— Independent AI regulatory assessment, March 2026
EU AI Act self-classification documented. Article 12 active. Human-in-the-loop by design. Every compliance claim is transparent, auditable, and available for your legal team to verify.
Transparency as a Service.
At Lifetime Oy, we believe that legal clarity is the foundation of industrial trust. Our "Compliance First" architecture is designed to turn complex EU regulations—such as Fit for 55, the EU AI Act, the Digital Services Act (DSA), the EU Data Act, and GDPR—from liabilities into competitive assets for our clients.
Below you will find our complete legal framework, governing our software, services, and commercial relationships. Each policy carries an explicit effective date, last review, and named escalation channel to simplify vendor-risk assessments.
This overview summarises the key legal and compliance controls for Lifetime Group (Lifetime Oy, Finland & DWS IQ Oü, Estonia), the DWS IQ 6 Platform, the Firehorse product line, Lifetime Consulting & Advisory services, and Lifetime Studios services.
| Policy | Applies to | Effective | Last reviewed |
|---|---|---|---|
| 🛡️ Digital Sovereignty | All EU deployments | 28 Jan 2026 | 01 Apr 2026 |
| ⭐ Privacy Policy & GDPR Statement | All visitors & data subjects | 01 Jan 2023 | 01 Apr 2026 |
| ⭐ Data Security Policy | All business partners & clients | 13 Dec 2025 | 01 Apr 2026 |
| ⭐ Data Handling Policy | Internal team & partners | 13 Dec 2025 | 01 Apr 2026 |
| ⭐ Agreement & Project Terms | Enterprise & project clients | 15 May 2024 | 01 Apr 2026 |
| ⭐ DWS IQ Terms of Service | DWS IQ SaaS users | 30 Jun 2024 | 01 Apr 2026 |
| ⭐ Firehorse Terms of Service | Marketing & reporting automation users | 02 Sep 2024 | 01 Apr 2026 |
| ⭐ Lifetime Fleet Terms | Robotics, drone & logistics partners | 12 Feb 2025 | 01 Apr 2026 |
| ⭐ Professional Services Terms | Consulting & advisory engagements | 20 Mar 2024 | 01 Apr 2026 |
| ⭐ Regulatory Notice for Investors | Prospective & current investors | 18 Oct 2024 | 01 Apr 2026 |
| ⭐ Return & Performance Policy | Store & subscription customers | 05 Jan 2024 | 01 Apr 2026 |
| ⭐ Lifetime Group Legal Notices 2026 | Lifetime Oy corporate & group entities | 01 Dec 2025 | 01 Apr 2026 |
| Data Processing Agreement (DPA) | All customers processing Personal Data via DWS IQ | 05 Feb 2026 | 01 Apr 2026 |
| KYA Standard v1.1 — Know Your Agent | BYO agent governance, sandbox isolation, DWS IQ | 09 Mar 2026 | 01 Apr 2026 |
| AI Safety Report 2026 Analysis | Security Research — all AI deployments | 06 Feb 2026 | 01 Apr 2026 |
| Security & Trust | Security architecture, pentest program, responsible disclosure | 18 Mar 2026 | 01 Apr 2026 |
Dates show when each control entered into force and the most recent audit or legal review. Earlier versions remain available upon request.
Lifetime Oy maintains formal documentation of DWS IQ 6's classification under the EU AI Act (Regulation 2024/1689), enforceable from 2 August 2026.
Classification: Limited-Risk AI System EU AI Act 2024/1689
DWS IQ 6 and Firehorse modules are self-classified as limited-risk AI systems under Article 6 and Annex III. They do not qualify as prohibited AI practices (Article 5) or high-risk systems (Annex III categories: biometrics, employment scoring, law enforcement, safety components of critical infrastructure).
Primary function: automating ESG data into auditable compliance dashboards and 2030 simulation models — a decision-support tool, not an autonomous safety-critical actuator.
| EU AI Act Requirement | Our Implementation | Status |
|---|---|---|
| Technical Documentation (Art. 11) | Full system cards, model documentation, and architecture specs maintained in internal governance repository | ✅ Active |
| Record-Keeping & Logging (Art. 12) | Automatic immutable logging of all AI events; 7-year retention; SIEM export available | ✅ Active |
| Reasoning Lineage / Explainability | Every AI decision includes a traceable input → output chain; provenance metadata embedded in all AI-generated reports | ✅ Active |
| Human-in-the-Loop Oversight | No autonomous safety-critical actions; human validation required before any actuation or compliance filing | ✅ By design |
| AI Governance Framework | Internal risk assessment, incident audit trails, autonomy tiers (1–5), and quarterly internal review | ✅ Active |
| Data Sovereignty & GDPR Art. 6 | Private-cloud deployment; EU data residency (FI/DE); all processing bases documented per GDPR Article 6 | ✅ Active |
| Transparency Obligations (Art. 50) | Users are disclosed when interacting with AI-generated compliance reports or automated content | ✅ Active |
| NIS2 Readiness | Incident reporting architecture; 24h early warning to Traficom; final report within 72 hours | ✅ Compliant |
| Third-Party Conformity Assessment | Not required for limited-risk classification; ISO 27001 audit roadmap active (Q3 2026 target) | 🔄 Roadmap |
⭐ Why Your Investment in Lifetime Oy is Secure
⭐ Privacy Policy & GDPR Statement
SAFE Snapshot Updated Q1 2026
Independent research and analysis on AI safety, cybersecurity, and enterprise risk management informing our platform security posture and compliance architecture.
