AI system card and legal-operational risk assessment

System, hazards, controls, residual risk and review criteria.

Code: AND-PUB-14-EN
Document edition: Edition dated 29 July 2026
Effective from: 2026-07-29
SHA-256: 9591ea67230c9c1f0157440c39b772dc6ee8d88ac9e9ccd7915b737685d31555

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Preamble, nature and effect of this document

Niltech Europe S.r.l., with registered office at Via Calmaggiore 5, 31100 Treviso (TV), Italia, VAT No. IT 05614380268 (“Niltech”), adopts this document in order to document system, context, hazards, exposed persons, controls, residual risk, acceptance criteria and suspension conditions.

This document is a corporate transparency and accountability record. It is not a third-party certification, legal opinion addressed to persons other than the company, absolute security warranty or blanket compliance statement; contractual commitments arise solely from the applicable agreements.

The assessment is continuous and records harm scenarios, exposed persons, measures, effectiveness, residual risk and decision. It does not assign an abstract immutable class to the product: legal qualification depends on intended purpose and concrete circumstances.

Personal and material scope

The objective scope includes Andrea AI, its public interfaces and processing strictly connected with the described functions. The commercial website and document library are published on andreaaiagent.com and use Bluehost infrastructure, MySQL and server mail transport. The application is made available through the separate andreaai.net domain on Hetzner infrastructure; Pinecone, Cloudflare, OpenAI and Google Gemini are involved only within the functions and agreements applicable to them.

The relevant operations concern document and image intake and analysis, policy-reading support, estimates and report drafts, case-file organisation, and ESG indicators only where supported by verifiable data. Potential information categories are: contact and prospect data on the website; in the application, case data, documents, images, notes, technical metadata and AI-assisted outputs according to configuration and contract. The actual privacy role, lawful basis and extent of processing depend on the contractual relationship and the lawful instructions of the party determining purposes and essential means.

Definitions and interpretation

“Service” means the Andrea AI functions made available under the agreement.
“Customer” means the legal person or professional entering into the agreement with Niltech.
“Authorised User” means an individual enabled by the Customer to use the Service under its responsibility.
“Customer Data” means data, documents, images, instructions and other content submitted or generated on the Customer’s behalf.
“Assisted Output” means a result produced through automated rules or artificial-intelligence components and subject to the stated controls.
“Further Supplier” means a third party providing Niltech with a technical service relevant to the documented scope.
“Incident” means an event compromising or capable of compromising confidentiality, integrity, availability, authenticity or resilience.
“Business Day” means a day other than Saturday, Sunday or an Italian national public holiday.

Specific duties and safeguards

1. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall decompose the system into verifiable use cases and components. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

2. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall identify harm from error, omission, bias, misuse, data and unavailability. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

3. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall estimate likelihood and impact using stated criteria. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

4. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall associate preventive, detective and corrective controls with each risk. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

5. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall assess effectiveness with tests, samples, results and limitations. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

6. Within its assigned role and without prejudice to the Customer’s responsibilities, Niltech shall accept, mitigate, avoid or transfer risk with owner and due date. The applicable file identifies the owner, scope, dependencies, acceptance criterion and evidence; absent those elements, the safeguard is not treated as demonstrated.

System and context

Andrea AI: document and image intake and analysis, policy-reading support, estimates and report drafts, case-file organisation, and ESG indicators only where supported by verifiable data.

The commercial website and document library are published on andreaaiagent.com and use Bluehost infrastructure, MySQL and server mail transport. The application is made available through the separate andreaai.net domain on Hetzner infrastructure; Pinecone, Cloudflare, OpenAI and Google Gemini are involved only within the functions and agreements applicable to them.

Key risks

inaccurate, incomplete or outdated outputs
over-reliance and improper automation
unnecessary personal or confidential data
bias, loss of context or misinterpretation
unavailability, supplier dependency or hostile use

Controls

Limited intended use, notices, human review, authorised access, source and document revision traceability where available, supplier management, testing and incident reporting reduce but do not eliminate risks.

Residual risk and review

Residual risk ranges from low to high depending on data and decision impact. Uses with legal, financial, insurance or rights effects require approval, enhanced control and, where necessary, suspension.

Review at least every six months and upon any change in model, provider, purpose, data category, incident or requirement.

Scope, audience and status of this document

This document is intended for customers, prospects, authorised users, advisers and control functions needing to understand the Andrea AI scope. Its specific objective is to document system, context, hazards, exposed persons, controls, residual risk, acceptance criteria and suspension conditions. It applies to the stated document revision and date and must be read with the applicable agreement, order, DPA, technical specifications and controlled procedures.

