Legal

A KMI access token is a complete, final sale of a defined right of access: the selected tier's seat allowance and, on tiers that include one, a fixed number of search operations ("the Service Allowance"). This is a purchase of access, not a transfer of money into a stored balance — no sum is held on the purchaser's behalf at any point, only the access right itself. Ownership of that access right passes to the purchaser, and the full price is earned by KMI, at the moment payment is made.

The price paid is not refundable, in whole or in part, once payment is made — including for any portion of the Service Allowance, seats, or access that goes unused. This is a deliberate feature of how the service is sold, not an oversight. A completed sale does not leave any sum owed back by either party: KMI does not hold a balance payable to the purchaser for whatever remains unused, and the purchaser owes nothing further to KMI. Nothing changes hands after the point of sale in either direction.

You are purchasing access — not depositing funds into a credit balance. The purchase is final and non-refundable once made, whether or not the full Service Allowance is used.

Where a tier includes a Service Allowance, it is drawn down one unit at a time as filtered searches are actually performed and return at least one result — never for a search that finds nothing, browsing, viewing a record, or reloading a page already paid for. The Service Allowance carries no expiry date: access continues for as long as any of it remains unused, at the purchaser's own pace. Rotating a token (issuing a replacement, e.g. because a key was compromised) carries the remaining Service Allowance forward exactly as it stood — it neither resets nor reduces it.

Access is provided for as long as the Platform, and Kuwait Mirror Limited itself, continues to operate and offer it — nothing here promises access for any fixed term. KMI may suspend, withdraw, or permanently discontinue the Platform, or any product, tier, or feature within it, in whole or in part, at any time and without prior notice. Where access ends because the Platform or the relevant service is discontinued, no refund, credit, or other compensation is owed for any unused portion of the Service Allowance — see No Refunds above, which applies equally here.

KMI may add, change, remove, or restrict any feature, module, or dataset within the Platform at any time, including after a purchase is made — whether or not that feature was described, displayed, or demonstrated to the purchaser before or at the time of purchase. A purchase under these Terms is a purchase of technical access to the Platform and its database, at the tier selected, not a commitment to keep providing any specific feature, dataset, or piece of functionality on an ongoing basis.

The Platform is provided "as is" and "as available," without warranty of any kind, express or implied, including as to uninterrupted availability, accuracy, fitness for a particular purpose, or security. KMI does not guarantee that the Platform will be free of technical faults or downtime, or free of unauthorised access (a security breach), and does not guarantee that data held on the Platform — including a purchaser's own account, seat, or Service Allowance history — will not be lost, corrupted, or disclosed as a result of such an event. To the fullest extent permitted by law, KMI accepts no liability, and owes no refund, compensation, or other remedy, to a purchaser for loss arising from downtime, a security incident, or data loss, however caused.

The above concerns unused service and events outside anyone's reasonable control, not a case where KMI is clearly at fault for failing to make the Platform available at all (a technical fault on KMI's own side, not the purchaser's decision not to use it, and not a security incident or discontinuation covered above). That narrower case is handled separately as a service-failure matter — contact contact@kuwaitmirror.com.

To the fullest extent permitted by law, KMI's total liability to a purchaser arising out of or in connection with the Platform, however arising, is limited to the amount actually paid by that purchaser for the Service Allowance or seat giving rise to the claim. KMI is not liable for indirect, incidental, special, or consequential loss — including loss of profits, loss of data, or loss of business opportunity — even if advised such loss was possible. Nothing in these Terms limits or excludes any liability that cannot lawfully be limited or excluded, such as for fraud, or for death or personal injury caused by negligence.

If KMI reasonably suspects a subscription is being misused — including, without limitation, sharing a token beyond its licensed seats, attempting to scrape, bulk-export, or systematically reproduce the underlying database, or using the Platform for a purpose outside the eligibility basis under which the subscription was granted — KMI may suspend the subscription, in whole or in part, at its sole discretion and at any time, without prior notice and without compensation or refund of any kind. KMI may likewise reduce, increase, or disable any part of the Service at its sole discretion and at any time, without prior notice and without compensation. A suspension does not, by itself, delete or reduce a subscription's Service Allowance or screening history; restoring access following a suspension is at KMI's discretion.

A token holder may rotate their own token at any time (see the session controls once signed in) — this issues an immediate replacement carrying the same remaining Service Allowance forward; it is not a new purchase. Ending a subscription outright, with no replacement issued, is handled by KMI directly on request and does not create any payment obligation in either direction.

KMI is the Kuwait layer of anti-money laundering and counter-terrorist financing (AML/CFT), know your customer (KYC), know your business (KYB) and enhanced due diligence (EDD) checks. It is a research platform that cross-references sanctions listings; politically exposed persons (PEPs), their family members and close associates; adverse media; criminal proceedings; wanted and travel-ban notices; company ownership, directors and beneficial owners; director disqualifications; offshore-leak records; citizenship-revocation actions; and jurisdiction risk, against a shared subject record. It does not exist to make legal, immigration, or compliance determinations.

