Privacy Terms of Service

Legal document · Version 1.0

Terms of Service

Effective from: August 5, 2026Applicable law: [jurisdiction]Provider: [name of legal entity]

Short and to the point

This summary is provided for convenience and does not replace the full text of the document.

Contractual base

1.Acceptance of conditions

These Terms of Service (hereinafter referred to as the “Terms”) govern the relationship between [name of the legal entity] (hereinafter referred to as the “Company”, “we”) and the legal entity or individual entrepreneur registering an account in the AutoAML service (hereinafter referred to as the “Client”, “you”).

By registering an account or starting to use the service, the Client confirms that he has read, understood and accepts these Terms, as well as the related documents: Privacy Policy and Personal Data Processing Agreement (DPA), which are an integral part of these Terms.

The terms are concluded with a legal entity, and not with an individual acting on its behalf; The employee registering the account confirms that he has the appropriate authority.

Legal capacity

2.Account registration

The service is intended for use by organizations that are obligated entities within the meaning of the applicable AML/CFT legislation (real estate agencies, consultants, other small and medium-sized obligated entities), or that provide them with related services.

Customer must provide accurate and current registration information, maintain the confidentiality of access credentials, and promptly notify us of suspected unauthorized access to the account.

Significant limitation

3.Description of the service and its limits

“AutoAML” is software that helps the Client: screen counterparties according to sanctions lists and PEP lists through integrated third-party providers; generate and prioritize alerts; prepare draft risk assessments and suspicious transaction reports (SAR/STR); keep a log and documentation of inspections in a format ready for presentation to the regulator.

The Service is not a substitute for the professional judgment of the Client's compliance officer or MLRO, legal advice, or a guarantee of compliance with AMLR/AMLA requirements. Any content generated by the AI ​​functions of the service (including draft SAR/STR and risk assessments) is of an auxiliary nature and is subject to mandatory verification and approval by an authorized employee of the Client before any use, including submission to the competent authorities.

The Client, as an obligated entity, bears full and exclusive responsibility for the fulfillment of its obligations under the applicable AML/CFT legislation; use of the service does not transfer or share this responsibility with the Company.

Commercial terms

4.Tariffs and payment

Current tariff plans, included check limits and the cost of checks above the limit are published on the service tariffs page and can be changed with notice of at least [30] days for already registered Clients.

  • The subscription is paid in advance for the selected period (month/year), unless otherwise agreed separately.
  • The cost of checks above the included limit is billed based on actual use.
  • Late payment may result in suspension of access to the service after prior notice.
  • Refunds of funds paid are carried out in the cases and in the manner specified on the tariffs page, or in accordance with applicable consumer protection legislation - insofar as it applies to B2B relationships.
Key responsibility of the Client

5.Responsibilities of the Client

  • Upload into the service only data that the Client has the right to process legally (own AML/CFT policy, consent, legal obligation).
  • Ensure that uploaded data about the Subjects of Inspection is accurate and up-to-date.
  • Do not use the service for purposes unrelated to the legal fulfillment of AML/CFT or KYC obligations.
  • Check and validate any AI-generated drafts before using them in external communications or submitting them to regulatory authorities.
  • Comply with applicable data protection laws in relation to Review Subjects, including notifying them of processing if required by law.
  • Do not attempt to circumvent the technical limitations of the service, including API limits and protections against automated abuse.
Link to DPA

6.Processing of personal data

With respect to the data that the Client uploads to verify the Subjects of verification, the Company acts as a processor of personal data on behalf of the Client under the terms of the Personal Data Processing Agreement (DPA) attached to these Terms. The Privacy Policy applies to the Client's account data.

In the event of a conflict between these Terms and the DPA regarding the processing of personal data of Verified Subjects, the DPA shall prevail.

Software rights

7.Intellectual property

All rights to the software, design, trademarks and service documentation belong to the Company or its licensors. Customer is granted a limited, non-exclusive, non-transferable license to use the service during the term of the subscription and solely for Customer's own internal purposes.

Data uploaded by the Client remains the property of the Client; The company does not acquire any rights to them, except for the rights necessary to provide the service.