Executed agreements and actually approved configurations prevail in case of inconsistency. Public information describes the control programme; it does not turn optional provider capabilities into Niltech controls or automatically attest legal applicability or satisfaction.

Exceptions, non-conformity and escalation

A deviation is not accepted by custom. The owner records the affected requirement, cause, impact, exposed data and persons, compensating measures, approver, expiry and closure criterion. The exception is reviewed if risk changes or a measure does not work as expected.

Incidents, possible unlawful processing, loss of data control, outputs with severe impact, contractual breaches, unapproved suppliers or unreliable evidence must be escalated without delay. Current Legal and functional scope: The documented scope includes the commercial website, the public library and, where expressly stated, processing connected with the application.

contain risk and suspend the affected phase where needed
preserve evidence, timing, decisions and communications
involve privacy, security, product, legal or management owners as appropriate
resume only after measure verification and documented authorisation

Review, change and improvement

The document is reviewed at least every six months and earlier when purpose, audience, data, GDPR or AI Act role, supplier, model, architecture, location, contractual terms or legal requirements change. Incidents, complaints, failed tests and new vulnerabilities trigger an extraordinary review.

Each review records inputs, participants, decision, changes, superseded evidence, remaining gaps and next date. Material corrections are published without retroactively altering the prior document revision. Contact and requests: info@nil-tech.net.

check change register and related documents
retest affected controls
update manifest, PDF, HTML and hashes
notify recipients where the change affects their rights or duties

Conditional classification conclusion

The described use is not, merely because it concerns insurance matters, the Annex III high-risk use involving risk assessment and pricing in relation to natural persons in life and health insurance. Use for that purpose, for selection, pricing or another decision significantly affecting an individual would be a changed use case and must be classified again before activation.

The conclusion applies only to the described intended use, with auxiliary output and effective human review. It is not a permanent certification: substantial modification or a new purpose may change the role, risk category and duties.

Harm scenarios and affected persons

The assessment considers users, persons mentioned in files, customers, counterparties, professionals and third parties. Risk is not limited to technical malfunction: it includes discrimination, loss of confidentiality, professional error, economic harm, inability to challenge and use of a result out of context.

misinterpretation of a policy, estimate or image affecting case handling
excessive processing of health data, third-party images or fraud information
over-reliance on output, automation bias or failure to escalate uncertainty
unavailability, supplier dependency, attack or manipulation of inputs and instructions

Method, residual risk and decision

For each scenario, the controlled register identifies cause, event, harm, affected person, likelihood and severity under a defined scale, preventive and detective controls, testing, owner and residual risk. A control receives credit only if applicable to scope and supported by evidence; a documentary statement alone does not reduce risk.

Residual risk is accepted, mitigated, transferred or leads to prohibition/suspension by a person with suitable authority. This document does not state a numerical rating or acceptability conclusion without the supporting evidence file.

Allocation of responsibility and reliance limitations

Within its sphere of responsibility, the Customer warrants the lawfulness of submitted data and instructions, user authorisation, suitable lawful bases and notices, and professional verification of outputs. Niltech remains responsible for activities directly under its control and does not assume the Customer’s regulatory, professional or decision-making functions.

Outputs from Andrea AI are auxiliary. Unless expressly agreed and subject to mandatory law, they are not legal advice, an expert determination, insurance decision, liability finding, credit assessment or other reserved professional act. The recipient must examine sources, completeness, consistency and consequences before use.

Nothing excludes liability that cannot lawfully be excluded. Outside those cases, attribution, remedies, limitations and quantification principles follow the applicable agreement, taking account of contributory conduct, mitigation duties and foreseeability under the governing law.

Evidence, review, requests and governing law

Every material assertion must be traceable to a contract, approved configuration, register, minutes, test, log or other reliable evidence. Supplier statements and Niltech controls are kept distinct. Absence of incidents is not, by itself, proof that a measure is effective.

Revisions are dated, reasoned and approved. A later revision does not retroactively alter facts or commitments applicable to earlier periods. Published copies are identified by code, date and cryptographic digest; those elements evidence copy integrity, not the substantive effectiveness of described controls.

Reports, clarification requests, rights requests and complaints may be sent to info@nil-tech.net. Niltech verifies identity and authority where necessary, records the request, responds within applicable periods and communicates any reasoned extension or refusal.

Unless mandatory law or a written agreement provides otherwise, Italian law governs interpretation. The Italian text is controlling; the English translation is provided for convenience.