Legal

SLAN Privacy Notice

How we handle your personal data, AI interactions, Memory, cookies, and your privacy rights.

Effective 2026-07-06 · Last updated 2026-07-06


At a glance

This summary gives you the key points. Please read the full notice below for the detail.

  • Who we are: SLAN is an AI-powered learning platform. Human experts contribute their knowledge to help build AI learning assistants, and learners interact with those assistants.
  • What we collect: your name and age, account and contact details, the content of your interactions with our AI assistants, technical/usage data, and — only if you turn it on — a personalised learning "Memory."
  • AI model providers: when you chat with an assistant, your messages are processed by trusted third-party AI model providers under their paid/enterprise terms, under which your content is not used to train their AI models. We do not use your personal data to train AI models.
  • Memory & cookies are opt-in: the Memory personalisation feature and non-essential cookies are off until you consent, and you can change your mind at any time.
  • Analytics about experts: any usage information we make available to experts/course creators is aggregated and does not identify you individually.
  • Where your data lives: your account data and the content you create with us are stored on servers in the European Union.
  • Your choices: you can access, correct, delete, export, or object to the use of your data, and withdraw consent at any time.

1. Who we are and who this notice covers

Nabita FZ-LLC ("SLAN", "we", "us", "our"), a company registered in the Ras Al Khaimah Economic Zone (RAKEZ), UAE, licence no. SFFO0689, registered address Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, UAE, is the data controller responsible for the personal data described in this notice.

  • Privacy contact: privacy@slan.co — Nabita FZ-LLC, Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, UAE
  • Data Protection Officer: not yet formally appointed. Contact privacy@slan.co in the interim. (We review annually under UAE Federal PDPL whether a DPO is required, including for high-risk processing — see Section 1.1.)
  • EU/UK representative (if SLAN has no EU/UK establishment): not yet appointed. Contact privacy@slan.co in the interim.

1.1 Which data-protection laws apply

Because SLAN is based in Ras Al Khaimah (RAK), UAE, and serves users internationally, more than one data-protection law applies, and we comply with each for the users it covers:

  • UAE Federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021), as amended and together with its Executive Regulations — our home regime, overseen by the UAE Data Office. (Note: RAKEZ is a general free zone, not DIFC or ADGM, so the separate DIFC/ADGM data protection regimes do not apply to us — we sit under UAE federal law.)
  • EU GDPR — applies to the extent we offer our Services to individuals in the EU/EEA.
  • UK GDPR — applies to users in the United Kingdom.
  • US state privacy laws (such as the CCPA/CPRA) — apply to users in those states (see Section 10.2).

Where these laws give you similar rights, we apply a single high standard. Where they differ, the rights specific to your location apply.

Note (high-risk processing). Our AI personalisation (profiling) and AI-driven Services may constitute "High Risk Processing Activities" under UAE Federal PDPL, which can require a Data Protection Impact Assessment (DPIA), registration/notification with the UAE Data Office, and possibly a DPO.

This notice applies to two groups of users, and we identify where their treatment differs:

  • Learners — individuals who use SLAN to learn and interact with our AI assistants.
  • Experts / Course Creators ("Experts") — individuals who contribute their professional knowledge and materials that we use to build and operate AI assistants.

It applies to our website, applications, and related services (the "Services").


2. The personal data we collect

2.1 From all users

  • Identity data: your name and age (you must be 18 or older — see Section 12).
  • Account & contact data: email address, login credentials, account settings, and preferences.
  • Technical & usage data: IP address, device and browser information, log data, pages and features used, and similar diagnostic information.
  • Communications: messages you send us (support requests, feedback) and our correspondence with you.
  • Cookies and similar technologies: see Section 9.

2.2 From Learners

  • AI interaction data: the messages, questions, and content you submit to our AI assistants and the responses generated for you.
  • Learning activity: progress, activity, and usage within courses and assistants.
  • Memory / personalisation data (only if you enable it): a short, evolving summary of your learning profile generated from your interactions — see Section 5.

2.3 From Experts / Course Creators

  • Professional profile: name, area of expertise, and any biography or credentials you choose to provide.
  • Contributed materials: the knowledge, documents, and content you submit so we can build AI assistants. You keep the intellectual property in the materials you contribute; we use them only as described in Section 7 and as set out in our Terms.

We do not intentionally collect special-category data (such as health, religious, or political information). Please do not submit such information to the AI assistants unless necessary, and avoid including it in materials you contribute.