International AI Safety Report 2026 — DWS Field Note New
Security is not a feature — it is the foundation of every DWS IQ deployment. Our security architecture is designed for EU-regulated industries where agent failures have legal, financial, and safety consequences.
| Layer | Technology | Purpose |
|---|---|---|
| Agent Identity | KYA Standard (Know Your Agent) | Cryptographic agent identity, capability gating, fault attribution |
| Behavioral Guardrails | Leash Snap Protocol (< 5ms) | Pre-execution controls enforced before every agent action |
| Trust Scoring | Agent Trust Score (ATS 0–100) | Real-time agent reliability scoring with automatic suspension |
| Forensic Audit | Firehorse Suite | Immutable audit trails, reasoning lineage, 7-year retention |
| Tool Isolation | MCP Colors Framework (RED/BLUE) | Destructive and read-only tools separated to prevent prompt injection escalation |
| Encryption | AES-256 at rest, TLS 1.3 in transit | All data encrypted in storage and during transmission |
| Data Residency | EU-only (Finland / Germany) | No data leaves EU jurisdiction; CLOUD Act exposure eliminated with EU-sovereign options |
npm audit + Bandit/Safety for
Python components
| Standard | Status | Target Date |
|---|---|---|
| GDPR | Compliant | Active since 2023 |
| NIS2 | Compliant | Active — 24h early warning to Traficom |
| EU AI Act | Limited-Risk Certified | Article 12 active; full enforcement Aug 2026 |
| KYA Standard v1.6 | Production-Ready | Q2 2026 launch |
| ISO 27001 | In Progress | Q4 2026 |
| SOC 2 Type II | Planned | Q2 2027 |
We welcome security researchers who identify vulnerabilities in our platform. Please report findings responsibly:
See our security.txt (RFC 9116) for machine-readable security contact information.
Lifetime Oy provides the following disclosures in the interest of full transparency. We encourage prospective customers, deployers, and investors to review these with their own legal and compliance teams before integration.
Our limited-risk self-classification applies to DWS IQ 6 as designed and deployed by Lifetime Oy. Under Article 28 of the EU AI Act, deployers bear independent responsibility for their own use-case risk assessment. If you integrate DWS IQ 6 into operations that may constitute safety-critical infrastructure under Annex III — for example, energy grid control, transport critical infrastructure, or employment-decision systems — a higher-risk classification may apply to your specific deployment, regardless of our provider-level classification.
We have designed DWS IQ 6 with preparatory controls (human oversight, audit trails, risk management tiers) that ease any such reclassification. Contact compliance@lifetime.fi to discuss your specific integration scenario before go-live.
DWS IQ 6 v1.0 launched on 23 February 2026 and is in an active pilot and early commercial phase. Real-world regulatory enforcement of AI Act claims across EU markets will mature after the August 2026 deadline. Enterprise customers should allow for a standard evaluation period. Our SLA (99.5% baseline uptime) and return policy protect your deployment commitment during this phase.
As a limited-risk AI system, no notified-body review or CE marking is required or planned. ISO 27001 certification is targeted for Q4 2026. Internal automated penetration testing (OWASP Top 10 + LLM Top 10) was established Q1 2026 and runs continuously. Annual external third-party pentest is planned for H2 2026 (report will be available under NDA upon request). No independent AI conformity assessment has been conducted to date — this is consistent with the limited-risk regime.
EU AI Act interpretation — particularly for Annex III point 1 (critical infrastructure) and cross-sector industrial AI — is still evolving as the EU AI Office publishes implementation guidance. Lifetime Oy monitors EU AI Office communications and updates its compliance position accordingly. Our governance framework is designed to accommodate regulatory clarifications without architectural rework.
Risto Anton Päärni
dpo@lifetime.fi
Requests processed within 30 days.
legal@lifetime.fi
Contract redlines, SCC questions, notice-and-action.
security@lifetime.fi
24/7 hotline for critical vulnerabilities.
Y-tunnus: 0772407-9
VAT: FI07724079
Laidunmaanraitti 2 A 25
02330 Espoo, Finland
DWS IQ Platform provider
Established Q2 2026
Subsidiary of Lifetime Oy