These are the terms of supply for services available on https://www.meetcleo.com/ ("Website"), on our applications, through your Facebook messenger application made available through our applications and/or directly via SMS ("Applications"). The Website and Applications (together referred to as the "Site") are operated by or on behalf of Cleo AI Ltd (Cleo, we, us and our). We are a limited company, registered in England. Our registered company number is 09864205, and our registered office is at 8 Blackstock Mews, London, England, N4 2BT. Cleo is registered with the Financial Conduct Authority (FCA) as an account information service provider with registration number 
Your use of any of the services offered on the Site (Services) is subject to these terms and by signing up for or using any Service you agree to be bound by them. You should print a copy of these terms for future reference. Use of your personal information submitted to us in as part of the provision of the Services is governed by our Privacy notice and Cookies Policy.
These terms were last updated March 2019
Registering with us
To use any of the Services, you must first register to set up an account with us by completing the account registration form available on the Site. You only need to register once.
To register, you must be at least 18 years of age.
Please note that additional eligibility criteria may apply to a particular Service, where indicated on the Site. It is your responsibility to ensure you satisfy all of the minimum eligibility criteria set out above before choosing to register with us. By doing so, you confirm to us that you do meet all of the minimum eligibility criteria.
To register, you must provide us with accurate, complete and up-to-date contact information, including email address and mobile telephone number. You are responsible for the information you provide to us. You must promptly update your Cleo account in the event of any changes to information you have provided.
Registration is subject to approval by us in all cases, and we reserve the right, in our sole and absolute discretion, to decline any application for registration, without giving a reason. If we approve your registration, you will receive a notification from us.
We may be required by law to carry out checks (including checks with credit reference agencies) for the purposes of confirming your identity.
Username and password
Upon registration for an account with us, you will be asked to utilise username and personalised security credentials to access your account. You must take all reasonable precautions to keep your username and personalised security credentials confidential and secure at all times. For example, you should not write down your personalised security credentials and you must take care that nobody sees (or overhears) you when using them. You are the only authorised user of your account and, accordingly, you must not disclose your username or personalised security credentials to anyone else.
You are responsible for all activities that occur using your username and personalised security credentials and you must contact us immediately if you discover or suspect any unauthorised use of your Cleo account or error in the operation of your username and/or personalised security credentials (see Contacting us and complaints). If you discover or suspect any unauthorised use of a payment or financial account linked to your Cleo account, you should immediately notify the provider of that account.
We may, from time to time, with or without prior notice, temporarily suspend the operation of any Service if we believe there has been unauthorised access to your Cleo account or we suspect it is being used to gain unauthorised access to any payment or financial account linked to the Services.
In the event we become aware of any major operational or security incident affecting the Services which could have an adverse impact on your financial interests, we are required to notify you of the incident and measures you can take to mitigate the impact.
Cleo AI Ltd is registered with the Financial Conduct Authority (reference 806670) under the Payment Services Regulations 2017.
The Services are described more fully on the Site. We pledge that the Services will substantially conform to the relevant description on the Site and will be provided with reasonable care and skill.
In particular, our Services involve the provision of account information services to you. This means that by using our Services, you agree that we may, either directly or through our trusted third party service provider Salt Edge Inc. ("Salt Edge"), access, process, aggregate or analyse information from one or more payment or other financial accounts ("Linked Accounts") that you link to your Cleo account in order to provide you with the following Services: provision of information regarding your transactions and financial position across all Linked Accounts; notifying you of certain activity concerning your Linked Accounts where you have requested such notifications; and responding to messages you have submitted through your Cleo account concerning your financial situation or transaction history.
Salt Edge requires that certain minimum terms are flowed down to you. By agreeing to these Terms of Service, you also agree to Salt Edge's end user terms which are available here.
We also offer access to an e-wallet service. The e-wallet service is a third party service provided by MangoPay and as such, the use of this service is subject to MangoPay's terms (available here). By agreeing to these Terms of Services, you also agree to MangoPay's terms. Where we provide payment services to you in connection with your MangoPay account, we do so as agent for MangoPay in accordance your MangoPay terms.
We may, from time to time, offer a trial additional premium suite of services (the "Cleo Plus Services") for which we may charge an additional fee (the "Cleo Plus Subscription Fee") per month (the “Subscription Period”).
Some of the Cleo Plus Services may be subject to additional terms and conditions. By signing up for the Cleo Plus Services, you agree to these additional terms. Some of the Cleo Plus Services may also be limited based on undisclosed qualifying criteria. By signing up for the Cleo Plus Services, you are aware that you may not be eligible for all services at all times.
