1. Purpose
This policy sets out how Feelin Well (trading name of Full Circle Design) uses artificial intelligence tools in the operation and development of its platform and business. It is intended to satisfy the AI literacy and governance requirements of the EU Artificial Intelligence Act (Regulation EU 2024/1689), which entered into force on 1 August 2024, with the AI literacy obligation under Article 4 applicable from 2 February 2025 and full transparency obligations applicable from 2 August 2026.
Feelin Well is a map-first fitness and wellness directory serving Ireland and the United Kingdom. The platform connects local communities with gyms, studios, personal trainers, therapists, and wellness businesses. This policy documents every AI system currently used in the business, establishes governance responsibilities, and sets out the framework for responsible AI use as the platform grows.
2. Scope
This policy applies to:
- All AI tools and systems used in the development, operation, or administration of the Feelin Well platform
- All AI tools used for content creation, marketing, or business operations
- Any future AI features introduced to the Feelin Well platform that are visible to or affect end users
- Aaron Cowan as the sole current operator, and any contractors, freelancers, or employees engaged in future
3. Definitions
AI system: A machine-based system designed to operate with varying levels of autonomy that infers from inputs how to generate outputs such as predictions, content, recommendations, or decisions that can influence physical or virtual environments (as defined in Article 3 of the EU AI Act).
Provider: An entity that develops or places an AI system on the market under its own name or trademark.
Deployer: An entity that uses an AI system under its own authority in a professional context. Feelin Well currently acts primarily as a deployer of third-party AI tools.
Minimal risk AI: AI systems posing little to no risk to users or fundamental rights. No specific EU AI Act obligations apply beyond Article 4 (AI literacy).
Limited risk AI: AI systems subject to specific transparency obligations under Article 50, including chatbots and AI-generated content.
4. AI Tool Inventory
The following AI systems are currently in use at Feelin Well. This inventory must be reviewed and updated whenever a new AI tool is adopted or an existing tool is discontinued.
Note: All three tools listed above are used internally by the business operator only. No AI system is currently visible to or directly used by end users of the Feelin Well platform.
5. Risk Classification
The EU AI Act establishes four risk tiers. Feelin Well's current AI use falls entirely within the minimal risk category.
5.1 Prohibited AI Practices (Article 5)
Feelin Well does not use and will not use any prohibited AI systems including: subliminal manipulation techniques, social scoring systems, real-time biometric identification in public spaces, emotion recognition in workplace or educational settings, or predictive policing systems. Any future AI feature will be assessed against Article 5 prohibitions before adoption.
5.2 High-Risk AI (Annex III)
Feelin Well does not currently use any high-risk AI systems as defined in Annex III of the EU AI Act. The platform does not use AI to make decisions affecting employment, creditworthiness, access to essential services, education, justice, law enforcement, critical infrastructure, or migration. All listing approvals and administrative decisions are made manually by the operator.
5.3 Limited Risk AI (Article 50)
Feelin Well does not currently operate any AI chatbots, virtual assistants, or AI content generation features that are visible to end users. If such features are introduced (see Section 8), Article 50 transparency obligations will apply and users must be clearly informed they are interacting with or viewing AI-generated content.
5.4 Minimal Risk AI
All three AI tools currently in use (Lovable, Claude, Canva AI) are classified as minimal risk. They are used exclusively for internal purposes by the business operator and do not influence decisions affecting the rights or interests of platform users or third parties. No specific EU AI Act obligations apply to these tools beyond Article 4.
6. AI Literacy (Article 4)
Article 4 of the EU AI Act has been in force since 2 February 2025. It requires all persons working with AI systems to have a sufficient level of AI literacy — meaning knowledge of AI capabilities, limitations, and risks proportionate to their role.
Feelin Well satisfies this requirement as follows:
- Aaron Cowan, as sole operator and the person responsible for all AI use within the business, has developed substantial practical AI literacy through active use of Lovable and Claude in the development and operation of the Feelin Well platform over an extended period.
- This hands-on experience encompasses: understanding how large language models generate outputs and their limitations, recognising when AI outputs require human review and correction, identifying appropriate versus inappropriate use cases for AI tools, understanding the principles of prompt engineering and AI system behaviour, and awareness of AI risks including hallucination, bias, and data handling.
- Aaron Cowan has read and understood this AI Use Policy and the obligations it documents.
