INBULK Artificial Intelligence Policy

1. Purpose and status

1.1. This Policy governs the use of the AI features of the Platform. AI is an auxiliary tool and does not replace the User’s professional judgement. The Platform clearly informs the User when the User interacts with an AI system or receives material generated by it, in the cases and to the extent provided by applicable law.

1.2. AI cannot on its own perform a Legally Significant Action. An Order, Service Request, Bid, Acceptance, document or instruction takes effect only after separate verification and confirmation by an authorised User.

1.3. An AI result does not constitute legal, financial, investment, tax, insurance, trading, logistics or other professional advice.

2. Available features

2.1. The AI features of the Platform may include, in particular:

• answering questions about the Platform’s functionality and assisting with navigation
• providing prompts on workflows, settings and the use of individual Platform features
• searching, summarising and briefly presenting information
• generating drafts of Orders, Service Requests, messages, documents, checklists and other materials
• generating analytical and predictive materials, scoring results and materials relating to anomaly detection
• classifying documents and information, extracting and structuring data, and checking the completeness of documents
• other AI features available to the User through the Platform interface.

2.2. The list of AI features set out in this Policy is not exhaustive and does not mean that they are necessarily available to all Users. The availability of individual features may depend on the country, the User’s role on the Platform, the selected tariff, the available functionality and other conditions of use of the relevant service.

3. Human oversight

3.1. Before using an AI result to take a decision or perform an action, the User must verify the facts, numerical values, dates, currency, details and sources that are material to the relevant operation, and the conformity of the result with the User’s instructions.

3.2. For decisions or actions with heightened legal, financial, operational or security risk, additional verification, additional confirmation by another authorised person (Second Approval) and/or review by a subject-matter specialist applies, depending on the nature of the relevant risk.

3.3. The Platform interface must clearly show the User when the User is interacting with AI, and must distinguish AI-generated material from a system status, a document, a message from the Operator or an action of another User. Where required by law, such content is additionally marked so that the use of AI can be detected automatically.

4. Limits of accuracy

4.1. A result may be inaccurate, incomplete, outdated, biased or fabricated. The absence of a warning is not a guarantee.

4.2. Where sources are shown, the User verifies their currency, completeness and applicability. An AI answer does not turn reference material into a legally binding document.

5. Prohibited data and uses of AI

5.1. The User must not enter, transmit or use through the AI features of the Platform:

• passwords, one-time confirmation codes (OTP), private keys, seed phrases, PIN codes, CVV/CVC codes, full payment details and other secret authentication data
• confidential or other information whose disclosure is prohibited by law, by a non-disclosure agreement (NDA), by rules of professional secrecy, or which infringes the rights of third parties
• special categories of personal data, biometric data for unique identification, data on criminal convictions and offences, or children’s data, except where the relevant AI feature expressly provides for such processing and there is a proper legal basis and the necessary safeguards for it.

5.2. It is prohibited to use the AI features of the Platform for:

• fraud, circumvention of sanctions or other lawful restrictions, creation or distribution of malicious software, manipulation of trading, or other unlawful activity
• taking decisions with material legal, financial or security consequences solely on the basis of an AI result, without proper verification and human oversight
• creating forged or misleading documents, evidence, certificates or other materials, or for unlawful impersonation.

6. Data and third-party providers

6.1. To operate the AI features, the Operator may engage third-party providers of the relevant technology services. Information about the categories of such providers, the purposes and categories of data processed, the countries of processing, retention periods and international transfer mechanisms is set out in the Privacy Policy and, where necessary, in the corresponding register of providers.

6.2. Content that the User transmits through the AI features of the Platform is not used to train publicly available AI models unless that purpose has been clearly communicated to the User before the relevant data is transmitted and there is a proper legal basis for such processing.

6.3. The operation of the AI features may involve processing of the User’s prompts, the context of a request, generated responses, feedback, safety signals and technical logs. Such data is processed only to the extent necessary for the operation of the relevant feature and is retained for a reasonably necessary period.

6.4. The data and content of one User may not be disclosed to another User through the AI features of the Platform without a proper legal basis or another basis expressly provided by law or by the terms of the relevant service.

7. Intellectual property rights and content

7.1. The User retains all rights belonging to it in the content that it enters, uploads or otherwise transmits through the AI features of the Platform. The legal status of materials generated with the use of AI is determined by applicable law, the Agreement and the terms of the relevant service. The Operator does not warrant the uniqueness of such materials, the arising of exclusive intellectual property rights in them, or the absence of rights and legitimate interests of third parties.

7.2. Before publishing, transferring to third parties or commercially using materials generated with the use of AI, the User must independently verify their accuracy, the lawfulness of their use, compliance with third-party intellectual property rights, including rights in trade marks and copyright works, and confidentiality requirements.

8. Scoring, recommendations and automated decisions

8.1. Scoring, ratings, forecasts, matching results and recommendations generated with the use of AI are informational and auxiliary in nature. They are not a guarantee of a counterparty’s reliability, of obtaining financing or insurance, of achieving a particular price or of any other commercial outcome.

8.2. Where an automated result may materially affect the User’s rights, the scope of the User’s access to Platform features or another significant decision, the User is, in the cases provided by applicable law, given proper information about that decision, an opportunity to provide additional information and the ability to request review of the decision by an authorised person.

9. Security and prevention of abuse

9.1. The Operator has the right to automatically detect, filter, restrict or block requests that may create a risk to the security of the Platform, of Users or of third parties, and to record such requests in technical logs. To test the resilience of the AI features, the Operator may also carry out controlled security and abuse-detection testing.

9.2. The User is prohibited from circumventing or attempting to circumvent the security mechanisms, technical restrictions, usage limits, system rules or other controls established by the Platform for the operation of the AI features.

10. Feedback and error reports

10.1. The User may report errors, unsafe or incorrect results, suspected unlawful disclosure of data or any other incident related to the use of the AI features of the Platform to the Operator at [email protected], providing only the information necessary to examine the case.

10.2. User feedback may be used to assess the quality of the AI features, correct errors and improve the functionality of the Platform. Before such use, personal, confidential and other excessive data is deleted or minimised, unless otherwise permitted on a proper legal basis.

10.3. Use of User feedback to train or improve AI models is permitted only in accordance with clause 6.2 of this Policy and with the Privacy Policy.

11. Liability

11.1. The User is responsible for a decision taken on the basis of AI, unless the Operator provided a separate professional service or committed its own culpable breach. The User independently assesses results generated with the use of AI and decides whether to use them. Liability for such decisions and their consequences is determined by the Agreement and applicable law.

11.2. Limits and exclusions are determined by the Agreement. They do not release a party from liability for unlawful disclosure of data or for its own other breaches.

12. Changes to the Policy

12.1. The Operator notifies Users of material changes to this Policy affecting the use of data, the engagement of third-party providers, the level of autonomy of the AI features, the User’s rights or the arrangements for human oversight, before such changes take effect, through the Platform, by email or through another channel provided by the Agreement.

12.2. A notice of material changes must state the date on which they take effect and briefly describe the main changes.

13. Contacts

13.1. The Platform Operator for a particular User is the INBULK Group legal entity named by the Country Addendum applicable to the User’s country of registration and recorded in the User’s Statement of Accession. The current list of the Platform Operators with their registration details, registered offices and contacts is published on the Platform Operators page: https://help.inbulk.com/en/operators .

13.2. For questions relating to the use of the AI features of the Platform, the User may write to [email protected].

13.3. The procedure and conditions for processing personal data are set out in the INBULK.COM Privacy Policy, the current edition of which is available in the “Policies” section: https://help.inbulk.com/policies 

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