Terms of Service

1. These terms

These Terms of Service (Terms) are a legal agreement between you and Genesis Chain Financial Group Pty Ltd (ABN 48 625 098 937, ACN 625 098 937) trading as CreditPolicy.ai and CreditPolicy.com.au (we, us, our).

By creating an account, starting a trial, subscribing (on the web or through an app store), connecting an AI assistant to our MCP server, installing our browser extension, emailing a question to our answer address, or otherwise using the Service, you agree to these Terms. If you do not agree, do not use the Service.

If you are agreeing on behalf of a company, brokerage, aggregator or other entity, you represent that you have authority to bind that entity, and "you" means that entity.

If you are a broker's client using a Client Portal, section 10 is the part of these Terms that applies to you.

Our Privacy Policy forms part of these Terms.

2. Definitions

Service: the CreditPolicy web application, the Client Portal, the Mobile App, the MCP server at https://creditpolicy.ai/api/mcp, the Extension, ask by email, our APIs, integrations, documentation and support.

Policy Library: the indexed collection of lender credit policy documents, guides, calculators and related materials made searchable or available through the Service.

Output: any answer, summary, comparison, assessment, serviceability result, extracted fact, citation, score, list, generated document, filled form or other material produced by the Service in response to your input, including AI-generated text.

Your Content: anything you submit to the Service, including questions, dictation, scenario details, notes, client records, deal records, documents you upload or email in, and anything your clients provide through a Client Portal you send them.

Client Data: personal or business information about your clients that forms part of Your Content.

Client Portal: the branded Fact Find and document-collection pages the Service lets you send to a client, including a self-serve link you publish.

Mobile App: the CreditPolicy app for iPhone and Android.

Extension: the CreditPolicy Form Filler extension for Chrome.

Connected Assistant: a third-party AI assistant, agent or developer tool that you authorise to access the Service via MCP, such as Claude, ChatGPT, Perplexity, Cursor or Visual Studio Code.

Credits: the usage units that meter AI actions in the Service, as described on our pricing page.

Consumer Law: the Australian Consumer Law in Schedule 2 to the Competition and Consumer Act 2010 (Cth).

3. What the Service is, and what it is not

Read this section carefully. It defines the limits of what we do.

3.1 An information tool

The Service is a research, information-retrieval and workflow tool. It searches published lender credit policy material and uses artificial intelligence to summarise, compare and present that material with citations; it organises client information you and your clients provide; and it produces documents, calculations and filled forms from that information for you to check.

3.2 We are not a credit licensee and we give no credit assistance

We do not hold an Australian Credit Licence and we are not a credit representative. We do not engage in credit activities, provide credit assistance, act as an intermediary, suggest or assist you or any consumer to apply for a credit contract, or arrange credit, within the meaning of the National Consumer Credit Protection Act 2009 (Cth).

The Service is software provided to licensed professionals. You are the credit licensee or credit representative. You are responsible for your own compliance obligations, including responsible lending and best interests duty obligations, preliminary assessments, identity verification, record keeping and disclosure.

3.3 Not advice

Nothing in the Service or in any Output is:

• credit advice, financial product advice, legal advice, tax advice or accounting advice;
• a recommendation that any credit product is suitable, appropriate or not unsuitable for any person;
• a statement of a lender's actual credit decision; or
• a commitment, approval, pre-approval, indication or guarantee that any lender will accept a scenario, an application or an applicant.

3.4 Lender policy changes and errors

Lender credit policies change frequently and without notice, differ between channels, aggregators and accreditation levels, and are frequently subject to unpublished overlays, discretions and exceptions. The Policy Library reflects the documents we have indexed as at the version and date shown, and may be incomplete, superseded or wrong.

You must independently verify every Output against the lender's current policy document and, where the matter is material, with the lender directly, before relying on it or communicating it to a client. The lender's own assessment governs. We are not responsible for a lender declining a deal, withdrawing a product, changing policy, or applying a policy differently from how it is described in the Policy Library.

3.5 AI outputs

Outputs are generated in part by large language models. These systems are probabilistic. They can produce text that is inaccurate, incomplete, internally inconsistent, out of date, or that appears authoritative while being wrong, including fabricated citations, misattributed policy positions, misread figures and misplaced form fields.

We are not responsible for any mistake, omission, hallucination, stale or incomplete citation, ranking error, fabricated policy position, misread document or other error in any Output.

