in the United States, United Kingdom, Canada, Australia, New Zealand, and Singapore. Data processing occurs exclusively within Microsoft Azure's East US 2 region regardless of the tenant's home country.

Pansophy AI does not provide legal advice. Organizations should consult qualified legal counsel to assess compliance obligations specific to their jurisdiction and use case.

7. Security Controls

8. Alignment with Microsoft Responsible AI Principles

Pansophy AI is built on the Microsoft Azure platform and is designed in alignment with Microsoft's six Responsible AI principles:

Fairness

Descriptive outputs only. No individual is ranked or rated relative to others. Recommendation, ranking, or rating language about the individual is programmatically excluded.

Reliability & Safety

Operates exclusively within the Microsoft Azure sovereignty boundary. Outputs include contextual framing to support accurate interpretation.

Privacy & Security

All data remains within the user's Microsoft tenant. PII scrubbing applied prior to external processing. AES-256 encryption at rest.

Inclusiveness

Onboarding materials disclose limitations for non-native English speakers and diverse communication styles.

Transparency

This Policy and the onboarding flow disclose the nature, capabilities, and limitations of the AI system to all users before first use.

Accountability

Human oversight required for all consequential decisions. Ongoing monitoring of outputs for bias and accuracy. Annual policy review.

9. In-Product Transparency Disclosure

Pansophy AI provides AI-use transparency through the Microsoft platform's AI-generated labeling on every agent response, the agent's in-session explanation of what it does, and the following transparency disclosure published in this Policy:

This opinion is based solely on word patterns in the provided text using a validated language scoring model. The system has no access to and does not process any demographic or PII information about the subject. This opinion is intended as one input among multiple documented factors in any decision made, including an employment decision. Second Opinion does not make recommendations or judgments about the individual; it only suggests how you might approach the conversation. We challenge your assumptions and confirm your hunches.

The agent also explains how the analysis works on demand at any time, for example when asked "How does this analysis work?"

10. Policy Governance and Updates

This Policy is reviewed and updated at least annually and whenever material changes are made to the Software's AI capabilities. The current version is available at this URL.

Revision history. v1.0 (21 April 2026) — initial release. v1.1 (28 July 2026) — clarified that the Software makes no recommendation or judgment about the individual being analyzed and may suggest how the user should approach or address them.

Questions regarding this Policy or requests to exercise data subject rights should be directed to:

Pansophy AI Inc. Responsible AI Office

privacy@pansophyai.com

pansophyai.com