Terms of Service

Last updated: 29 August 2026 · Effective: 1 May 2026

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, connecting an AI assistant to our MCP server, 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.

Our Privacy Policy forms part of these Terms.

2. Definitions

Service — the CreditPolicy web application, the MCP server at https://creditpolicy.ai/api/mcp, our APIs, integrations, documentation and support.

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

Output — any answer, summary, comparison, assessment, citation, score, list or other material generated by the Service in response to your input, including AI-generated text.

Your Content — anything you submit to the Service, including questions, scenario details, notes, client records, deal records and uploaded documents.

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

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.

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 and information retrieval tool. It searches published lender credit policy material and uses artificial intelligence to summarise, compare and present that material with citations.

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, record keeping and disclosure.

3.3 Not advice

Nothing in the Service or in any Output is:

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 or misattributed policy positions.

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

You acknowledge that:

3.6 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.

3.7 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 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.

3.8 Use in proceedings

You must not present any Output as our evidence or expert report, or state that “CreditPolicy said” in any court, tribunal (including AFCA) or licensee process, without our prior written consent.

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.

You must:

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.

We may accept or decline any registration, trial or subscription request in our discretion, and are not required to give reasons for doing so.

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.

5. Trials, subscriptions, fees and billing

Trial. We may offer a free trial. 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.

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

Payment. 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, suspend access, and recover reasonable costs of recovery. We do not store full card numbers.

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. 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. Delivery occurs whether or not you use every feature, like every answer, or submit a deal.

Cancellation. You can cancel at any time from your account settings. Cancellation takes effect at the end of the current billing period. 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.

Stopping future charges. The exclusive way to stop future charges is to cancel in‑account (or to give written notice to hello@creditpolicy.ai or legal@creditpolicy.ai). Cancellation is effective at the end of the then‑current period.

Chargebacks and payment disputes. Opening a chargeback, payment dispute or bank recall after access was provided is a material breach of these Terms. Fees remain due. We will contest any such dispute and may provide evidence of account creation, login, usage, IP/device logs and access availability. We may suspend access immediately, terminate your subscription, and recover the disputed amount plus our reasonable recovery costs (including Stripe dispute fees). You acknowledge that disagreement with an Output, a lender decision, a missing lender, downtime, or a change of mind is not a basis for a chargeback. Nothing in these Terms prevents your bank or card network from processing a dispute where their rules permit it; we will simply contest it. Unpaid fees survive termination.

Price changes. We may change fees on 30 days' written notice, effective from your next renewal. If you do not accept the change, you may cancel before it takes effect.

Published rates and meters. In addition to subscription or seat fees, the Service may have usage‑based charges, including credits, token allowances, included usage, prepaid packs, API/MCP/in‑app call charges, task/job/form‑fill charges, and server/compute/infrastructure charges (together, Meters). We may introduce, change or withdraw any Meter, allowance or included usage at any time. Where an allowance applies, usage in excess of the then‑current allowance is billed at the published rate in force at the time the excess usage occurs. Published rates shown on our pricing page or in‑app are the rates that apply.

Rate changes for usage. We may change Meter rates by publishing the new rate on the pricing page and/or in‑app. Continuing to use a Meter after publication means you accept the new rate. We are not required to maintain historical rates for future usage.

New mandatory fees. If we introduce a brand‑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, tokens, 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 evidence and payment. Our usage records (including logs, token/call/task/compute counts, IP/device data and login times) are prima facie evidence of usage incurred and amounts payable. Extra usage is payable when consumed and may be charged as it occurs or in arrears.

No set‑off or withholding. You must pay all amounts due in full without set‑off, counterclaim, withholding or deduction, and you must not initiate a chargeback to avoid properly incurred fees or overage.

Overage and enforcement. We may suspend, throttle or rate‑limit usage (including API keys, MCP connections and Connected Assistants) if you exceed limits or if payment for overage fails. Extra‑usage charges are part of what you are paying for once access or usage has been provided.

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

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.

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;
  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;
  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; or
  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, token/call/task abuse, or any script that repeatedly requests the Service in a way that hammers our infrastructure;
  13. circumvent, disable or exceed any fair‑use, concurrency, rate, token, call, task or compute limits we set; or
  14. tender any Output as our evidence or expert report, or state that “CreditPolicy said”, in any court, tribunal (including AFCA) or licensee process, without our prior written consent.

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:

Deletion. You can delete client and deal records in the application. 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), 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.