You acknowledge that:

• Outputs must be treated as a starting point for your own professional judgement, never as a substitute for it;
• you will apply human review to every Output before acting on it or passing it to a client, a lender or a licensee;
• you have the skills and licensing to evaluate the Output; and
• the Service does not make, and must not be used to make, automated decisions about any individual without human review.

3.6 Serviceability, calculators and extracted facts

Serviceability results are indicative. They are computed from the figures in the client file (which may have been read from documents by AI and may be wrong), from our understanding of each lender's published assessment rules, and from lender calculators as at the version we hold. They are not a lender's assessment and may differ from it. Facts extracted from documents must be checked against the source document. An identity check performed by the Service is a document comparison, not a Document Verification Service, biometric or credit check, and it does not satisfy your own verification-of-identity obligations on its own.

3.7 No guarantee of outcome

We do not warrant that use of the Service will result in any application being approved, any deal being funded, any time being saved, or any commercial outcome being achieved. Any figures we publish about time savings, accuracy or coverage are estimates and general in nature.

3.8 We do not represent any lender

We are not the agent, broker, partner, representative, employee or spokesperson of any lender whose material appears in the Policy Library. Listing a lender, ingesting their PDF or calculator, or citing their policy does not create any relationship with that lender. We take no responsibility for any lender's actions, inactions, delays, discretions, unpublished overlays, withdrawn products, credit decisions, conduct or communications.

3.9 Use in proceedings

You must not present any Output as our evidence or expert report, or state that "CreditPolicy said" something, in any court, tribunal (including AFCA) or licensee process, without our prior written consent. You may of course keep and produce your own records of what you relied on.

4. Eligibility and accounts

To use the Service you must be at least 18, and be a licensed Australian mortgage or finance broker, a credit representative, or an employee, contractor or authorised staff member of one. Your clients use the Client Portal under section 10 and do not need an account.

You must:

• provide accurate registration information and keep it current;
• keep your sign-in credentials, login codes, personal keys and Connected Assistant tokens confidential, and not share your account;
• be responsible for all activity under your account, including activity by your staff, by any Connected Assistant you authorise, by the Extension in your browser, and by anyone who emails from your account address; and
• notify us immediately at security@creditpolicy.ai of any suspected unauthorised access.

Accounts are for named individuals. Seats may not be shared or rotated between people. Where your plan includes multiple seats, you are responsible for your users' compliance with these Terms, and the account owner may add and remove users and will see what the team shares.

We may accept or decline any registration, trial or subscription request in our discretion, and will tell you if we do.

Licensing and insurance. You must hold and keep current any credit licence or credit-representative authority, and any professional indemnity insurance, required for your work. We do not supply these. If you lose or cease to hold them, we may suspend or terminate your access.

Deleting your account. You can delete your account at any time from Account in the Mobile App or at creditpolicy.ai/delete-account. The Privacy Policy explains what is deleted and when.

5. Trials, subscriptions, fees and billing

Trial. We may offer a free trial, with or without a promo code. Trials are for evaluation, are limited to one per person or business, and may be modified or withdrawn at any time. Unless you cancel before the trial ends, your subscription begins and the first payment is charged. We tell you the trial end date when you start, and it is shown in your account settings.

Subscription. Subscriptions renew automatically for successive periods (monthly or annually, as selected) until cancelled. Fees are stated on our pricing page and at checkout, are in Australian dollars and include GST unless stated otherwise.

Payment on the web. You authorise us and our payment processor (Stripe) to charge your nominated payment method for all fees, including renewals. We are the merchant of record. If a payment fails we may retry it, tell you, and suspend access until it is paid. We do not store full card numbers.

Subscriptions bought in the Mobile App are governed by section 11 and billed by Apple or Google, not by us.

What you are paying for. The fee is for access to the software platform as provided: the ability to sign in, search the Policy Library, use AI-assisted retrieval, and use account features, within the Credits and limits of your plan. It is not for any particular answer, approval, time saving or commercial outcome.

Delivery of access. The Service is a digital service. Delivery occurs when we activate your account and you can sign in, whether or not you use every feature or submit a deal.

Cancellation. You can cancel at any time from your account settings, or by written notice to hello@creditpolicy.ai. Cancellation takes effect at the end of the current billing period and you keep access until then. Except where the Consumer Law requires otherwise, fees already paid are not refundable, and we do not provide pro rata refunds for partial periods or unused seats. Cancelling in your account or by written notice is the way to stop future charges.