- Any contractor, freelancer, or employee engaged by Feelin Well in future will be required to read this policy and confirm their understanding of the AI tools used in the business before commencing work.
Evidence of AI literacy: This policy document, together with the documented history of AI-assisted platform development, constitutes demonstrable evidence of AI literacy for inspection purposes.
7. Governance and Oversight
7.1 Responsibility
Aaron Cowan is the named AI Governance Owner for Feelin Well. All decisions regarding the adoption, use, and discontinuation of AI tools are the responsibility of Aaron Cowan. This responsibility includes:
- Reviewing and approving any new AI tool before adoption
- Maintaining and updating this AI tool inventory
- Ensuring compliance with EU AI Act obligations as they come into force
- Reviewing this policy annually or whenever a material change in AI use occurs
7.2 Human Oversight
Feelin Well maintains human oversight over all consequential decisions. Specifically:
- All business listing approvals and rejections are made manually by the admin user — no automated approval system exists
- All content published on the platform is reviewed before going live
- AI-generated content used in marketing or communications is reviewed and approved by Aaron Cowan before publication
- No AI system makes autonomous decisions that affect user access to the platform or business listings without human review
7.3 Vendor Due Diligence
Before adopting any new AI tool, Feelin Well will review the provider's terms of service, data processing agreements, and any published EU AI Act compliance statements. This review will be documented and retained.
8. Planned Future AI Features
Feelin Well is considering introducing the following AI features to the platform. Each feature must be assessed for EU AI Act compliance, risk classification, and transparency obligations before deployment.
Before any planned feature is deployed, Aaron Cowan will conduct a compliance review against the EU AI Act risk tiers and update this policy accordingly. Legal advice will be sought where any feature is assessed as limited risk or above.
9. Prohibited Practices
The following AI practices are prohibited at Feelin Well regardless of any commercial or operational benefit:
- Using AI systems that employ subliminal techniques to manipulate user behaviour beyond their conscious awareness
- Using AI to exploit vulnerabilities of specific groups including persons with disabilities, elderly users, or minors
- Using AI for social scoring of users or businesses based on personal characteristics or behaviour
- Using real-time biometric identification systems in publicly accessible spaces
- Using AI for emotion recognition of users or employees
- Using AI to make or influence individual decisions affecting access to the platform in a discriminatory manner
- Scraping third-party platforms using automated AI tools in violation of those platforms' terms of service
10. Data Protection and AI
The use of AI tools at Feelin Well intersects with obligations under the General Data Protection Regulation (GDPR) (Regulation EU 2016/679). The following principles apply:
- Personal data relating to Feelin Well users or business customers is not shared with external AI tools for training purposes
- When using Claude or Canva AI for content creation, no real user personal data is included in prompts or inputs
- Lovable has access to the Feelin Well codebase and database schema as required for development. Feelin Well's data processing agreements with Lovable govern how this data is handled
- Any future AI feature that processes personal data will require a Data Protection Impact Assessment (DPIA) under GDPR Article 35 before deployment
- Users will be informed in the Privacy Policy and Terms of Service of any AI systems that process their personal data
11. Incident Management
If an AI system used by Feelin Well produces an output that causes or risks causing harm to a user, a business customer, or a third party, the following steps will be taken:
- Immediately suspend or restrict the use of the AI system responsible
- Assess the nature and scope of the harm or potential harm
- Notify affected individuals in accordance with GDPR breach notification obligations where personal data is involved
- Document the incident, the AI system involved, and the remedial action taken
- Review this AI Use Policy and update the AI tool inventory and risk assessment as required
- Seek legal advice where the incident may constitute a reportable breach under the EU AI Act or GDPR
12. Policy Review
This policy will be reviewed:
- Annually, on or before the anniversary of the date of adoption
- When any new AI tool is adopted by the business
- When any AI feature is introduced to the Feelin Well platform that affects end users
- When material changes occur in EU AI Act obligations or guidance from the European AI Office
- Following any AI-related incident
The review will be conducted by Aaron Cowan as AI Governance Owner. Any material changes to this policy will be recorded with a new version number and date.
13. Contact
Questions about this AI Use Policy? Email support@feelinwell.co.
Feelin Well | Full Circle Design | Ardfinnan, Clonmel, Co. Tipperary, Ireland
Version 1.0 | Adopted 24 June 2026 | EU AI Act (Regulation EU 2024/1689) Compliant