On signing up to use the Cleo Plus Services, you will provide us with valid, up-to-date and complete credit or debit card details, and you authorise us to charge such credit or debit card for the Cleo Plus Subscription Fee. You will be charged to your Cleo Wallet, or if failing this, to the bank account linked to your Cleo wallet.
By signing up to the services you agree to use this first Cleo Plus account as your sole Cleo Plus account.
Cleo may change the price for the Cleo Plus Services from time to time, and will communicate any price changes to you in advance and, if applicable, how to accept those changes. Price changes for Cleo Plus Subscription Fees will take effect at the start of the next subscription period following the date of the price change. As permitted by local law, you accept the new price by continuing to use the Cleo Premium Service after the price change takes effect. If you do not agree with the price changes, you have the right to reject the change by unsubscribing from the Cleo Premium Service prior to the price change going into effect. Please therefore make sure you read any such notification of price changes carefully.
If we are unsuccessful in taking payment from your Cleo Wallet or debit/credit card, and without affecting any other rights and remedies available to us, we will, without responsibility to you, suspend or temporarily disable all or part of your access to the Cleo Plus Services and we shall be under no obligation to provide any or all of the Cleo Plus Services while the Premium Subscription Fee remains unpaid.
All amounts and Cleo Plus Subscription Fees stated or referred to in these Terms of Service:
- are payable in the currency of your country;
- are inclusive of value added tax (if applicable) unless otherwise expressly stated.
Your payment will automatically renew at the end of the “Subscription period”, unless you cancel your Paid Cleo Plus Services Subscription through Cleo before the end of the current Subscription Period. The cancellation will take effect immediately and you will be downgraded to the Free Service.
Cleo Crusher subscription services
To learn more about our Cleo Crusher beta programme available in some US states and the Motherloan feature click here
Linking payment or financial accounts
To use our Services you must link one or more payment accounts or, where available through the Services, other financial accounts, to your Cleo account. To link a payment or other financial account, we require certain account details from you including your personalised security credentials relating to that account ("Linked Account Security Credentials") (such as usernames, access numbers, passwords, security questions and answers, token/SMS codes, multifactor information, biometric information, device information usernames, PIN). We need these details in order to access and collect information from your Linked Account and/or your associated Linked Account transactions to provide our Services. You are responsible for notifying us of any changes to the Linked Account information or Linked Account Security Credentials you have provided.
Any Linked Account Security Credentials you provide will either be communicated directly to your Linked Account provider through the Services, or will by collected, held and stored securely by Salt Edge. Salt Edge will not make your Linked Account Security Credentials available to any third party other than your Linked Account provider (or other issuer of Linked Account Security Credentials) and will only transmit them through safe and efficient channels in accordance with regulatory rules. Cleo itself will not at any time store your Linked Account Security Credentials.
Any Linked Account data that you provide, and any information obtained from your Linked Accounts, shall only be used by us or Salt Edge to enable us to provide the Services to you (which may include, without limitation, using such data in connection with managing and investigating any security incidents relating to the Services).
You must only link payment or other financial accounts that you are the account holder of. In linking a financial account to your Cleo account, you confirm that you are the account holder. In linking an account, you should check that you are permitted by your Linked Account provider to share account details (and in particular any Linked Account Security Credentials) with us and Salt Edge as contemplated by these Terms of Service. This means that you should check any terms and conditions with your Linked Account provider. You should be aware that only providers of payment accounts that are accessible online are required by regulations to allow you to access account information through a service provider such as Cleo.
Our Services only support payment or other financial accounts provided by certain financial institutions and within certain jurisdictions. The payment and financial accounts that we are able to support may, from time to time, change and a list of those currently supported is available on our Site. We cannot guarantee that your Linked Account provider will allow us (whether directly or through Salt Edge) to access information from your Linked Account and you are responsible for providing any additional consent or authorisation required in order for us to do so.
Accessing your Linked Account
When you link a payment or financial account to your Cleo account, we will use your Linked Account Security Credentials to access and collect information from your Linked Accounts in order to provide our Services. The information that we and/or Salt Edge will access and collect includes transactions on your Linked Account, the features and benefits of your Linked Account and details of any regular transactions you have set up on your Linked Account.