Payment disputes and chargebacks. If you believe a charge is wrong, contact us first at hello@creditpolicy.ai and we will look into it promptly. Nothing in these Terms prevents your bank or card network from processing a dispute where their rules permit it. We will contest a dispute we consider unjustified, and may provide evidence of account creation, sign-ins, usage and access availability. While a disputed amount is unpaid we may suspend access; if a dispute is decided in our favour, the fee remains payable together with the dispute fee the card network charged us. Disagreement with an Output, a lender decision, a missing lender or a change of mind is not a basis for a chargeback, because what you paid for is access, which was provided.

Price changes. We may change our subscription fees from time to time. If we increase the subscription fee for your existing plan, we will give you at least 30 days' advance written notice by email to the address on your account, stating the new fee and the date it applies from. A price increase will not apply before both (a) the 30-day notice period has expired and (b) your next subscription renewal; if your next renewal falls inside the notice period, the increase applies from the following renewal. You may cancel before the increased price is first charged, without any fee or penalty, and keep access until the end of the period you have paid for. If you do not cancel, your subscription renews at the new price and you authorise us and Stripe to charge it. Nothing in this clause limits your rights under the Consumer Law.

Credits and usage charges. In addition to subscription fees, the Service meters AI actions in Credits, and may offer included allowances, prepaid packs and usage-based charges for API, MCP, in-app actions, form fills, document processing and similar work (together, Meters). Published rates on our pricing page or in-app are the rates that apply. We may introduce, change or withdraw a Meter, allowance or included usage. If a change increases what you pay for usage you already have access to, we will give at least 14 days' notice by email or in-app before it applies, and you may cancel before it applies; a new optional feature with its own Meter can be introduced without notice because you choose whether to use it.

New mandatory fees. If we introduce a new mandatory fee for an existing plan that previously included the relevant usage, we will give at least 30 days' written notice and the change will take effect from your next renewal. If you do not accept it, you may cancel before it takes effect.

Credits and expiry. Unused Credits, allowances or prepaid packs expire at the earlier of the end of the applicable period or any expiry stated at purchase, and are not refundable except where the Consumer Law requires otherwise.

Usage records. Our records of usage (logs, Credit, call, task and compute counts, device data and sign-in times) are evidence of the usage incurred and the amounts payable unless you show they are wrong. Usage charges are payable when consumed and may be charged as they occur or in arrears.

Set-off. You must pay all amounts due in full without set-off, counterclaim, withholding or deduction, except as required by law or agreed by us in writing.

Limits and enforcement. We may throttle, queue or rate-limit usage (including API keys, MCP connections and Connected Assistants) if you exceed the limits of your plan or if payment for usage fails. Usage charges are part of what you are paying for once the usage has been provided.

Taxes. You are responsible for any taxes other than taxes on our income.

Promo codes and offers. A promo or discount code can be used once per person or business, applies only as described when it is published, cannot be combined with another offer unless we say so, and may be withdrawn at any time. We may reverse a trial or discount obtained with a code you were not eligible for.

Referral programme. If we offer referral rewards, a reward is earned only when the broker you referred is a genuinely new customer who completes their trial and pays their first regular monthly subscription invoice; the reward is a credit against an eligible monthly renewal, not cash, and is not a permanent discount. Self-referrals, duplicate accounts and referrals of existing customers do not qualify, and we may reverse a reward obtained through them. Rewards may be changed or withdrawn for future referrals at any time; rewards already earned are honoured. The in-app referral page states the current reward.

6. Licence to use the Service

Subject to these Terms and payment of applicable fees, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable licence to access and use the Service for your internal business purposes as a broker, and to let your clients use the Client Portal for the finance matter you are handling for them.

7. What you must not do

You must not, and must not permit anyone else to:

