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Nodl AI Transparency & EU AI Act Disclosure

As of: 11 June 2026
Provider: ex-nihilo GmbH, Effingergasse 18/2-3, 1160 Vienna, Austria


1. Purpose of This Page

This page explains how Nodl uses artificial intelligence, which content is AI-generated, what limitations exist, and which obligations users should observe when using Nodl.

This page serves in particular transparency towards users and conversation partners as well as preparation for transparency obligations under the EU AI Act.


2. What Is Nodl?

Nodl is an AI-native voice-to-document platform. Users can record spoken content or upload audio files. Nodl generates transcripts from it, distinguishes speaker segments, and creates structured documents such as meeting notes, task lists, summaries, or other Markdown documents.

Nodl is an assistance system. Results must be reviewed, corrected, and approved by users.


3. Where Does Nodl Use AI?

Nodl uses AI in particular in the following steps:

Step AI use Result
Live transcription preview Preliminary real-time transcription during recording Live preview, not authoritative
Batch transcription Subsequent transcription of the entire recording Stored transcript with timestamps
Speaker separation Technical assignment of segments to different speakers Speaker labels such as “Speaker 1”, “Speaker 2”
Document creation Transformation of the transcript into structured documents Markdown documents, meeting notes, task lists, etc.
Contextualisation Use of recording timestamp and output type Better structure, relative date references, formatting

Nodl currently does not generate synthetic voices, voice clones, images, videos, or deepfakes.


4. AI Models Used

The specific model versions used may change where required for quality, security, availability, cost, or legal requirements.

Purpose Provider / Model Status
Live and batch transcription Mistral / Voxtral — batch: voxtral-mini-latest; live preview: voxtral-mini-transcribe-realtime-2602 EU processing where technically/contractually configured; no training with customer data; zero-data-retention or comparable setting where available
Document creation Google / Gemini — gemini-3.1-flash-lite EU processing where technically/contractually configured; no training with customer data; zero-data-retention or comparable setting where available

Nodl does not use customer data, audio, transcripts, prompts, or documents to train its own AI models. Under the current technical and contractual settings, the AI service providers used are also not permitted to use this data for model training.


5. Which Content Is AI-Generated or AI-Assisted?

With Nodl, the following content is in particular AI-generated or AI-assisted:

  • live transcription preview,
  • stored transcripts,
  • speaker labels and speaker segments,
  • timestamps and segment boundaries,
  • structured documents,
  • summaries,
  • task lists,
  • extracted decisions, names, dates, deadlines, or other structured information.

Original audio is not AI-generated. It is stored as an original source created or uploaded by the user.

Nodl should indicate in the product through appropriate notices that transcripts and documents were created with AI assistance. Regardless of presentation in the UI: all transcripts and documents generated by Nodl are to be treated as AI-assisted work products and reviewed before use.


6. Original Audio as Reference Source

Original audio may be stored unchanged as a reference source where the user or customer uses or configures this function. It then serves for comparison with transcripts and generated documents — not as legal proof provided by Nodl.

Nodl may create technical derivatives, such as normalised audio files, waveforms, transcript segments, and metadata. These derivatives do not alter the stored original audio.

Storage of original audio does not mean that Nodl guarantees the legal evidential value, permissibility, or completeness of a recording in every proceeding. Users are themselves responsible for lawfully recording conversations, informing participants, and using recordings only where permitted.


7. Human Review and Responsibility

Nodl is not intended to make decisions without human review.

Users must in particular review:

  • whether the transcript is correct,
  • whether speakers were correctly separated,
  • whether names, numbers, deadlines, and dates are correct,
  • whether summaries omitted important points or weighted them incorrectly,
  • whether tasks, responsibilities, and deadlines are correct,
  • whether the document is suitable for the specific purpose,
  • whether legal, medical, tax, employment law, or other professional requirements are met.

Nodl does not replace professional advice or professional approval.


8. Known Limitations and Error Risks

AI-assisted transcription and document creation may contain errors. Typical risks include in particular:

  • incorrectly understood words,
  • missing or incorrect punctuation,
  • confusion of names or technical terms,
  • incomplete or incorrect speaker separation,
  • hallucinations or additions by the language model,
  • incorrect interpretation of context,
  • inaccurate summaries,
  • incorrect date or deadline interpretations,
  • omission of important details,
  • distortion due to poor audio quality, accents, dialects, background noise, or multiple people speaking simultaneously.