Under the GDPR we must have a "lawful basis" for each use of your personal data. The table summarises our main uses.

PurposeWhoData usedLawful basis (GDPR Art. 6)
Create and manage your accountAllIdentity, account dataPerformance of a contract
Provide the Services and AI assistantsAllAccount, AI interaction, usage dataPerformance of a contract
Memory / personalisationLearnersAI interaction data → profile summaryConsent (opt-in; withdraw any time)
Build and operate AI assistants from contributed knowledgeExpertsContributed materials, profilePerformance of a contract
Aggregate, non-identifying analytics and reportingAllUsage data (aggregated/anonymised)Legitimate interests — to understand and improve the Services
Non-essential cookies and similar trackingAllCookie/usage dataConsent (opt-in via cookie banner)
Security, fraud prevention, and service integrityAllTechnical, usage dataLegitimate interests; legal obligation
Communicate with you about the ServicesAllContact dataPerformance of a contract; legitimate interests
Comply with legal obligationsAllAs requiredLegal obligation

Where we rely on legitimate interests, we have assessed that our interests do not override your rights, and you can object at any time (Section 10). Where we rely on consent, you can withdraw it at any time without affecting prior processing.


4. Our AI assistants and third-party AI model providers

When you interact with a SLAN AI assistant, your messages and the content you submit are processed by trusted third-party AI model providers to generate responses.

  • We use these providers under their paid/enterprise terms. Under those terms, your prompts and the AI's responses are not used to train or improve the providers' AI models. This is consistent with the enterprise/paid policies published by major AI providers.

  • We do not use your personal data to train any AI model, and we do not use it to improve our AI for other users beyond the personalisation you control in Section 5.

  • Providers may retain content briefly to detect misuse and keep their services secure, and for legal compliance, as described in their terms.

  • We may change AI model providers over time as technology evolves. We will always select providers that offer comparable data-protection commitments, and we will keep this notice and our sub-processor information up to date.

  • We currently use Google Gemini, Anthropic (Claude), and OpenAI as our third-party AI model providers, each accessed under their paid/enterprise API terms (not free-tier), under which prompts and outputs are not used to train their models by default. If data residency ("zoning") requirements apply to your account or region, this can be arranged on request.


5. The Memory / personalisation feature (Learners)

Memory is an optional feature that personalises your learning experience. It is off by default and only operates if you turn it on (consent).

How it works. When Memory is enabled, relevant messages from your conversations — the same messages already used to answer you — are processed by our AI model provider a second time to generate a short summary of your learning profile (for example, your goals, level, and topics of interest). That summary is stored in your account and used to make future responses more relevant to you.

Your controls. At any time you can:

  • View the information held in your Memory;
  • Edit or correct it;
  • Delete individual items or your whole Memory; and
  • Turn Memory off, which stops new profile information from being created.

Turning Memory off or deleting items does not affect the lawfulness of processing carried out before you did so. We keep Memory data only while your account is active or until you delete it (Section 11).

We design the feature to capture only learning-relevant information and not to infer sensitive personal data.


6. Analytics and usage metrics

We use usage information to understand how the Services are used and to improve them.

  • Any usage information we make available to Experts / Course Creators about how their courses or assistants are used is aggregated and anonymised — for example, total numbers of users, popular topics, or overall completion rates.
  • Experts do not have access to your individual profile, your Memory, or activity that identifies you personally.
  • Aggregated, anonymised statistics that cannot reasonably be linked to you are not "personal data" and may be used and shared to operate and improve the Services.

If/when individually identifiable analytics are ever introduced, this notice will be updated and, where required, your consent obtained.


7. Expert / Course Creator content

If you contribute as an Expert, we process your professional profile and the materials you submit so that we can build and operate AI learning assistants.

  • You retain the intellectual property in the materials you contribute. We use them under the licence set out in our Terms, solely to create and operate the AI assistants (including retrieval-augmented generation).
  • Building an assistant may involve automated, internal processing of your materials to produce intermediate learning structures used by the system. These are generated and used internally to operate the Services.
  • Your personal data as an Expert (name, contact, profile) is handled in accordance with this notice.

Intellectual-property ownership and licensing terms are governed by our Terms, not by this Privacy Notice.