1. resell, sublicense, rent, lease, share or otherwise make the Service or the Policy Library available to any third party, including other brokerages, unless we agree in writing;
2. scrape, crawl, bulk-export, systematically download, index or otherwise extract the Policy Library or any substantial part of it, whether manually, by script, by API or through a Connected Assistant;
3. use the Service or any Output to build, train, fine-tune, evaluate or improve any machine learning model, dataset, index or product that competes with the Service;
4. reverse engineer, decompile, disassemble or attempt to derive the source code, models, prompts, retrieval logic or architecture of the Service, except to the extent this restriction is void under law;
5. circumvent or attempt to circumvent any usage limit, rate limit, access control, authentication mechanism, watermark or security feature, or probe or test the Service for vulnerabilities without our written consent (report anything you find to security@creditpolicy.ai instead);
6. use the Service to provide a substantially similar service to third parties, or to operate a bureau, agency or "policy answers" service for non-subscribers;
7. submit content that is unlawful, infringing, defamatory, malicious, or that you do not have the right to submit, or send a Client Portal to anyone who is not your client or who has not asked you to act;
8. upload malware, or interfere with, overload or disrupt the Service or its infrastructure;
9. misrepresent an Output as a lender's decision, as advice from us, or as coming from a licensed source;
10. use the Service for any consumer-facing automated credit decisioning;
11. use the Service in breach of any law, licence condition, aggregator requirement or professional obligation that applies to you;
12. do anything that degrades, delays, overloads or interferes with the Service for other users, including runaway Connected Assistants, MCP loops, bulk scraping, concurrent job floods or scripts that repeatedly request the Service; or
13. use the Extension, the webhook export or DocuSign sending to submit, send or sign anything on behalf of a person who has not authorised you to do so.

We may monitor use for compliance with this section, and may rate-limit, suspend or terminate accounts that breach it.

8. Your Content and Client Data

Ownership. You retain all rights in Your Content. We claim no ownership of it.

Licence to us. You grant us a non-exclusive, worldwide, royalty-free licence to host, store, copy, transmit, display and process Your Content solely to provide, secure, support and improve the Service, and as described in our Privacy Policy. This licence ends when Your Content is deleted, subject to backups and legal retention.

Your warranties. You represent and warrant that:

• you own or have all necessary rights and consents to submit Your Content and to send a Client Portal to each client you send it to;
• your submission and our processing of Your Content will not breach any law, any third party's rights, or any obligation you owe to a client, lender, aggregator or licensee;
• you have complied with the Privacy Act in collecting Client Data and in disclosing it to us, to any Connected Assistant you authorise, to DocuSign, to a webhook destination you configure, and to a bank-statement provider you link, including giving APP 5 notice and obtaining any consent required under Part IIIA of the Privacy Act; and
• you will not submit sensitive information or credit information beyond what is reasonably necessary.

Tax File Numbers and identity documents. Do not type a Tax File Number into the Service anywhere. Documents uploaded through the Client Portal are scanned and any visible TFN is covered before the document is saved, and a document whose TFN cannot be covered is rejected; that protection does not extend to numbers you type into notes, chat or forms. Upload identity documents only where the lender or your own verification obligations require them.

Deletion. You can archive or delete client files and records in the application, and delete your account. On termination, we handle your data as set out in the Privacy Policy.

Aggregated and de-identified data. We may generate and use aggregated, de-identified statistics about use of the Service (for example, which policy topics are most queried). This data does not identify you, your clients or your brokerage, and we may use and publish it without restriction.

Responsibility for Client Data. We act as your service provider processing Client Data on your instructions. You remain responsible for the accuracy and lawfulness of Client Data you choose to submit (including via a Connected Assistant or a Client Portal), for giving required APP 5 notices, for any consents required under Part IIIA and the Privacy (Credit Reporting) Code, and for all outcomes for your clients. We are not liable for any loss, misuse or regulatory action arising from Client Data you chose to submit or collect.

Records and retention. The Service is not your compliance file. We do not warrant that chats, Outputs or uploads will be retained for your AFCA, ASIC or licensee record-keeping. You must keep your own records, and the application lets you export a client file at any time. We may delete data after termination as set out in the Privacy Policy.

Exports you direct. When you export a client file to a webhook, send a form through DocuSign, or let a Connected Assistant read or write a file, you are directing the disclosure and the recipient's own terms apply to it.

9. Connected Assistants and the MCP server

You enable it, you own the consequences. Connecting a third-party AI assistant to the Service is optional and entirely at your election. When you authorise a Connected Assistant:

• you grant it access to the Service on your behalf, using scoped OAuth credentials or a personal key, and you are responsible for everything it does under that authorisation;
• the consent screen names the assistant, where it will send you back to, and every tool it will be able to use, including the ones that change your client files and the one that emails a client their portal invitation; by approving it you authorise all of those actions when the assistant takes them;
• data returned by the Service into that assistant, including policy excerpts, comparisons, assessments and your own client and deal records, leaves our platform and is thereafter governed by that provider's terms and privacy policy, not ours;
• that data may be retained in your chat history with the provider, processed outside Australia, logged, or reviewed by that provider consistent with its own policies; and
• you are responsible for satisfying your own privacy, confidentiality and professional obligations before disclosing Client Data to any Connected Assistant.