We will access and collect information from your Linked Account: on a daily basis in order to refresh the financial information displayed on your Cleo dashboard; if you have set up notification requests within your Cleo account, as and when required in order to provide you with the relevant notifications (and until such notification request has been cancelled by you); and whenever you send us a message through your Cleo account regarding your Linked Accounts in order to answer your message. You may remove a Linked Account from your Cleo account at any time. Upon removal, we shall delete, and ensure that Salt Edge deletes, any Linked Account Security Credentials held by us and/or Salt Edge and neither of us will continue to access or collect information regarding the removed account. If you have signed up for a MangoPay account through Cleo, then we may continue to hold information regarding P2P transactions you have made or received during the term of our agreement with you.
In relation to our provision of the Services please note that our Services consist of the provision of information obtained from your Linked Account providers; we do not provide the information in your Linked Account nor have any responsibility for this information, it is the responsibility of your Linked Account provider to ensure that the information and data in your Linked Account is accurate and up to date; we, nor Salt Edge, will be responsible for any delays or errors caused by the delays or errors of your Linked Account providers; we cannot guarantee that your Linked Account providers will allow us or Salt Edge to access all or any information from your Linked Accounts; the information obtain from your Linked Account providers is provided to you on an "as is" basis and therefore no assurances are made that such data is accurate or up to date and neither we or Salt Edge will be liable for any losses you incur as a result of your reliance on that information; you are responsible for reviewing and notifying us of any discrepancies between the financial information provided to you through our Services and information provided to you directly from your Linked Account providers.
You should always confirm the information in your Cleo account with the information in your Linked Account. Should you wish to rely on any payment account or transaction information provided under the Service such that, if it were incomplete, inaccurate or out of date you could be prejudiced, you should check the information with the relevant payment account provider it has been obtained from.
Changes to the Service and terms
As it is our policy to continually review and update our Service offerings, we reserve the right to make changes to any Service and/or to these terms from time to time. We will always give you as much notice as we reasonably can of such significant changes.
Service suspension and termination
We may, from time to time, with or without prior notice, temporarily suspend the operation of any Service and/or the Site (in whole or in part) for repair or maintenance work or in order to update or upgrade any contents, features or functionality.
These terms will continue to apply until terminated by either party. We may, with or without prior notice, terminate any contract between you and us ("Contract") or suspend and/or terminate any Service and/or your use of your account in the event that you have breached any of these terms.
If you have breached these terms, we may take such action as we deem appropriate. Such a breach by you may result in our taking, with or without notice, all or any of the following actions: issue of a warning to you; immediate, temporary or permanent withdrawal of your right to use any Service; legal proceedings against you for reimbursement of all recoverable loss and damage resulting from the breach; and/or disclosure of all relevant information to law enforcement authorities as we reasonably feel is necessary.
The responses described above are not limited, and we may take any other action we deem appropriate.
Upon termination of any Contract or Service or your account, for any reason: all rights granted to you under these terms will immediately cease; we will delete any information we hold regarding your Linked Accounts (including Linked Account Security Credentials); and you must promptly discontinue all use of the Service.
You may terminate your account at any time, but you must notify us if you wish to do so (see Contacting us).
Access to the Services
We may, from time to time, restrict access to certain features, parts or content of the Services, or even all the Services, to users who have registered with us. In particular, we reserve the right to disable your account, at any time, if in our opinion you have failed to comply with any of the provisions of these terms or if any details you provide for the purposes of registering as a user prove to be false.
We cannot guarantee the continuous, uninterrupted or error-free operability of the Service. There may be times when certain features, parts or content of the Site, or the entire Site, become unavailable (whether on a scheduled or unscheduled basis) or are modified, suspended or withdrawn by us, in our sole discretion. We will use our reasonable efforts to provide you notice when the Site and/or Service is to be unavailable or when we are modifying, suspending or withdrawing the Services but in some instances particularly where there is a security, or data breach threat or we are required by law, this may not be possible. We will give you notice if we decide to terminate provision of the Services on any Application or the Website.
What you are not allowed to do
Except to the extent expressly set out in these terms, you are not allowed to: 'scrape' content or store content of the Site on a server or other storage device connected to a network or create an electronic database by systematically downloading and storing all of the content of the Site; remove or change any content of the Site or attempt to circumvent security or interfere with the proper working of the Site or the servers on which it is hosted; or create links to the Site from any other website, without our prior written consent, although you may link from a website that is operated by you provided the link is not misleading or deceptive and fairly indicates its destination, you do not imply that we endorse you, your website, or any products or services you offer, you link to (and do not frame or replicate) the home page of the Site, and the linked website does not contain any content that is unlawful, threatening, abusive, defamatory, pornographic, obscene, vulgar, indecent, offensive or which infringes on the intellectual property rights or other rights of any third party.