Nothing in this system constitutes legal advice, a compliance opinion, or a substitute for professional due diligence. Any decision relying on a record here should be independently verified against primary sources and, where relevant, qualified counsel.

Every record carries a confidence or risk rating and, where available, a link or attached document identifying its source. Records marked "Pending Review" or "Translated" have not been independently verified and should be treated with additional caution. The retrieved_at date on each record shows when it was last checked against its source — a record with no recent review may be stale.

Where possible, entries are sourced from official gazettes, court filings, government decrees, or the published lists of a designating authority (OFAC, OFSI, the UN Security Council, or the EU). Secondary sources (news reporting) are marked as such in the source field rather than presented as primary evidence.

KMI's findings rest on the sources it holds, and every one of those sources is incomplete: a register, a published list or a collection of decisions contains what its publisher has made available, not everything that exists. A search that finds nothing means only that nothing was found in those sources. It is not evidence that no record, appointment, listing, proceeding or decision exists elsewhere, and must not be reported as a clearance. Published records are sometimes revised or withdrawn by their publisher; KMI re-reads its sources on a schedule and relies on the latest published version, and every finding should be verified against the source record it cites before it is relied on.

Company register information (for example, directorships, persons with significant control and director disqualifications on the UK Companies House register) is filed by the companies and individuals concerned. A registrar publishes it but does not generally verify it, and details such as nationality or country of residence are as declared. KMI records a register entry against a subject only after an analyst has confirmed that it concerns that subject — a shared name is never treated as a match on its own — and cites the register page it came from.

Court and tribunal records are reported as the court or tribunal published them, with their date and stage, and are never recharacterised, summarised as a finding the court did not make, or used to predict or influence a judicial outcome. A proceeding that has not concluded is shown with its stage and the presumption of innocence. Where a published decision anonymises a party, KMI does not attempt to identify them, directly or by combining pieces of information from different sources.

KMI uses fixed, documented rules — not machine learning or generative AI. A name is matched to a subject only when the name agrees and an independent detail agrees too (such as a date of birth, an identifier, or a stated nationality); a detail that disagrees rules the match out. Match scores are for triage and are never findings in themselves: nothing enters a subject's file until an analyst has reviewed it. The computed risk score lists every signal it counts and the weight each carries, and is shown separately from the source records it is drawn from.

Names, family names and places of origin are shared by many unrelated people in Kuwait. KMI never infers a relationship, an identity or a characteristic from a name, and does not record tribal or ethnic affiliation. Its matching rules and outputs are reviewed for misleading or discriminatory effects and for errors that repeat across records, which are corrected at their source. Anyone who believes a record is wrong, or wrongly attributed to them, may ask for it to be corrected (see Your UK GDPR Rights below).

KMI's records are not published to search engines and are not browsable: they are returned only in answer to a search for a named subject, by an identified seat with a stated reason, and every search and every opened file is logged. Automated collection or scraping of KMI content is prohibited and is detected and stopped.

Kuwait Mirror Limited, a company registered in England and Wales (Company Number 17431334), is the data controller for personal data processed within KMI.

Any individual described in a record may exercise their rights under UK GDPR — Access (Article 15), Rectification (Article 16), Erasure (Article 17), Restriction (Article 18), or Objection (Article 21) — or simply dispute a record's accuracy, using our Data Subject Request form. We respond within one calendar month of receiving a request (Article 12(3)), and may ask for proportionate identity verification before acting on it. Data portability (Article 20) does not apply here: it only covers data provided to us directly, and none of our records are collected that way. You may also complain to the ICO at ico.org.uk at any time. Records under active dispute are flagged in their notes field pending resolution rather than removed outright, to preserve an audit trail.

Access is restricted to holders of a valid, individually issued access token (see Purchase Terms & Refund Policy). Its contents are confidential and are not for public distribution or republication, in whole or in part, without independent verification and Kuwait Mirror Limited's written consent.

An annual listing fee purchases inclusion on the Register for a defined 12-month period ("the Listing Period"), contingent on admission under the Admission Standard and continued compliance with it. This is a purchase of a right to be listed, not a transfer of money into a stored balance — no sum is held on the applicant's behalf at any point. The full fee is earned by Kuwait Mirror Limited at the moment payment is made.

A member admitted as part of a Founding Cohort offer is listed on a lifetime basis instead — no annual fee is charged or renewed for that listing, and the provisions of this section concerning payment of an annual fee do not apply to them. Founding Cohort status is extended solely at Kuwait Mirror Limited's own invitation; it is not a status an applicant may request, apply for, or otherwise seek to obtain, and no application submitted under the Admission Standard constitutes, or is treated as, a request for it.