We do not control third-party assistants. We do not endorse them, do not warrant their behaviour, availability, security or accuracy, and are not liable for their acts or omissions, for their handling of data you send them, or for outputs they generate using our data. The consent screen warns you when an assistant proposes to send you back to a host we do not recognise; treat that warning seriously.

Instruction risk. AI agents can be manipulated by content they process, including through prompt injection in documents, web pages and emails. You must not rely on a Connected Assistant to take consequential actions, such as sending a portal to a client, without your review.

Tokens and keys. You can revoke an assistant's token or a personal key at any time in Settings. We may limit the number of live keys and the rate of requests.

We may change or withdraw MCP access. We may modify, rate-limit, suspend or discontinue the MCP server, any tool it exposes, or access for any particular assistant or client, at any time, with or without notice.

Runaway usage. If a Connected Assistant loops or burns Credits, that usage is yours, subject to the limits of your plan. We may end the assistant's session, revoke its access or cut off traffic to stop it.

Directory listings. Where the Service is listed in a third-party directory or app store (for example the Claude connector directory or the ChatGPT app directory), that listing does not create any relationship between you and us other than under these Terms, and the directory operator is not a party to these Terms.

10. The Client Portal and your clients

10.1 For brokers

The Client Portal lets you collect a Fact Find, documents, an address, a bank-statement step, messages and signed disclosures from your client under your branding. When you use it:

• you are the one collecting the information, for the finance matter you are handling, and we provide the portal as your service provider;
• you must give your client the privacy notice the law requires, and have any consent you need, before or when you send the invitation; switching on the disclosures step shows them a collection notice in your name, but the obligation is yours;
• the Credit Guide and Privacy Consent shown in the disclosures step are your documents; you are responsible for their content and for whether they satisfy your licensee and the law;
• an electronic signature captured in the portal is recorded with the time and IP address; whether it is sufficient for a particular document under the Electronic Transactions Act 1999 (Cth), its state equivalents or a lender's requirements is for you to decide;
• an illion BankStatements link you add is a link to illion's service under your own illion account and terms; we do not receive the statements and only record that your client said they completed the step;
• a self-serve link you publish creates a client file for whoever uses it; you are responsible for where you publish it and for what you do with files it creates; and
• you must not use the portal to collect information from anyone who is not your client, or for any purpose other than the finance matter.

10.2 For clients using a portal

If your broker has sent you a CreditPolicy portal link, these terms apply to your use of it:

• the portal is operated by us for your broker; your broker is the one asking for the information and the one you are dealing with, and your broker's own terms and privacy policy apply to how they use it;
• you must only provide information and documents that are yours or that you are entitled to provide, and they must be true and complete to the best of your knowledge, because your broker and a lender will rely on them;
• you must not upload anything unlawful, malicious or that infringes someone else's rights;
• the one-time code emailed to you is for you alone; do not share it;
• if you choose to sign a document in the portal, you agree that your typed or drawn signature, with the time and IP address recorded, is your signature on that document;
• the bank-statement step, if offered, takes you to illion's service, where illion's terms apply;
• we provide the portal as is for your broker; we do not give you advice, we do not assess your application, and nothing in the portal is a lender's decision; and
• the Privacy Policy, section 11, tells you what happens to your information and how to ask about it.

11. The Mobile App and app-store subscriptions

The Mobile App is licensed, not sold, to you under these Terms. Apple and Google are not parties to these Terms, are not responsible for the Mobile App or its content, and have no obligation to provide support or maintenance for it; they are third-party beneficiaries of this section and may enforce it. You must comply with the terms of the app store you download it from.

In-app subscriptions are bought from, and billed by, Apple or Google, at the price shown in the store, and renew automatically through the store until cancelled in your store subscription settings at least 24 hours before the end of the current period. Refunds for in-app purchases are handled by Apple or Google under their policies; we cannot issue them. A subscription bought in the app gives the same access as the equivalent web plan, and the credits, limits and cancellation rules of section 5 otherwise apply.

