This AI Usage & Transparency Policy (“Policy”) explains how Goya de Hoog Consultancy, (“the Company,” “we,” “us”), registered with the KVK under number 96682329, uses artificial intelligence (AI) tools across both its education consultancy services and visa consultancy services. This Policy applies to our internal use of AI and to how we disclose AI use to clients, website visitors, and the public, in accordance with Regulation (EU) 2024/1689 (the “EU AI Act”) and the GDPR / Uitvoeringswet AVG.

1. Purpose & Scope

This Policy covers all AI tools used by the Company in the course of its business, including tools used for drafting written content, generating or editing images, scheduling and administrative automation, and any tool that interacts with clients or website visitors.

2. How We Use AI

We use AI-assisted tools to support tasks such as: drafting and refining written content (social media posts, marketing copy, internal documents, and client communications).

We do not currently use AI to dynamically generate real-time chatbot responses to clients or website visitors. Our Facebook messaging replies use fixed template text written and approved by our team, not AI-generated dynamic responses. If this changes in the future, we will update this Policy and add the disclosure required under Article 50(1) of the EU AI Act for direct AI-to-person interaction.

3. Human Oversight

AI tools are used as drafting and productivity aids, not as decision-makers. All AI-assisted content is reviewed, edited, and approved by a member of our team before it is published, sent to a client, or otherwise relied upon. We do not use AI systems to make automated decisions that produce legal or similarly significant effects concerning clients or website visitors.

4. Client Data & Confidentiality When Using AI Tools

Where client information (including project briefs, personal data, or confidential business information) may be used with an AI tool, we take the following precautions:

• We use reputable AI providers and, where available, configurations or plans that do not use submitted content to train the provider's underlying models

• We limit what is shared with AI tools to what is reasonably necessary for the task at hand.

• Sensitive personal data (for example, information relevant to a visa or migration case) is handled with particular care and is not submitted to general-purpose consumer AI tools without a clear necessity and appropriate safeguards. We do not upload personal documents, sensitive personal and financial information to any A.I. platforms of your clients.

• Our use of AI tools is consistent with, and does not override, the commitments made in our Privacy Statement.

5. Disclosure of AI-Generated Public Content

Disclosure of AI-Generated Content In accordance with Article 50 of the EU AI Act:
* Written Content: Because all AI-assisted written materials undergo thorough human review and editorial control before publication (as set out in Section 3), individual text publications do not require explicit AI disclosure labels under Article 50(4).
* Synthetic Media: Should we publish publicly accessible images, audio, or video that are substantially AI-generated or manipulated and could be mistaken for authentic media, we will clearly label them as artificially created.

6. AI Literacy

In accordance with Article 4 of the EU AI Act, we ensure that team members and contractors who use AI tools on behalf of the Company have a sufficient understanding of those tools' capabilities, limitations, and appropriate use, including when human review is required and how to handle client data responsibly when using them.

7. Third-Party AI Providers

We use third-party AI providers for content drafting, image generation, and administrative automation. We select providers based on their data protection terms and reliability, and we review this selection periodically as tools and regulations evolve.

8. Questions or Complaints

For questions about this Policy or our use of AI, contact us at admin@goyadehoog.com. Complaints regarding data protection aspects of our AI use may also be lodged with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens). Complaints regarding AI Act transparency obligations may be directed to the relevant Dutch market surveillance authority once designated.

9. Changes to This Policy

We may update this Policy as our use of AI tools evolves or as EU and Dutch AI regulation develops. The version published on our website is the current version.

Version: 2026/01 — Effective from: 26 Jul 2026

AI USAGE & TRANSPARENCY POLICY