8. Who we share your data with

We do not sell your personal data. We share it only as needed to run the Services:

  • Service providers (processors) acting on our instructions — for example, cloud hosting, AI model providers, payment processing (Stripe), analytics, email delivery, and customer support tools. They are bound by contracts (Art. 28 GDPR) that require them to protect your data. (Note: Stripe acts as an independent controller for some payment and fraud-prevention purposes under its own terms.)
  • AI model providers, as described in Section 4.
  • Professional advisers, auditors, and authorities where required by law or to protect our rights.
  • In a business transfer (merger, acquisition, or reorganisation), subject to this notice.

A current list of our key sub-processors is available at [link / on request].


9. Cookies and similar technologies

We use cookies and similar technologies to operate the Services and, with your consent, to measure usage.

  • Essential cookies are necessary for the Services to function and are always on.
  • Non-essential cookies (such as analytics) are off until you accept them via our cookie banner. You can accept, reject, or change your choices at any time, with reject as easy as accept.

For details of each cookie, its purpose, and duration, see our Cookie Policy.


10. Your privacy rights

10.1 If you are in the DIFC / UAE

Under the DIFC Data Protection Law No. 5 of 2020, you have rights that mirror those below, including the rights to access, rectify, erase, restrict, and port your data, to object to processing, and to withdraw consent. You may lodge a complaint with the DIFC Commissioner of Data Protection. To exercise your rights, contact us at privacy@slan.co.

10.2 If you are in the EU/EEA or UK

You have the right to: access your data; rectify inaccurate data; erase data ("right to be forgotten"); restrict processing; data portability; object to processing based on legitimate interests; and not be subject to solely automated decisions with legal or similarly significant effects. You may also withdraw consent at any time where we rely on it (for example, Memory and non-essential cookies).

To exercise any right, contact us at privacy@slan.co. You also have the right to lodge a complaint with your local data protection supervisory authority. As we do not yet have an EU/EEA establishment, no single lead authority has been designated; you may complain to the supervisory authority in your own EU/EEA or UK country of residence.

10.3 If you are in the United States

Depending on your state, you may have the right to know/access, delete, correct, and opt out of certain data uses, and to be free from discrimination for exercising your rights. We do not "sell" your personal information, and we do not "share" it for cross-context behavioural advertising. To exercise these rights, contact us at privacy@slan.co.

We respond to verified requests within the timeframes required by law.


11. Where your data is stored and how long we keep it

  • Storage location. Your account data and the content you create with us are stored on servers located in the European Union.
  • Access from RAK/UAE. SLAN is based in Ras Al Khaimah (RAK), UAE. Our authorised personnel may access your data from the UAE to operate and support the Services. For EU/EEA and UK users, access from the UAE is an international transfer; because the UAE is not currently covered by an EU/UK adequacy decision, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs). Under UAE Federal PDPL, transfers to the EU rely on the EU's recognised adequate status.
  • AI processing. When you interact with our AI assistants, your messages are processed by our third-party AI model providers under their paid/enterprise terms. Depending on the provider, some of this processing may take place outside the EEA. Where personal data is transferred outside the EEA/UK, we rely on appropriate safeguards such as adequacy decisions or Standard Contractual Clauses, together with the provider's data-protection commitments.
  • You can request more information or a copy of the relevant safeguards by contacting us.
  • Retention. We keep personal data only as long as necessary for the purposes in this notice:
    • Account and profile data — for as long as your account is active, then 90 days after closure (to allow account recovery and fraud/security checks).
    • AI interaction data — 24 months from your last activity, then deleted.
    • Memory data — until you delete it or close your account.
    • Aggregated/anonymised analytics — may be kept indefinitely as it does not identify you.
    • Where we must keep data to meet legal obligations, we retain it for the required period.

12. Children

The Services are intended for adults. You must be 18 or older to use SLAN, and we do not knowingly collect personal data from anyone under 18. If we learn that we have collected data from a person under 18, we will delete it.


13. How we protect your data

We use appropriate technical and organisational measures to protect your data, including encryption in transit and at rest, access controls, and restrictions on internal access. Access to your Memory and personal content is limited by our access controls. No system is completely secure, but we work to protect your information and will notify you and the relevant authorities of a personal-data breach where the law requires.


14. Changes to this notice

We may update this notice from time to time. If we make material changes, we will notify you through the Services or by email and update the "Last updated" date above. Where a change requires your consent, we will ask for it.


15. Contact us

Questions or requests about this notice or your personal data:

  • Email: privacy@slan.co
  • Post: Nabita FZ-LLC, Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, UAE
  • EU/UK representative: not yet appointed (required once SLAN has an EU/EEA learner base — see Section 1.1). Contact privacy@slan.co in the interim.