Device features. Face ID, Touch ID or your device unlock can lock the app; the check is done by your device and we never receive biometric data. The camera, photo library and microphone are used only when you choose to attach a photo or dictate. Your session is stored encrypted on the device. Keep your device secure; anyone who can unlock it and the app can use your account.

Updates. We may update the Mobile App, require you to install an update to keep using it, and withdraw it from an app store.

12. The Extension, ask by email and other channels

Extension. The Extension fills web forms in your browser from a client file when you ask it to. It runs only on sites you allow, reads a page only when you press Fill or Next, and never presses a Submit, Lodge, Apply, Pay or similar button, never ticks a declaration, consent or privacy box, and never answers a consent question. Everything it types is for you to check before you submit the form, and you are responsible for every field you submit to a lender, licensee or client. Lender and aggregator websites are not ours and may have their own rules about automated filling; comply with them. The Extension is a beta feature under section 14.

Ask by email. You can email a question to our answer address from the address on your account. We only answer messages whose sender authentication aligns with your account address, but email can be spoofed and misdirected; do not email identity documents, TFNs or anything you would not want to appear in your saved chats. A reply is an Output and section 3 applies to it.

Document generation and forms. You must check every field and every statement of any document the Service drafts or any PDF it fills before sending it to a lender, licensee or client. We are not the author of any form or document you submit. Wrong, missing or misplaced content is your responsibility.

DocuSign sending. When you send a filled form for signature, we send it through our DocuSign account on your instruction. You are responsible for the content, for the signers you name, and for any requirement that a particular document be signed in a particular way. We may limit how many envelopes you can send.

Team plans. On a team plan, the account owner controls membership and the team shares a brand kit, templates, disclosures and the client files it chooses to share. Each member is bound by these Terms and the owner is responsible for the team's use.

13. Intellectual property

Ours. We and our licensors own all rights in the Service, including the software, the Policy Library structure, index, embeddings and metadata, the prompts and retrieval logic, our trade marks, Jack and our other artwork, and all improvements. Nothing in these Terms transfers any of those rights to you.

Third-party lender material. Lender policy documents, guides and calculators are the property of the relevant lenders. We index, cite and present them for the purpose of information retrieval and analysis. Your licence to use the Service does not grant you any right in that underlying material beyond viewing and using it within the Service for your own broking work, and does not permit you to redistribute lender documents or calculators or to use a lender's calculator outside the terms on which the lender makes it available to brokers.

Outputs. As between you and us, you may use Outputs for your internal broking work and in dealing with your clients and lenders, subject to section 7. Outputs are generated from third-party material and are not warranted to be original or free of third-party rights.

Your branding. You grant us a licence to use the name, logo and colours you give us (or that we derive from your website at your request) to brand your portals, documents and emails to your clients. You warrant that you have the right to use them.

Feedback. If you give us suggestions or feedback, we may use them without restriction or compensation.

14. Availability, support and beta features

We aim to keep the Service available but do not warrant uninterrupted or error-free operation. We may perform maintenance, and may modify, add to or remove features at any time. We will use reasonable efforts to give notice of changes that materially reduce core functionality.

Support is provided by email and in-app chat during Australian business hours. We offer no service level agreement unless we have signed a separate written agreement with you.

Features marked beta, preview or early access (including the Extension and new lender calculators) are provided as is, may be unstable or withdrawn, and should not be relied on for production work without particularly careful human checking.

Fair use and shared infrastructure. We set fair-use, concurrency, rate, Credit, call, task and compute limits and may change them. To protect other users we may throttle, queue, cancel jobs, revoke MCP access or suspend traffic that is harming the Service; doing so is not a breach by us. The Service runs on shared infrastructure, and other customers' use may affect performance. We do not warrant a reserved slice of capacity unless a separate written agreement says so.

15. Suspension and termination

By you. Cancel at any time in your account settings, or delete your account.

By us, for cause. We may suspend or terminate your access immediately, without refund, if you breach these Terms, if payment fails, if we reasonably suspect fraud, security risk or misuse, or if required by law. We will tell you why unless the law or an investigation prevents it.

By us, at our discretion. We may also terminate any account, or decline to continue providing the Service to any person, on at least 14 days' notice to you. If we terminate under this paragraph (rather than for cause), we will refund any prepaid fees for the unused portion of your subscription period, and that refund is your sole remedy for the termination.