Mutual confidentiality

8.Confidentiality

The Parties undertake to maintain the confidentiality of unpublished commercial, technical and financial information received from each other in connection with the execution of these Terms, and to use it only for the purposes provided for in these Terms, during the term of the agreement and [X] years after its termination.

Service level

9.Service availability

At the initial stage (MVP and pilot operation), the service is provided on a “best effort” basis without a formally guaranteed level of availability (SLA). Planned maintenance work is announced in advance whenever possible. A formal SLA with guaranteed uptime can be agreed upon separately for corporate Clients.

Dependency on third parties

10.Third-party data and service providers

The Service uses data and functionality from third party screening providers (for example, sanctions list providers, PEP and adverse media, crypto asset screening). The Company uses reasonable efforts to select reliable suppliers, but does not guarantee the completeness, accuracy or timeliness of updates of data provided by such third parties and is not responsible for failures, downtime or errors in data beyond the reasonable control of the Company.

Limitation of liability - part 1

11.Disclaimer of warranties

Except as expressly provided in these Terms or required by applicable law, the service is provided “as is” and “as available”, without warranties of any kind, express or implied, including warranties of fitness for a particular purpose, freedom from errors or full compliance of the service with all AMLR/AMLA requirements in each particular situation of the Client.

Limitation of liability - part 2

12.Limitation of liability

To the maximum extent permitted by applicable law, the Company's aggregate liability to the Client for any reason related to these Terms is limited to the amount paid by the Client for the service for the [3/6/12] months preceding the event giving rise to liability.

The Company is not responsible for indirect, incidental damages or lost profits, as well as for the consequences of decisions made by the Client based on AI-generated drafts without proper verification by an authorized employee, as required by section 3.

Nothing in this section limits liability that cannot be limited under applicable law (for example, liability for intent or gross negligence, where provided by law).

Mutual guarantees

13.Indemnification

The Client undertakes to compensate the Company for losses incurred in connection with the Client’s violation of the assurances about the legality of the downloaded data (Section 5) or use of the service in violation of these Terms, including reasonable costs of legal defense.

Termination of relationship

14.Duration and termination of the contract

  • The contract is valid for the paid subscription period and is automatically renewed unless otherwise agreed or provided for by the selected tariff.
  • Either party has the right to terminate the contract due to a material breach by the other party that is not corrected within [14/30] days after written notice.
  • After termination of the contract, the Client has the opportunity to export account data within [30] days.
  • Data subject to mandatory storage under Art. 77 AMLR (see Privacy Policy, section 6), are retained by the Company for the period established by law, regardless of the fact of termination of the contract, unless otherwise expressly agreed (for example, transferring the archive for storage to the Client himself).
Order of changes

15.Changing conditions

We have the right to change these Terms by notifying the Client at least [30] days before the changes come into force. Continued use of the service after this date is considered acceptance of the updated Terms. If the changes significantly worsen the Client's position, the Client has the right to terminate the contract before the changes come into force.

Jurisdiction

16.Applicable law and dispute resolution

These Terms are governed by the law of [specify jurisdiction, usually the country of registration of the Company], without regard to conflict of laws rules. The parties strive to resolve disputes through negotiations; If no agreement is reached, the dispute is referred to [competent court / arbitration - specify].

For Clients - consumers (if applicable to certain categories of users) mandatory rights provided for by the legislation on their protection at the place of residence are retained, regardless of the choice of applicable law.

Standard provisions

17.Other provisions

  • Force majeure. Neither party is liable for failure to fulfill obligations due to force majeure circumstances.
  • Severability. The invalidity of a particular provision does not entail the invalidity of the remaining Terms.
  • Assignment of rights. The Client has no right to assign rights under the contract without the prior written consent of the Company, with the exception of reorganization within a group of companies.
  • Entire Agreement These Terms, the Privacy Policy and the DPA constitute the entire agreement of the parties regarding the subject matter.
Contacts

18.Contacts

Company[legal name]
Support Email[support@domain]
Email for legal issues[legal@domain]