AI Model Register
A complete register of third-party AI providers used by October Health, maintained in accordance with the EU AI Act and ISO 42001.
OpenAI
Models
Deployment contexts
Purpose within October Health
- Luna conversational AI (emotional support, check-ins)
- Ash coaching and L&D content generation
- HR document summarisation
- Assessment analysis
- Image generation for in-product and content illustration
- Content moderation and safety classification
Data processing
| Property | Value |
|---|---|
| Training opt-out | Yes (contractual) |
| Conversation logging | Disabled |
| Data retention | Zero retention |
| DPA in place | Yes |
| International transfers | Standard Contractual Clauses (SCCs) |
EU AI Act risk classification
Limited Risk (EU AI Act)
Hiring-support features using OpenAI models are classified High Risk and subject to additional human oversight.
Google Gemini
Models
Deployment contexts
Purpose within October Health
- Ivy AI Dietitian — nutritional advice and meal planning
- Multimodal document understanding
- Workplace Wellbeing Benchmark analysis
- Fallback provider during primary-provider outages
Data processing
| Property | Value |
|---|---|
| Training opt-out | Yes (contractual) |
| Conversation logging | Disabled |
| Data retention | Zero retention |
| DPA in place | Yes |
| International transfers | Standard Contractual Clauses (SCCs) |
EU AI Act risk classification
Limited Risk (EU AI Act)
Nutritional advice is presented as informational; clinical dietary decisions remain with registered professionals.
October Health does not share user conversation content with any third-party AI provider for the purpose of model training. This is enforced contractually via Data Processing Agreements with each provider and verified during our quarterly audit cycle.
All providers listed above have confirmed in writing that October Health data is excluded from their training pipelines. We use API-tier access with zero data retention, ensuring that conversation content is not stored beyond what is necessary for immediate processing.