Service protection. We may suspend, throttle or limit any account, seat, Connected Assistant, API key or MCP connection, with or without prior notice, where that is reasonably necessary to protect the Service, our infrastructure or other users, and we may isolate or end sessions or jobs so that other customers are not affected. We will restore access once the risk has passed, and if removal is purely for our convenience and you are not in breach, the refund in the previous paragraph applies.

Regulatory status. If you cease to hold the credit licence or credit-representative authority you require, or your professional indemnity insurance lapses, we may suspend or terminate your access.

Effect. On termination, your licence ends and you must stop using the Service, uninstall the Extension and the Mobile App, and revoke any Connected Assistant. You should export anything you need before terminating. Sections 3, 7, 8 (warranties and responsibility), 9, 10, 13, 16, 17, 18, 19, 20 and 23 survive termination.

16. Australian Consumer Law

Nothing in these Terms excludes, restricts or modifies any guarantee, right or remedy you have under the Consumer Law or any other law that cannot lawfully be excluded.

If the Consumer Law applies to you and we breach a consumer guarantee in relation to the Service, which is a service not ordinarily acquired for personal, domestic or household use, our liability for that breach is limited, to the extent permitted by section 64A of the Consumer Law, at our option, to:

(a) resupplying the Service; or

(b) paying the cost of having the Service resupplied.

17. Disclaimers

Subject to section 16, and to the maximum extent permitted by law:

• the Service and all Outputs are provided "as is" and "as available";
• we exclude all warranties, conditions, guarantees and representations not expressly set out in these Terms, whether express, implied, statutory or otherwise, including implied warranties of merchantability, fitness for a particular purpose, accuracy, completeness, currency, non-infringement and quiet enjoyment;
• we do not warrant that the Policy Library is complete, accurate, current or free from error, or that it covers every lender, product, channel or policy position (including any ranking or citation order); and
• we do not warrant that the Service will meet your requirements, satisfy any regulatory obligation you have, or produce any particular result.

18. Limitation of liability

Subject to section 16, and to the maximum extent permitted by law:

18.1 Excluded loss. Neither party is liable to the other for any indirect, special, incidental, punitive or consequential loss, or for any loss of profit, loss of revenue, loss of commission or trail commission, loss of business, loss of opportunity, loss of goodwill or reputation, loss of anticipated savings, loss of data, or the cost of substitute services, however arising, whether in contract, tort (including negligence), statute or otherwise, and whether or not the party was advised of the possibility of that loss.

18.2 Cap. Our total aggregate liability to you for all claims arising out of or in connection with the Service and these Terms is limited to the greater of (a) the total fees you paid us in the 12 months immediately before the first event giving rise to liability, and (b) AUD $100.

18.3 Specific exclusions. Without limiting the above, we are not liable for any loss arising from:

• your reliance on an Output without independently verifying it against the lender's current policy or the source document;
• a lender declining, withdrawing, repricing or reassessing any application, or applying a policy differently from how it is described in the Policy Library;
• any act or omission of a lender (including delays, discretions, overlays or withdrawn products), aggregator, licensee, bank-statement provider, e-signature provider, or of any Connected Assistant or its operator;
• any regulatory action, licence condition, complaint or determination made against you or your personnel (including for responsible lending, best-interests duty, verification of identity, misleading or deceptive conduct, privacy or unlicensed credit activity);
• Client Data you disclosed to a Connected Assistant, a webhook destination or other third party, or collected through a Client Portal without the notice or consent the law requires;
• your breach of the Privacy Act or any obligation you owe your clients;
• any unauthorised access to your account arising from your failure to keep credentials, devices or tokens secure; or
• any failure, change of price or policy, inaccuracy or unavailability of any upstream AI model, hosting, network, storage, payment, app store or other third-party provider (including OpenAI, Google, Anthropic, Stripe, Apple, Google Play, Vercel, Supabase or similar providers).

18.4 Contribution. Our liability is reduced to the extent your acts or omissions, or those of your personnel, caused or contributed to the loss.

18.5 Basis of the bargain. You acknowledge that the fees reflect this allocation of risk, and that we would not provide the Service on these fees without it.

19. Indemnity

To the maximum extent permitted by law, you indemnify us, and our officers, employees and contractors, against all claims, liabilities, losses, damages, fines, penalties and reasonable costs (including reasonable legal costs) brought by or involving any client, lender, aggregator, licensee, regulator (including ASIC, AFCA and the OAIC), court or other person, to the extent they arise out of or in connection with:

• your credit assistance or broking activities, including any advice, recommendation, application or submission you make to a client or lender using an Output;
• Your Content and Client Data, including any claim that it infringes a third party's rights or was collected or disclosed in breach of the Privacy Act, and your disclosure of Client Data to us, to a Connected Assistant or to any other recipient you direct;
• your breach of these Terms or of any law, licence condition or professional obligation; or
• any third party treating an Output as your advice or as our advice because of how you presented it.

