LEGAL GOVERNANCE & SOVEREIGN PRIVACY // REVISED 2026 // UAE • UK • EU (PORTUGAL)

Institutional Privacy Policy & Terms of Engagement

Clear, binding covenants on client code ownership, strict data sovereignty compliant with UAE Federal Decree-Law No. 45/2021 (PDPL), deterministic AI containment, and zero vendor lock-in across all engineering and architecture contracts.

Last Certified January 15, 2026
Version Standard V4.2 Sovereign
Jurisdictions UAE (PDPL) • UK • EU
IP Guarantee 100% Client Sovereign
AI Containment Zero Telemetry / UAE Enclave

The Four Non-Negotiables of Every Hashed System Contract

Unlike legacy outsourcing firms, we reject intellectual rent-seeking, lock-in wrappers, and data harvesting. These four tenets are irrevocably enshrined in every statement of work.

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ARTICLE I GUARANTEE

100% Client IP Ownership

Full assignment governed by UAE Copyright Law (Federal Law No. 38/2021) and international conventions. You own every line of source code, Dockerfile, Terraform template, and vector configuration immediately upon milestone signoff.

NO VENDOR HOOKS • NO ROYALTIES
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SOVEREIGN STORAGE

Sovereign In-Region Compute

Client records, model embeddings, and customer payloads remain within sovereign UAE boundaries (AWS UAE me-central-1, Azure UAE North, or local UAE Tier-3+ facilities) in strict compliance with UAE PDPL cross-border transfer laws.

GEO-FENCED BY DESIGN
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ZERO FOUNDATION TRAINING

Zero AI Model Retention

We mandate zero-data-retention APIs and self-hosted open-weights LLMs. Your operational prompts, internal schemas, and IP are strictly isolated from foundational model training.

DETERMINISTIC CONFINEMENT
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FINANCIAL RIGOR

Milestone-Based Billing

Predictable fixed-scope sprints with rigorous bi-weekly demos. Capital is disbursed only upon verified automated test pass-rates and production milestone approvals.

NO HIDDEN RETAINERS

Sovereign Data Governance & International Privacy Protocols

Compliant with UAE Federal Decree-Law No. 45/2021 (PDPL), EU Regulation 2016/679 (GDPR), and the UK Data Protection Act 2018. Designed for institutional clients requiring absolute jurisdictional clarity.

BINDING DIRECTIVE

Scope & Responsible Operating Entities

This Privacy Policy establishes how Hashed System and its international affiliates process, secure, and govern proprietary information and personally identifiable data (PII). Depending on your contractual domicile and project jurisdiction, the data controller is formally registered as:

Hashed System Ltd Dubai Silicon Oasis (DSO), Dubai Digital Park, United Arab Emirates.
Hashed System UK Ltd Berkeley Square House, Mayfair, London W1J 6BD, United Kingdom.
Hashed System EU Lda Avenida da Liberdade 245, 1250-143 Lisbon, Portugal.

Our sovereign architecture delivery models guarantee that customer production payloads remain within the contractual sovereignty borders agreed upon in your respective Statement of Work (SOW).

UAE SPECIAL MANDATEUAE PDPL 45/2021

UAE Personal Data Protection Law (Decree-Law No. 45/2021)

Hashed System operates in strict adherence with the UAE Federal Decree-Law No. 45/2021 on the Protection of Personal Data (PDPL) and supervisory guidelines issued by the UAE Data Office. For all projects with GCC and UAE nexus:

Articles 22 & 23 Cross-Border ControlPersonal data and confidential client records are maintained within designated UAE cloud zones unless standard contractual clauses and adequacy safeguards are executed under UAE Data Office directives.
72-Hour Mandatory Breach NoticeAutomated protocol enforcing immediate notification to the UAE Data Office and impacted data subjects within 72 hours of any confirmed security or telemetry incident.
30-Day Statutory DSAR ResolutionFull fulfillment of statutory rights (access, rectification, erasure, and objection) within the mandatory 30-calendar-day statutory limit.
UAE Data Protection Officer (DPO)A dedicated DPO accredited under UAE regulatory frameworks oversees all sovereign engineering architectures and client audits.
DATA INVENTORY

Categories of Information Processed

Hashed System operates strictly under the principle of data minimization. We classify processed data into three non-overlapping tiers:

  • check_circle Account & Commercial Metadata: Authorized signatory names, corporate email addresses, billing coordinates, and communications conducted through institutional advisory channels.
  • check_circle Architecture & Staging Artifacts: Git branches, automated continuous integration logs, test seeds, and synthetic mock datasets utilized for performance verification.
  • check_circle Production Payloads (Client Tenant): Live production records processed within the client’s designated AWS/Azure/GCP VPC or sovereign bare-metal clusters, accessed strictly via zero-trust ephemeral bastions.
COMPLIANCE BASIS

Lawful Bases & Multi-Jurisdictional Regulatory Alignment

All processing operations executed by Hashed System engineers are anchored in rigorous statutory standards:

UAE PDPL (Decree-Law 45/2021)

Execution of contract (Article 4.2), explicit sovereign consent for cross-border engineering collaboration, and alignment with the UAE Data Office regulations.

EU GDPR & UK DPA 2018

Legitimate commercial interest and contractual performance under Article 6(1)(b) & (f). European Standard Contractual Clauses (SCCs) are baked into every non-EU engagement.

SPECIAL COVENANT CONTAINMENT V2.4

Enterprise AI, LLM Prompt Isolation & Vector Data Privacy

As an enterprise systems advisory implementing autonomous AI agents, Retrieval-Augmented Generation (RAG) pipelines, and high-concurrency LLM routers, we enforce categorical engineering safeguards:

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Zero Foundational Model Training Retention No customer prompts, completion outputs, or vectorized chunks are ever retained or utilized to train or fine-tune public base models (e.g., OpenAI, Anthropic, or Meta LLaMA foundation architectures). We bind all external API keys to institutional Zero-Data-Retention (ZDR) service agreements.
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Sovereign Vector Stores (Qdrant / Milvus / pgvector) Embeddings and vector databases are deployed inside customer-controlled VPC environments with dedicated cryptographic keys (AWS KMS / HashiCorp Vault). We never run shared-tenant vector infrastructure across commercial clients.
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Air-Gapped & On-Premise Enclaves For defense, sovereign wealth, and banking clients, we deploy containerized local inference engines via vLLM / TensorRT-LLM inside sovereign data centers with strict physical and network air-gapping.
INFRASTRUCTURE

Third-Party Sub-Processors & Cloud Partners

Hashed System leverages only tier-1 SOC-2 Type II and ISO 27001 certified cloud infrastructure for development staging and internal telemetry. Sub-processors are bound by identical confidentiality and security terms:

Amazon Web Services UAE & EU Regions
GitHub Enterprise SOC-2 Git Repositories
Cloudflare Zero Trust Edge WAF
HashiCorp Cloud KMS Secrets Vault
LIFECYCLE

Data Retention, Ephemeral Staging & Cryptographic Deletion

Staging environments and test databases are subject to automated ephemeral teardown cycles. Upon final milestone handoff and acceptance:

  • done Development branch databases undergo complete cryptographic erasure within 30 calendar days.
  • done All staging credentials, temporary IAM access keys, and Bastion tunnels are revoked with verification audit logs provided.
  • done A formal Certificate of Cryptographic Sanitization is issued by our Lead Security Architect upon request.
SOVEREIGN RIGHTS

Data Subject Rights & Access Requests (DSAR)

Under UAE PDPL (Federal Decree-Law No. 45/2021), EU GDPR, and UK DPA, you retain sovereign ownership of personal records. DSAR requests are resolved within the mandatory 30-calendar-day statutory timeframe in direct coordination with our UAE compliance desk at [email protected].

LEGAL SHIELD

Security Safeguards & Bilateral NDA Protection

Every client interaction is shielded under a reciprocal mutual Non-Disclosure Agreement (NDA). All engineering staff, principal architects, and advisors hold strict background certifications and are bound by bilateral secrecy obligations that survive the termination of commercial engagements indefinitely.

Terms of Service & Master Delivery Standards

Our delivery methodology is built around transparency, verifiable sprint commits, and total elimination of software vendor lock-in.

ARTICLE 01 assignment_turned_in

Work Product Assignment & Git Transfer

Upon clearance of each sprint milestone invoice, Hashed System assigns 100% of the intellectual property, copyright, patentable algorithms, and repository commits directly to the client. We retain no residual claim or backend telemetry hook.

IMMEDIATE IP CONVEYANCE
ARTICLE 02 verified

90-Day Production Defect Warranty

All custom software delivered under fixed-scope contracts is backed by an unconditional 90-day post-launch warranty. Any reproducible deviation from documented functional requirements is remediated at zero additional cost.

SLA INTEGRITY BACKED
ARTICLE 03 vpn_key

Confidentiality & Bilateral Non-Disclosure

All discussions, architecture schemas, financial projections, and proprietary algorithms are protected under mutual non-disclosure covenants enforceable across UAE, English, and Portuguese jurisdictions.

PERPETUAL SECRECY COVENANT
ARTICLE 04 groups

Senior Architect Guarantee

We operate strictly via high-caliber, senior-level principal engineers. We maintain a zero-junior subcontracting policy—every client sprint is managed by named architects with minimum 8+ years distributed systems tenure.

ZERO OUTSOURCED SHELLS
ARTICLE 05 balance

Liability & Consequential Damages

Our liability caps are equitable and tied to the aggregate contract value paid within the preceding 12 months. Standard consequential, indirect, and punitive loss carve-outs conform to DIFC and English Common Law norms.

BALANCED INSTITUTIONAL RISK
ARTICLE 06 account_balance

Dispute Resolution & Arbitration

Disputes are subject to binding international arbitration under the rules of the Dubai International Arbitration Centre (DIAC / DIFC-LCIA) or the High Court of Justice in London, ensuring neutral, enforceable proceedings.

DIFC / ENGLISH COURT JURISDICTION

Local Compliance Guarantees by Registered Entity

Execute Master Services Agreements under the sovereign legal entity best aligned with your corporate treasury, tax residency, and cross-border regulatory demands.

Dubai & GCCUAE HQ
Operating EntityHashed System Ltd (DTEC Freezone, Dubai Silicon Oasis, DIEZ License)Techno Hub 1, Dubai Digital Park, Dubai Silicon Oasis, Dubai, UAE
STATUTORY REGIMES & STANDARDS
verifiedUAE PDPL (Federal Decree-Law No. 45/2021)
verifiedElectronic Transactions & Trust Services Law (Decree-Law 46/2021)
verifiedCommercial Transactions Law (Decree-Law 50/2022)
verifiedCBUAE Cloud & Technology Risk Framework
verifiedDubai Cyber Security Standard (DESC)
DISPUTE FORUM
gavelDIAC Arbitration (Dubai 2022 Rules) or DIFC Courts
Primary CurrencyAED / USD
Tax StatusUAE Corporate Tax & FTA VAT Registered
United Kingdom UK HUB
Operating Entity Hashed System UK Ltd Berkeley Square House, Mayfair, London W1J, UK
STATUTORY COMPLIANCE
verified UK GDPR & Data Protection Act 2018
verified Information Commissioner's Office (ICO)
verified High Court of Justice (England & Wales)
Primary Currency GBP / EUR / USD
European Union EU HUB
Operating Entity Hashed System EU Lda Avenida da Liberdade 245, Lisbon, Portugal
STATUTORY COMPLIANCE
verified EU Regulation 2016/679 (GDPR Strict)
verified CNPD (Comissão Nacional de Proteção de Dados)
verified EU Standard Contractual Clauses (SCCs)
Primary Currency EUR / USD

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