You must only use the Services and anything available from the Site for lawful purposes (complying with all applicable laws and regulations), in a responsible manner, and not in a way that might damage our name or reputation or that of any of our affiliates.
All rights granted to you under these terms will terminate immediately in the event that you are in breach of any of them.
Intellectual property rights
All intellectual property rights in any content of the Services (including text, graphics, software, photographs and other images, videos, sound, trade marks and logos) are owned by us or our licensors. Except as expressly set out here, nothing in these terms gives you any rights in respect of any intellectual property owned by us or our licensors and you acknowledge that you do not acquire any ownership rights by downloading content from the Site. In the event you print off, copy or store pages from the Site (only as permitted by these terms), you must ensure that any copyright, trade mark or other intellectual property right notices contained in the original content are reproduced.
Service features and content
In all cases, information available through the Services is not intended to amount to authority or advice on which reliance should be placed. You should check with us or the relevant information source before acting on any such information.
To the fullest extent permitted by law, we make no promises, pledges or representations about the Services and/or the Site and we accept no liability for any loss or damage of any kind incurred as a result of you or anyone else using the Services and/or Site or relying on any content available through the Services.
We cannot and do not guarantee that any content provided as part of the Services will be free from viruses and/or other code that may have contaminating or destructive elements. It is your responsibility to implement appropriate IT security safeguards (including anti-virus and other security checks) to satisfy your particular requirements as to the safety and reliability of content.
The Services may, from time to time, include links to external sites, which may include links to third party offers and promotions. We include these to provide you with access to information, products or services that you may find useful or interesting. We are not responsible for the content of these sites or for anything provided by them and do not guarantee that they will be continuously available. The fact that we include links to such external sites does not imply any endorsement of, or association with, their operators or promoters.
Nothing in these terms shall limit or exclude our liability to you: for death or personal injury caused by our negligence; for any promise made by us to you fraudulently; for breach of any term implied by the Consumer Rights Act 2015 and which, by law, may not be limited or excluded; or for any other liability that, by law, may not be limited or excluded.
We will not be liable or responsible for any failure to perform, or delay in performance of, any of our obligations that is caused by events outside our reasonable control.
You may not transfer or assign any or all of your rights or obligations under any Contract.
All notices given by you to us must be given in writing to the address set out at the end of these terms. We may give notice to you at the email address you provide to us when signing up for an account. All notices and information we provide to you shall be in English.
If we fail to enforce any of our rights, that does not result in a waiver of that right.
If any provision of these terms is found to be unenforceable, all other provisions shall remain unaffected.
These terms may not be varied except with our express written consent.
These terms and any document expressly referred to in them represent the entire agreement between you and us in relation to the subject matter of any Contract. We are required by law to advise you that Contracts may be concluded in the English language only and that no public filing requirements apply.
These terms shall be governed by English law, except that if you live in Scotland or Northern Ireland, there may be certain mandatory applicable laws of your country which apply for your benefit and protection in addition to or instead of certain provisions of English law.
Subject to the next paragraph and any entitlement to refer a complaint to the Financial Ombudsman Service, you agree that any dispute between you and us regarding these terms or any Contract will only be dealt with by the English courts, except that if you live in Scotland or Northern Ireland, you can choose to bring legal proceedings either in your country or in England, but if we bring legal proceedings, we may only do so in your country.
The European Online Dispute Resolution platform http://ec.europa.eu/consumers/odr/ provides information about alternative dispute resolution which may be of interest and we are required to inform you that you may use it if there is a dispute that cannot be resolved between you and us.
Additional Terms. In conjunction with your access or use of the Services, you may be subject to additional terms, rules, policies, and conditions that are posted on the Website, including, but not limited to, terms and conditions for our referral or rewards programs (the “Additional Terms”), which are hereby incorporated by reference into these Terms. In the event of a conflict between any Additional Terms and these Terms, these Terms will control.
Contacting us and complaints
Please submit any questions you have about these terms, or any complaint or concern in relation to any Service through Intercom or by email to email@example.com. Any complaints regarding our Services will be dealt with in accordance with our complaints handling procedures, a summary of which can be requested from us by email.
If we do not resolve your complaint to your satisfaction, you may be able to refer it to the Financial Ombudsman Service (FOS). The FOS is an organisation set up by law to give consumers a free and independent service for resolving disputes with financial institutions and regulated firms. The FOS can be contacted by post at Exchange Tower, London E14 9SR, by telephone on 0800 023 4567, or by email at firstname.lastname@example.org. Further information on how to refer a complaint to the FOS and whether you are eligible to do so can be found at financial-ombudsman.org.uk.