AI & Data Processing Governance Policy
Effective Date: 27 August 2024
Last Updated: 06 December 2025
Preamble
This AI & Data Processing Governance Policy (“Policy”) constitutes a binding framework governing the design, development, deployment, operation, limitation, and legal positioning of artificial intelligence systems and data processing activities conducted by INSPYR FINNOVATION PRIVATE LIMITED, operating under the brand name Biocog (“Biocog”, “Company”).
This Policy is drafted to withstand scrutiny from regulators, financial institutions, enterprise customers, auditors, investors, and courts across India, the European Union, and emerging markets. It supersedes and replaces all prior AI-related disclosures, summaries, or statements.
0. Legal Characterisation of the Platform
Biocog operates as a digital climate-intelligence and data-processing infrastructure provider. Biocog does not operate as an autonomous decision-making system.
Biocog expressly disclaims classification as a regulated decision-making authority, advisor, verifier, auditor, or certifying body under any jurisdiction.
1. Purpose & Scope
Biocog operates an AI-native climate infrastructure platform that transforms business data into carbon intelligence, ESG signals, and climate-finance enablement.
- Allocate risk between Biocog and counterparties
- Define lawful purposes and boundaries of AI use
- Preserve integrity of proprietary models
- Prevent regulatory misclassification
- Mitigate systemic, operational, and model risks
2. Classification of AI Systems
- OCR for invoice and document ingestion
- Large Language Models for normalization and inference
- Emission foundation models for Scope 1–3 estimation
- Statistical anomaly, fraud, and risk detection systems
- Voice-based AI systems for MSME onboarding
3. Nature of AI Outputs
- Probabilistic estimates based on statistical modeling
- Not deterministic facts or certified measurements
- Not regulatory filings
- Subject to variability from data, models, or regulations
4. Human Oversight & Responsibility
Biocog maintains human oversight over AI system design, monitoring, and improvement.
5. Data Inputs & Quality Dependency
AI outputs are materially dependent on the quality, completeness, timeliness, and accuracy of input data.
Biocog does not independently authenticate, audit, or verify raw data unless expressly agreed in writing.
6. Model Training & Learning
- User data may be used to train and improve models
- Training uses aggregated and anonymized datasets where feasible
- Users may opt out of future training via written request
- Embedded learnings are non-reversible and non-extractable
7. Bias, Error & Drift
AI systems may reflect biases present in training data and may drift due to regulatory, market, or data changes.
8. Prohibited Uses
- Using AI outputs as sole basis for regulatory filings
- Reverse engineering or model extraction
- Training competing systems using outputs
- Misrepresentation as certified or verified results
9. Data Security & Processing Controls
Biocog applies encryption, access controls, environment segregation, audit logs, monitoring, and incident response mechanisms appropriate to processing risk.
10. Third-Party AI & Infrastructure
Biocog may rely on third-party AI tools or infrastructure and disclaims liability for their behavior, outages, or policy changes.
11. Regulatory Alignment
- India Digital Personal Data Protection Act, 2023
- Emerging global AI governance principles
- GDPR and EU AI Act risk-based frameworks (where applicable)
12. Limitation of AI Liability
13. Policy Updates
This Policy may be updated to reflect regulatory, technical, or operational changes. Continued use constitutes acceptance.
14. Contact
For questions or opt-out requests, contact biocog.v1@gmail.com