Kuwait Mirror maintains a public listing. A listing is not a promise of work: we do not source, allocate or guarantee work for listed members. Where a client asks us for a proposal and names a listed member, or asks us to suggest one, we pass the request on; the member alone decides whether to accept it.

A Register listing is limited to verification and directory publication under the Admission Standard (see What You Are Purchasing above); it does not, by itself, make Kuwait Mirror Limited a party to any instruction a listed member subsequently receives. For each such instruction, the member may elect, at their sole discretion:

• to accept and perform it directly, in which case no fee of any kind is payable to Kuwait Mirror Limited in respect of it; or
• to request Kuwait Mirror Limited's managed service for that instruction, under which Kuwait Mirror Limited handles the engagement contract, invoicing, and cover on the member's behalf, in consideration of a facilitation fee of 3% of the total fees payable to the member under that instruction.

An election of the managed service applies only to the instruction for which it is made; it does not bind the member to elect it for any other instruction, and a member may decline it for every instruction they receive.

The facilitation fee is distinct from, and payable independently of, the annual listing fee described in What You Are Purchasing above. A member listed on a lifetime Founding Cohort basis is exempt from the annual listing fee only; that exemption does not extend to the facilitation fee, which applies to a Founding Cohort member on the same terms as to any other member wherever the managed service is elected.

Any listing fee actually paid is not refundable, in whole or in part, once an applicant is admitted and listed — including where the Listing Period ends early because the applicant is later de-listed for failing to maintain the Admission Standard (see De-listing below), withdraws voluntarily, or the Register or Platform is discontinued (see Service Availability below). This is a deliberate feature of how a paid listing is sold, not an oversight; it has no application to a lifetime Founding Cohort listing, for which no fee is ever charged.

A paid Listing Period is not a guarantee that the Register, or Kuwait Mirror Limited itself, will continue operating for the full 12 months. Kuwait Mirror Limited may suspend, withdraw, or permanently discontinue the Register, in whole or in part, at any time and without prior notice. Where a Listing Period ends early because the Register or Platform is discontinued, no refund, credit, or other compensation is owed for any unused portion of that period — see No Refunds above, which applies equally here.

The Register is provided "as is" and "as available," without warranty of any kind, express or implied, including as to uninterrupted availability, accuracy, or security. Kuwait Mirror Limited does not guarantee that the Register will be free of technical faults or downtime, and does not guarantee that a member's listed data will not be lost, corrupted, or disclosed as a result of a technical fault or security incident.

Admission to the Register verifies the Admission Standard grounds stated on a member's own profile at the time of admission and each annual renewal — it is not a continuous, real-time verification of a member's conduct, competence, or integrity at every moment they are listed. Kuwait Mirror Limited accepts no liability for a listed member's conduct, opinions, or work product after admission, and accepts no liability to any lawyer, law firm, chambers, court, tribunal, academic institution, publisher, or other third party who relies on the Register when selecting or instructing a listed member. The Register is a directory, not an endorsement of, or guarantee concerning, any individual listed on it.

Kuwait Mirror Limited may remove a member's listing from the Register at any time, without prior notice and without refund of any kind, where it reasonably believes the member no longer satisfies the Admission Standard — for example:

• a lapsed professional indemnity insurance;
• an unrenewed conflict-of-interest declaration; or
• a credible complaint concerning the member's professional conduct.

De-listing does not entitle the member to a refund of any part of the Listing Period's fee already paid.

Kuwait Mirror Limited is the controller of the personal data you give us when you apply and while you are listed, under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

What we hold, and why. Your application and profile details, your qualifications, memberships, insurance and documented work, your identity document and signature, your payments, and a record of the checks we make and our correspondence with you. We use them to assess your application and maintain your listing (performance of our agreement with you, Article 6(1)(b)); to verify credentials and keep the Register reliable for those who use it (our legitimate interests, Article 6(1)(f)); and to keep the financial records the law requires (Article 6(1)(c)).

What is public. Only your profile as approved for publication, which we publish with your consent (Article 6(1)(a)). Your contact details, identity document, signature, insurance documents, payments and our record of checks are never published, nor any Coverage selection you chose not to show. You may withdraw your consent to publication at any time; your listing then ends.

How long we keep it. An application that is started but not submitted is deleted automatically. Once you are listed, your record and payment history are kept after the listing ends, so that the Register can show who was listed and when, and for as long as the law requires us to keep financial records.

Your rights. You may ask for a copy of your personal data, its correction or erasure, the restriction of its use, or a copy to take elsewhere, and you may object to its use on the basis of our legitimate interests. We do not sell your data or use it for marketing. We reply within one month. Write to contact@kuwaitmirror.com. You may also complain to the Information Commissioner's Office (ico.org.uk) or to the data protection authority where you live.

Questions about these Terms, an application, or an existing listing: contact@kuwaitmirror.com.