This indemnity does not apply to the extent a claim arises from our breach of these Terms, our negligence or our wilful misconduct. It includes our reasonable costs of responding to a subpoena, notice or compulsory process about your use of the Service.

We have no obligation to defend, appear for or represent you in any proceeding, investigation or regulatory action, and use of the Service is not a defence to one; any licence, regulatory or disciplinary outcome is yours. You must not join us to such a proceeding, or claim contribution from us, except where a court directs it or we have agreed in writing.

This indemnity survives termination. We will notify you of any claim, allow you to control the defence with counsel we reasonably approve, and cooperate reasonably at your cost. You may not settle a claim in a way that imposes any obligation or admission on us without our written consent.

20. Confidentiality

Each party must keep the other's confidential information confidential, use it only for the purposes of these Terms, and protect it with at least reasonable care. This does not apply to information that is public other than through breach, was already known, is independently developed, or must be disclosed by law.

We treat Your Content as your confidential information. You treat the Service's non-public features, pricing and documentation as ours.

21. Changes to these Terms

We may amend these Terms from time to time, including to reflect changes to the Service, our pricing structure, our suppliers, the law or our business. We will publish the amended Terms at creditpolicy.ai/terms and update the "Last updated" date.

Changes that are not materially adverse to you (for example clarifications, new features, new sections describing an optional feature, or changes required by law) take effect when published. For changes that are materially adverse to you, we will give at least 14 days' notice by email or in-app notice before they take effect. If you do not accept a change, your remedy is to cancel before it takes effect, and if a materially adverse change causes you to cancel a prepaid annual plan we will refund the unused portion. Continuing to use the Service after a change takes effect means you accept the amended Terms.

Price changes to an existing subscription are governed by section 5 and receive the notice and cancellation rights stated there.

22. Notices

We may give you notice by email to your account address, or by in-app notice. For any increase to an existing subscription fee, we will send notice by email to the email address associated with your account. We may also display the notice in the Service. You must give us notice by email to legal@creditpolicy.ai. Notices are taken to be received on the day sent unless a delivery failure is received.

23. General

Governing law. These Terms are governed by the laws of Victoria, Australia. You and we submit to the non-exclusive jurisdiction of the courts of Victoria and the courts able to hear appeals from them.

Disputes. Before starting proceedings (other than for urgent interlocutory relief), the parties must first attempt to resolve the dispute in good faith by written notice describing the dispute, followed by discussions between senior representatives within 14 days.

Unfair terms. Nothing in these Terms is intended to be an unfair term under the Consumer Law. If a term would be unfair in its application to you, it is to be read down to the extent necessary to protect our legitimate interests and no further, and the rest of these Terms continues.

Force majeure. Neither party is liable for failure to perform (other than to pay money) caused by an event beyond its reasonable control, including internet or provider outages, failures of upstream AI providers, natural disasters, industrial action, or government action.

Assignment. You may not assign or novate these Terms without our consent. We may assign or novate to an affiliate or in connection with a sale, merger or restructure of our business, on notice to you.

Subcontracting. We may use subcontractors and service providers to perform our obligations, and remain responsible for their performance.

Severability. If any provision is unenforceable, it is severed to the minimum extent necessary and the rest continues.

Waiver. A failure or delay in exercising a right is not a waiver of it.

Relationship. Nothing creates a partnership, joint venture, agency or employment relationship.

Entire agreement. These Terms and the Privacy Policy are the entire agreement between you and us about the Service, and supersede all prior representations, other than any fraudulent misrepresentation.

Publicity. We will not use your name or logo as a customer reference without your consent.

24. Contact

Genesis Chain Financial Group Pty Ltd trading as CreditPolicy.ai and CreditPolicy.com.au ABN 48 625 098 937 | ACN 625 098 937 Registered / office: Ground Floor, 100 Douglas Parade, Williamstown VIC 3016, Australia Email: legal@creditpolicy.ai General: hello@creditpolicy.ai Privacy: privacy@creditpolicy.ai Security: security@creditpolicy.ai Victoria, Australia