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/licensee record‑keeping. You must keep your own records. We may delete data after termination as set out in the Privacy Policy.

Sensitive information. You must not upload credit reports, credit eligibility information, TFNs, driver licences, passports or other identity documents beyond what is reasonably necessary. If you do, you are responsible for compliance with Part IIIA of the Privacy Act and the Privacy (Credit Reporting) Code.

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:

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.

Instruction risk. AI agents can be manipulated by content they process, including through prompt injection. You must not rely on a Connected Assistant to take consequential actions without your review.

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 tokens, calls or tasks, that usage is yours. You are responsible for any resulting overage. We may terminate the assistant’s session, revoke MCP 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 Connectors 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. 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, and all improvements. Nothing in these Terms transfers any of those rights to you.

Third-party lender material. Lender policy documents are the property of the relevant lenders. We index and cite 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.

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

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

11. 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 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 Form Filler) are provided as is, may be unstable or withdrawn, and should not be relied on for production work. Output from such features requires particularly careful human checking.

Form Filler and generated PDFs. You must check every field of any generated or filled PDF before sending it to a lender, licensee or client. We are not the author of any form you submit. Wrong, missing or misplaced fields are your responsibility.

Fair use and shared infrastructure. We set fair‑use, concurrency, rate, token, call, task and compute limits and may change them at any time. To protect other users we may immediately throttle, queue, cancel jobs, revoke MCP access or cut you off; doing so is not a breach by us and is not grounds for refund or chargeback. The Service runs on shared infrastructure. Other customers’ use may affect performance. We do not warrant a reserved slice of capacity unless a separate written agreement says so.

12. Suspension and termination

By you. Cancel at any time in your account settings.

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.

By us — at our discretion. We may also suspend or terminate any account, or decline to continue providing the Service to any person, at any time and in our sole discretion, on notice to you. We are not required to give reasons. 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 and enforcement. We may suspend, throttle, limit or permanently remove any account, seat, Connected Assistant, API key or MCP connection at any time, with or without cause and with or without prior notice, including to protect the Service, our infrastructure or other users. We may isolate, rate‑limit or terminate your sessions or jobs so that other customers are not affected.

Refunds on removal. If we remove or discontinue your access purely for our convenience and you are not in breach, the prepaid unused‑period refund in this section applies. If removal is because you breached these Terms, abused, overloaded or placed the Service or others at risk, no refund is due.

No right to continued access. Access is a licence, not a property right. You have no right to continued access beyond your current paid‑up period and are subject to these Terms.

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. You should export anything you need before terminating. Sections 3, 7, 8 (warranties), 9, 10, 13, 14, 15, 16 and 20 survive termination.

13. 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.

14. Disclaimers

Subject to section 13, and to the maximum extent permitted by law:

15. Limitation of liability

Subject to section 13, and to the maximum extent permitted by law:

15.1 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.

15.2 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.

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

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

15.5 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.

16. Indemnity

To the maximum extent permitted by law, you indemnify us, and our officers, employees and contractors, against all claims, demands, proceedings, investigations, inquiries, audits, complaints, prosecutions and enforcement actions (whether civil, criminal, administrative or regulatory), and all related fines, penalties, costs and expenses (including legal costs on a solicitor‑and‑own‑client/indemnity basis), brought by or involving ASIC, AFCA, OAIC, ACCC, AUSTRAC, state or federal police, any Director of Public Prosecutions, any court or tribunal, any licensee, aggregator, lender, client or other authority or person, arising out of or in connection with:

Without limiting the above, this indemnity includes our reasonable costs of responding to or complying with any notice, subpoena, dawn‑raid, information request or compulsory process.

You must not join, name or seek contribution from us in any such proceeding without our prior written consent. We have no obligation to indemnify, defend, appear for or represent you in any prosecution, investigation or regulatory action. You acknowledge that any prosecution, licence action or regulatory outcome is yours alone; use of the Service is not a defence and does not make us a co‑principal, accessory or credit licensee.

For clarity, and without limiting the first paragraph of this section, you also indemnify us for all claims, liabilities, losses, damages, fines, penalties and reasonable legal costs arising out of or in connection with:

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.

17. 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.

18. Changes to these Terms

We may amend these Terms at any time and in our sole discretion, 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, 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.

19. Notices

We may give you notice by email to your account address, or by in-app notice. 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.

20. 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.

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.

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.

21. 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