Privacy Notice

BELMAR RADIOLOGY LIMITED, company number 17047911, trading as The 2A Bank, is the controller of personal information processed through the platform.

Registered office: 71–75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

Contact: belmar.radiology@gmail.com.

• Account email
• Optional display name
• Authentication and account-security records
• Email-verification status
• Access and approval status
• Access source and expiry
• Practice sessions
• Mock attempts
• Answers and scores
• Timings and progress
• Skipped and flagged questions
• Bookmarks
• Spaced-repetition schedules
• Performance summaries
• Feedback reports
• Support correspondence
• Legal-document acceptance records
• Marketing preferences
• Administrative and security audit records
• Account-deletion requests
• MCP OAuth connections
• MCP permissions and revocations
• Limited MCP tool-call audit information (see AI Assistant & MCP below)
• Payment references, purchase records and access entitlements when payments are later introduced
• Technical information reasonably required to secure and operate the service

The 2A Bank does not have access to raw passwords. Passwords are handled by our authentication provider using industry-standard hashing.

The 2A Bank does not currently collect payment-card information. Full card details will not be stored by The 2A Bank when payments are introduced; a payment provider will process card details on our behalf.

Candidates are not asked why they select Custom or Untimed mock timing. Candidates should not enter health or other sensitive personal information into free-text feedback.

Contract — registering and operating candidate accounts; supplying approved beta, complimentary or paid access; saving progress and results; providing practice and mock functions; providing Account Settings; responding to support and account requests; administering future purchases.

Legitimate interests — protecting the platform and question bank; preventing account sharing; detecting scraping, extraction, fraud and misuse; investigating errors and security incidents; maintaining administrative audit records; improving question quality; analysing aggregate product performance; administering the controlled beta; handling disputes and establishing or defending legal claims. Legitimate interests are used only where our interests are not overridden by the candidate's rights.

Legal obligation — complying with tax, accounting, consumer, court, regulatory and other legal requirements.

Consent — optional marketing communications, and any future non-essential analytics or tracking. We do not rely on consent where contract, legitimate interests or legal obligation is the actual basis.

Two separate AI features are available on the platform. The first is an integrated Explain my answer feature that generates a personalised explanation for an eligible question you have completed. The second is an optional connection that lets a compatible external AI service read permitted revision and performance information from your account.

Explain my answer (integrated)

• Processing occurs only when you request an explanation for a specific question.
• Each request may include the question stem and lead-in; answer options; your selected answer; the approved correct answer; the approved explanation; the associated learning point, key discriminator and common pitfall; and the question's category or topic metadata.
• Model usage, token counts, response time and failure information are recorded for reliability, security and cost control.
• The AI request is designed not to include your name, email address, unrelated account information, or another candidate's information.
• Requests are sent through the Lovable AI Gateway and a selected third-party model provider. The current provider may change where the platform configuration changes.
• Only the minimum information required for the requested explanation is sent.
• Generated explanations are cached at the database level for up to 30 days; expired entries are no longer served. Cached rows are not actively deleted on that schedule at present.
• Usage and security records for AI requests are retained for operational and security purposes; no separate deletion period is currently enforced by an automated job.
• The feature is optional. Candidates may continue using the approved editorial explanation when AI is disabled or unavailable.
• The feature does not make decisions about examination results, platform access or any legal or similarly significant matter.

Optional external AI assistant (MCP connector)

• Connecting an external AI assistant is optional and not required to use Explain my answer.
• The 2A Bank does not run or pay for the external AI model.
• Data is shared only when you connect and authorise a compatible external client.
• MCP tools are read-only and scoped to your signed-in account.
• Tools may return performance summaries, revision context and approved feedback relating to questions already answered or revealed.
• Active-mock answers and explanations are not available.
• The full question bank cannot be browsed, searched or exported.
• External AI services operate under their own terms and privacy notices — please review those documents before connecting.
• Connections can be revoked through Account Settings. Revocation blocks future access but cannot remove information already received by an external provider.
• MCP audit records contain the user, client, tool, timestamp, success status and error code. They do not contain question text, answers or AI conversations.

We do not claim that data processed through these features is never retained by a provider, never processed internationally, or never used by a provider for its own model training or evaluation. That depends on the current provider and configuration and is stated only where it has been verified.

• Candidate participation may be facilitated through an Academy, deanery, NHS organisation or other training body.
• The 2A Bank does not routinely disclose identifiable candidate performance to such organisations unless the candidate has been clearly informed and there is an appropriate lawful basis.
• Academy participation does not give the Academy ownership of candidate accounts or platform data.
• Any future institutional reporting must be covered by a separate written arrangement and an updated Privacy Notice.
• Properly anonymised aggregate feedback may be used to evaluate and improve the service.

• Supabase — database and authentication (data processor).
• Cloudflare Workers — application hosting (via our TanStack Start deployment).
• Lovable AI Gateway — routes integrated Explain my answer requests to a third-party model provider on our behalf.
• OpenAI — currently the underlying model provider used through the Lovable AI Gateway for Explain my answer. The specific provider or model may change where the platform configuration changes.
• Candidate-authorised external AI providers, only where the candidate has explicitly connected an MCP client.
• Professional advisers.
• Insurers.
• Courts, regulators and public authorities where legally required.
• Stripe — payment processor for paid access. Stripe processes the transaction, calculates and collects applicable taxes and issues the invoice. The 2A Bank does not receive or store your full payment card details; we only record the Stripe payment reference, amount paid and plan purchased so we can activate and manage your access.
• A transactional-email provider — only after one has been selected and configured. None is configured today.

• Some processors, or candidate-authorised AI services, may process information outside the United Kingdom.
• Appropriate contractual or legal safeguards will be used where required.
• Candidates can request further information through belmar.radiology@gmail.com.
• International users may have additional local rights.

• Active account and learning information — while the account remains open and reasonably required to provide access.
• Closed account — ordinary account and learning data deleted or anonymised within 30 days.
• Residual encrypted backups — removed through normal rotation within 90 days.
• Security and administrative logs — up to 12 months unless required for an investigation or claim.
• Support enquiries and complaints — up to 2 years after resolution.
• Approval, suspension, reset, deletion and MCP security audit records — up to 2 years.
• Marketing-consent and withdrawal records — while relevant and for a reasonable period afterwards to demonstrate compliance.
• Properly anonymised aggregate statistics — may be retained indefinitely.
• Payment, invoice, tax and accounting records — retained for the period required by applicable law after payments are introduced.

Records may be retained longer where reasonably required for fraud prevention, disputes, legal claims or legal obligations.

• Right of access
• Right to correction
• Right to erasure
• Right to restriction
• Right to object to processing based on legitimate interests
• Right to portability where applicable
• Right to withdraw consent (including marketing) at any time
• Right to complain to the Information Commissioner's Office

Rights vary according to the lawful basis and may be subject to legal exceptions. Requests: belmar.radiology@gmail.com.

• We use reasonable technical and organisational protections.
• Row-Level Security, authenticated access and audit controls are used.
• No online service can guarantee absolute security.
• Material changes to this Privacy Notice will be communicated appropriately (for example, on your next authenticated visit).