Original audio may serve as a reference source for comparison where needed.


9. No Automated Decisions Concerning Users

Nodl does not make solely automated decisions that produce legal effects concerning users or similarly significantly affect them.

Technical processes such as free plan limits, usage counting, rate limits, security checks, or abuse protection are not professional decisions about persons but serve contract performance, system security, and fair use.

If an account is restricted due to suspected security or abuse, the user may contact support.


10. No Emotion Recognition as Product Purpose

Nodl is not designed as an emotion recognition system.

If a person says in a recording that they are sad, angry, ill, stressed, or happy, that statement may appear in the transcript or document. This is a reproduction of the content of the recording. However, Nodl is not designed to detect, evaluate, classify emotions of persons, or derive decisions from them.


11. No Biometric Identification or Categorisation

Nodl uses speaker separation to technically distinguish different speakers within a recording. The purpose is better readability and structuring.

Nodl is not intended for:

  • identifying persons by their voice,
  • creating voiceprints,
  • recognising speakers across different recordings,
  • authenticating persons,
  • forming biometric categories,
  • deriving protected characteristics from voice or speech.

Users may not use Nodl contrary to this intended purpose for biometric identification or categorisation.


12. No Use for Model Training

Nodl does not use customer data to train its own AI models.

Audio, transcripts, prompts, documents, and other customer data are not transmitted to AI providers so that they can train their models. For the AI services used, non-training and zero-data-retention or comparable settings are intended where technically and contractually available.


13. Healthcare and Other Regulated Use Cases

Nodl does not generally prohibit use in healthcare. Healthcare providers and other regulated users decide themselves whether and under what conditions they may use Nodl.

However, Nodl is:

  • not a medical device,
  • not a diagnostic system,
  • not a therapy system,
  • not an emergency system,
  • not a clinical decision support system,
  • not a substitute for professional review,
  • not legal, tax, medical, or compliance advice.

Anyone using Nodl in medical, legal, tax, employment law, financial, security-critical, or other regulated contexts remains fully responsible for legal basis, consents, professional secrets, documentation obligations, retention obligations, deletion obligations, professional review, and human approval.


14. Transparency Towards Conversation Partners

Users are responsible for lawfully informing conversation partners when conversations are recorded, transcribed, analysed, stored, or processed with AI. Depending on country, context, and industry, express consent may be required.

This applies in particular to:

  • meetings,
  • customer conversations,
  • advisory conversations,
  • employee conversations,
  • patient conversations,
  • confidential conversations,
  • conversations with minors,
  • cross-border communication.

Nodl provides technical functions. Lawful use in the specific conversation context lies with the user.


15. Publication of AI-Generated Texts

If users publish Nodl-generated texts, in particular on matters of public interest, they are themselves responsible for required notices, labelling, editorial review, and legal requirements.

Nodl recommends clearly marking published or externally shared documents as AI-assisted where relevant in the respective context or legally required.

A sensible label might be:

This document was AI-assisted created with Nodl from an audio recording and human-reviewed.

For internal working documents, a shorter label may suffice:

AI-assisted draft. Please review before use.


16. Recommended UI and Export Labelling

For robust transparency, Nodl should support at least the following notices in the app and in exports:

  • notice after recording: “Transcript and document are created with AI assistance and may contain errors.”
  • notice on the document: “AI-assisted draft. Please review before use.”
  • export metadata or Markdown header where technically sensible, e.g.:

yaml ai_assisted: true created_with: "Nodl" source_type: "audio_recording_or_upload" transcription_model_batch: "voxtral-mini-latest" transcription_model_live: "voxtral-mini-transcribe-realtime-2602" document_model: "gemini-3.1-flash-lite" human_review_required: true

These notices should not be understood as a substitute for legal review but help with transparency, traceability, and AI Act readiness.


17. Contact

Questions about AI use, transparency, security, or the EU AI Act may be directed to:

ex-nihilo GmbH
Effingergasse 18
1160 Vienna
Austria
Email: [email protected]


18. Changes to This Page

This page may be updated when models, providers, functions, legal requirements, or technical labelling change.

How Nodl processes personal data is described in the Privacy Policy. The contractual terms of use are set out in the Terms of Service.

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