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MorphCast AI Act Transparency Position

Last updated: July 1, 2026

MorphCast is committed to the responsible development and deployment of Emotion AI technologies.

This page summarizes MorphCast’s current position regarding the European Union Artificial Intelligence Act (EU AI Act), the safeguards implemented across MorphCast products, and the respective responsibilities of MorphCast and its customers.

For a detailed description of how MorphCast Emotion AI works, including capabilities, limitations, training principles, accuracy information, bias considerations, security measures, and governance practices, please refer to:

Beyond the Algorithm: Building Trustworthy Emotion AI

Product Availability

MorphCast products are available globally, including within the European Union.

However, certain functionalities are subject to regional restrictions and technical safeguards designed to address legal and regulatory requirements, including the EU AI Act and applicable privacy laws.

MorphCast continuously monitors regulatory developments and may update product features, territorial availability, technical safeguards, and documentation as requirements evolve.

Protected Regions

For certain jurisdictions identified by MorphCast as Protected Regions, including the European Union, EEA countries outside the EU, Switzerland, the United Kingdom, and China, additional safeguards are applied.

In these regions:

• Emotion AI processing remains local to the user device;

• Emotion AI outputs are not transmitted to MorphCast servers;

• Emotion AI analytics are not collected by MorphCast;

• MorphCast backend systems reject unauthorized transmission attempts.

These safeguards are implemented through a combination of regional pass-key authorization, client-side controls, server-side validation, and inbound analytics rejection mechanisms.

Customer Responsibilities

Customers remain responsible for ensuring that their specific use of MorphCast products complies with all applicable laws and regulations, including the EU AI Act, GDPR, employment laws, consumer protection laws, and any other applicable national requirements.

Where required by applicable law, customers are responsible for providing notices and transparency disclosures, obtaining consent or another lawful basis, conducting any required legal assessments, and ensuring lawful deployment of the technology.

MorphCast prohibits any use of its products for purposes prohibited under applicable law, including uses expressly prohibited by the EU AI Act.

In particular, in the European Union and European Economic Area, MorphCast products must not be used, put into service, or deployed to infer or assess the emotions of natural persons in workplace settings or educational institutions, except where such use is intended for a documented and specific medical or safety purpose permitted by applicable law.

This is an Article 5 prohibited-practices restriction and is separate from the EU AI Act high-risk classification regime under Annex III. Any high-risk obligations that may apply to Annex III systems follow the applicable transition timeline, including any amendments adopted under the EU Digital Omnibus.

Supporting Responsible Deployment Under the EU AI Act

MorphCast provides privacy first Emotion AI technology that runs entirely on the user’s device, without transmitting facial images or biometric data to MorphCast servers.

If you integrate MorphCast into your application or service, you are generally the deployer of the AI system under the EU AI Act. As the deployer, you are responsible for ensuring that your implementation complies with applicable legal requirements, including transparency obligations where they apply.

MorphCast supports these obligations by providing privacy by design technology, technical documentation and implementation guidance.


Provider and Deployer Responsibilities

The following table summarizes the typical allocation of responsibilities.

MorphCast (Provider)Customer (Deployer)
Provides the SDK and APIsIntegrates the SDK into the application
Designs the technology according to privacy by design principlesDefines the purpose of processing
Provides technical documentationInforms end users where required
Provides implementation guidanceObtains consent where required by applicable law
Delivers software updatesEnsures compliance with applicable laws

Developer Compliance Checklist

Before deploying MorphCast within the European Union, you should verify that your implementation:

☐ Clearly informs users that Emotion AI is being used, where required.

☐ Explains which signals are analyzed.

☐ Explains how AI outputs are used within the application.

☐ Does not present AI outputs as objective facts or medical diagnoses.

☐ Does not use MorphCast to infer or assess emotions in workplace settings or educational institutions, except where the use is intended for a documented and specific medical or safety purpose permitted by applicable law.

☐ Obtains user consent where required by applicable law.

☐ Complies with applicable GDPR obligations.

☐ Evaluates whether transparency obligations under Article 50 of the EU AI Act apply to the specific use case.

☐ Evaluates whether any high-risk obligations under Annex III apply to the specific use case, subject to the applicable transition timeline.


Example User Notice

The following example may be adapted to your application.

This application uses MorphCast Emotion AI to estimate facial expression, attention and engagement signals. Processing is performed locally on your device. No facial images are transmitted to MorphCast servers.


Example Consent Notice

Where consent is required under applicable law, a notice similar to the following may be appropriate.

By enabling your camera, you acknowledge that this application uses MorphCast Emotion AI to estimate facial expression and engagement signals. Processing takes place locally on your device. No facial images are transmitted to MorphCast servers.


Important Limitations

MorphCast estimates behavioral and emotion related signals using machine learning models.

The generated outputs:

  • are probabilistic estimates;
  • are not objective facts;
  • should not be interpreted as medical, psychological or legal conclusions;
  • should always be evaluated within the context of the application.

Developers remain responsible for deciding how AI outputs are used within their products.


Transparency by Design

MorphCast has been designed to support responsible AI deployment through:

  • on device processing;
  • no transmission of facial images to MorphCast servers;
  • privacy by design architecture;
  • clear technical documentation;
  • implementation guidance for developers;
  • transparent communication regarding system capabilities and limitations.

Disclaimer
This guide is provided for general informational purposes only and does not constitute legal advice. Customers are responsible for assessing their own compliance obligations under the EU AI Act, the GDPR and any other applicable laws.


This page reflects MorphCast’s current understanding of the applicable framework and may be updated from time to time.