Privacy Policy

1. Who We Are

This Privacy Policy explains how BASHAN collects, processes, and protects personal information when you visit our website, communicate with BASHAN AI, or submit information for an initial case assessment during our beta testing period.

2. Information We Collect

We collect information that you voluntarily provide to us when using BASHAN, interacting with BASHAN AI, or submitting an initial case assessment. This may include:

• Contact Details: Name and email address, and other contact details where you choose to provide them
• Location and Background Information: Country of residence, nationality, and other relevant location information where provided.
• Business & Investment Information: Details regarding businesses, investments, companies, shareholdings, ownership or management interests, investor status, and alleged financial or commercial loss where relevant.
  
• Case Facts & Chronology: Case facts, dates, events, and background details provided by you.
• Involved Entities: Names of individuals, companies, public authorities, or organisations involved in your matter.
• Documents & Evidence: Uploaded documents, contracts, correspondence, court papers, or administrative records voluntarily submitted.
• AI Conversations: Questions, messages, and information provided during chat or text conversations with BASHAN AI.

Technical Data: Our website and technology providers may process technical information such as IP address, browser or device information, and service logs where necessary to operate and secure the service.

3. How We Use Information

We use the collected information for the following operational purposes:

• To evaluate case inquiries and prepare structured case files, chronologies, and summaries.
• To communicate with you regarding your assessment or beta service updates.
• To answer questions about BASHAN, its services, and case preparation processes.
• To coordinate with independent lawyers, experts, or professional advisers only upon your explicit request and authorization.
• To test, improve, and secure BASHAN platform features and AI workflows during the beta period.

4. Our Lawful Bases for Processing

We rely on different lawful bases depending on why we use your information:‍Article 6(1)(b) UK GDPR — where processing is necessary to take steps at your request before entering into a service arrangement, including responding to and assessing your case enquiry.Article 6(1)(f) UK GDPR — our legitimate interests in operating, securing and improving BASHAN, preventing misuse, and responding to general enquiries, where those interests are not overridden by your rights and interests.Article 6(1)(c) UK GDPR — where processing is necessary to comply with a legal obligation.

Lawful Basis Status: Legal basis to be confirmed before publication. Submitting information does not automatically create valid consent for every type of processing.

5. Sensitive and Criminal Offence Information

In explaining cross-border matters, users may voluntarily provide information concerning sensitive circumstances, such as:

• Health or medical background;
• Criminal allegations, proceedings, or administrative sanctions;
• Detention, imprisonment, or deportation;
• Political or other sensitive personal circumstances.

The appropriate legal basis and any additional conditions required for processing sensitive or criminal offence information Where necessary for the establishment, exercise or defence of actual or prospective legal claims or legal rights, BASHAN may process special category information under Article 9(2)(f) UK GDPR. Where criminal offence data is necessary for legal claims, BASHAN relies on Schedule 1, Part 3, paragraph 33 of the Data Protection Act 2018, together with an applicable Article 6 lawful basis.

6. How BASHAN AI Uses Information

BASHAN AI is an automated intake and structuring tool. BASHAN AI may:

• Ask questions to clarify case background;
• Organise and summarise facts, dates, and evidence;
• Identify missing information required for a structured case file;
• Help produce an initial case assessment;
• Answer general questions about BASHAN, its scope, services, and coordination processes.

BASHAN AI outputs are preliminary and may contain errors or omissions. BASHAN AI does not provide legal advice, make final legal decisions, or guarantee that a matter will be accepted or successful. Any indication that a matter may be suitable for further review is preliminary only.

7. Who We May Share Information With

Information may be shared only with limited categories of recipients where necessary:

• Technology & Infrastructure Providers: Service providers supporting hosting, databases, email, AI processing and other technical functions, subject to appropriate contractual and data protection arrangements.
• Independent Lawyers & Professionals: Independent legal counsel, experts, or professional advisers, shared where appropriate and authorised in connection with your matter.
• Public Authorities: Relevant public bodies or regulators only where disclosure is strictly required by applicable law.

8. International Data Transfers

Some technology providers or professional recipients may process personal information outside the United Kingdom. Where this occurs, BASHAN will consider the applicable data protection requirements and safeguards.

International transfer mechanisms, locations, and contractual safeguards: Transfer locations and safeguards: Details to be confirmed before publication.

Some technology providers or professional recipients may process personal information outside the United Kingdom. Where a restricted transfer occurs, BASHAN will use a transfer mechanism permitted by UK data protection law where required. Further information about applicable safeguards may be requested at privacy@endarison.com

9. Data Retention

Personal information and uploaded documents are retained only for as long as necessary to fulfill beta case assessment requests or meet compliance obligations. BASHAN does not store information indefinitely.

We retain personal information only for as long as reasonably necessary to provide the assessment, consider any requested follow-up, maintain security and audit records, and meet applicable legal or compliance obligations. Information will be deleted or anonymised when it is no longer reasonably required.

10. Data Protection Rights

Depending on the circumstances and applicable data protection law, you may have rights including access, rectification, erasure, restriction of processing, data portability, objection to processing, and withdrawal of consent where consent is relied upon.

data protection rights: To exercise your data protection rights, contact: privacy@endarison.com.

11. Security

BASHAN aims to use appropriate technical and organisational measures to protect personal information against unauthorised access, disclosure, alteration, loss or destruction.

12. Complaints

If you have concerns about how BASHAN handles your personal information, please contact privacy@endarison.com. You may also have the right to complain to the Information Commissioner's Office (ICO), the UK data protection supervisory authority.

13. Changes to the Privacy Policy

This Privacy Policy may be updated periodically to reflect operational, feature, or legal changes during and after the beta period. Updated policies will be posted on our website with a updated date
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14. Contact

For inquiries regarding this Privacy Policy or beta data processing practices, please contact: