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Export Compliance Policy

Last updated: November 6, 2025

1. Overview

BrainPredict OÜ complies with all applicable export control laws and regulations, including:

  • EU Dual-Use Regulation (EU) 2021/821 - Controls export of dual-use items
  • Estonian Export Control Act - National implementation of EU regulations
  • UN Security Council Resolutions - International sanctions and embargoes
  • EU Sanctions Regulations - Restrictive measures against specific countries/entities

2. Export Classification

BrainPredict AI software may be subject to export controls:

Classification:

  • Category: Dual-use items (software with AI/ML capabilities)
  • ECCN: Under review (AI software classification evolving)
  • Jurisdiction: Estonia (EU member state)

3. Restricted Countries and Entities

BrainPredict services are NOT available to customers in the following jurisdictions:

Embargoed Countries:

  • Cuba
  • Iran
  • North Korea (DPRK)
  • Syria
  • Crimea, Donetsk, and Luhansk regions of Ukraine
  • Any other country subject to comprehensive EU/UN sanctions

Additionally, BrainPredict will not provide services to:

  • Entities on EU Consolidated Sanctions List
  • Entities on UN Sanctions Lists
  • Specially Designated Nationals (SDN) lists
  • Denied Persons or Entity Lists

4. Customer Obligations

By using BrainPredict services, Customer represents and warrants that:

  1. Customer is not located in, organized under the laws of, or owned/controlled by persons in restricted countries
  2. Customer is not on any sanctions list or denied party list
  3. Customer will not use BrainPredict services for prohibited end-uses (weapons development, military applications)
  4. Customer will not re-export or transfer BrainPredict services to restricted parties
  5. Customer will comply with all applicable export control laws
  6. Customer will immediately notify BrainPredict if their status changes

5. Prohibited End-Uses

BrainPredict services may NOT be used for:

  • Weapons Development: Design, development, or production of nuclear, chemical, or biological weapons
  • Military Applications: Direct military or defense applications without proper authorization
  • Missile Technology: Development of missile delivery systems
  • Surveillance: Mass surveillance or human rights violations
  • Terrorism: Any activity supporting terrorism or terrorist organizations

6. Screening Procedures

BrainPredict implements the following screening procedures:

  • Customer Screening: All new customers screened against sanctions lists
  • Ongoing Monitoring: Quarterly re-screening of existing customers
  • Transaction Screening: High-value transactions screened for compliance
  • IP Geolocation: Access blocked from restricted countries

7. Violations and Enforcement

If BrainPredict discovers a violation of export controls:

  1. Immediate Suspension: Account suspended immediately
  2. Investigation: Internal investigation conducted within 48 hours
  3. Reporting: Violations reported to Estonian authorities and EU Commission
  4. Termination: Account permanently terminated without refund
  5. Legal Action: BrainPredict reserves right to pursue legal remedies

8. Changes to Sanctions Lists

Export control regulations change frequently. BrainPredict will:

  • Monitor sanctions lists daily for updates
  • Notify affected customers within 24 hours of new restrictions
  • Provide 7-day grace period for data export (if legally permitted)
  • Suspend access immediately if required by law

9. Contact Information

For export compliance questions or to report violations:

BrainPredict OÜ - Compliance Officer

Email: privacy@brainpredict.ai

Phone: +372 6630414

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Jõe tn 3-314, 10151, Estonia

Registry Code: 17352111