Acceptable Use Policy

1.1. Purpose

This Acceptable Use Policy sets out the minimum rules that apply to the Client’s access to and use of the Website, the Synergik account, all Synergik Platforms, workspaces, dashboards, Products, Services, Deliverables, communication channels, provider integrations and any other functionality made available through or in connection with Synergik.

This Policy is intended to protect Synergik, Clients, authorised users, Professional Service Providers, regulated providers, third-party providers, public authorities, counterparties, systems, data, Confidential Information, intellectual property and the integrity of the Synergik ecosystem.

1.2. Incorporation into the Terms

This Policy forms part of the Synergik Terms and Conditions and is incorporated into them by reference.

By creating a Synergik account, accessing the Website, using any Synergik Platform, accepting a Service Order, accepting a quotation, uploading Client Content, requesting a Product or Service, or otherwise using the Synergik ecosystem, the Client agrees to comply with this Policy.

1.3. Relationship with other terms

This Policy applies together with:

• the Synergik Terms and Conditions;
• the applicable Platform-Specific Terms;
• the applicable Service Order;
• the applicable quotation;
• the Privacy Policy;
• the Data Processing Addendum, where applicable;
• the AI and Automation Policy;
• professional engagement terms;
• regulated-provider terms;
• third-party provider terms; and
• applicable law.

In the event of conflict between this Policy and a more specific Platform-Specific Term, Service Order, professional engagement term or regulated-provider term, the more specific term shall prevail for the relevant Product, Service or platform, unless this Policy imposes a stricter security, compliance or lawful-use restriction.

1.4. No limitation of Synergik’s rights

This Policy does not limit any right of Synergik under the Terms, including the right to refuse, restrict, suspend, terminate, remove, quarantine, report or preserve any account, user, workspace, Client Content, Product, Service, Deliverable or activity where Synergik considers such action necessary or appropriate.

2.1. Lawful and authorised use only

The Client shall use the Synergik ecosystem only for lawful, authorised and legitimate business, professional, commercial, incorporation, compliance, regulatory, advisory, technical, training or related purposes.

The Client shall not use the Synergik ecosystem for any unlawful, fraudulent, misleading, abusive, unauthorised, harmful, infringing, deceptive, evasive or prohibited purpose.

2.2. Use within agreed scope

The Client shall use each Product, Service, Deliverable, workspace, platform function or provider integration only within the scope for which it is made available or ordered.

The Client shall not use any Product, Service or Deliverable outside the agreed Client, entity, project, jurisdiction, matter, workflow, Service Order, quotation, platform or purpose, unless Synergik expressly permits such use in writing.

2.3. Responsibility for users

The Client is responsible for all access to and use of the Synergik ecosystem by its authorised users, invited users, employees, officers, directors, shareholders, founders, consultants, contractors, representatives, advisers, service providers and any other person accessing the account or workspace through credentials, permissions or invitations issued by or on behalf of the Client.

A breach of this Policy by an authorised user shall be treated as a breach by the Client.

3.1. General prohibition

The Client shall not use the Synergik ecosystem, any Product, Service, Deliverable, communication channel, workspace, document, report, template, workflow, provider integration or platform function to commit, facilitate, conceal, support, promote, prepare or enable unlawful conduct.

3.2. Financial crime

The Client shall not use the Synergik ecosystem in connection with:

• money laundering;
• terrorist financing;
• proliferation financing;
• sanctions evasion;
• fraud;
• corruption;
• bribery;
• tax evasion;
• market abuse;
• insider dealing;
• unlawful disclosure of inside information;
• market manipulation;
• deceptive token offerings;
• unlawful fundraising;
• payment fraud;
• card fraud;
• identity fraud;
• corporate identity fraud;
• document fraud;
• concealment of beneficial ownership;
• concealment of source of funds;
• concealment of source of wealth; or
• any other financial crime or unlawful financial activity.

3.3. Sanctions and restricted persons

The Client shall not use the Synergik ecosystem where such use would involve, benefit, support, facilitate, conceal or be connected with:

• a. a sanctioned person;
• b. a person owned or controlled by a sanctioned person;
• c. a restricted jurisdiction;
• d. sanctions evasion;
• e. a transaction prohibited by sanctions laws;
• f. assets, funds, wallets, accounts, entities or arrangements connected with sanctioned persons; or
• g. any activity that may cause Synergik, a Synergik Party, a provider, a Professional Service Provider or a regulated provider to breach sanctions laws.

3.4. Illegal regulated activity

The Client shall not use the Synergik ecosystem to conduct, prepare, structure, advertise, facilitate, conceal or support any regulated activity without all required licences, registrations, authorisations, exemptions, permissions or approvals.

This includes, without limitation:

• crypto-asset services;
• payment services;
• electronic money services;
• banking services;
• investment services;
• lending or credit services;
• insurance services;
• securities offerings;
• crowdfunding services;
• asset management;
• portfolio management;
• custody services;
• exchange services;
• transfer services;
• financial promotions;
• public offerings;
• investment advice;
• payment processing;
• card issuing; and
• any other regulated activity.

3.5. No misleading regulatory or provider use

The Client shall not use Synergik materials, Products, Services, Deliverables, platform outputs, reports, policies, templates, documents, explanations, summaries or communications to mislead any regulator, authority, public registry, bank, payment provider, card issuer, investor, customer, counterparty, auditor, adviser, provider or other person.

4.1. General content restrictions

The Client shall not upload, submit, transmit, store, generate, request, circulate, publish, approve, adopt or use Client Content that:

• is unlawful;
• is fraudulent;
• is false, forged or misleading;
• infringes intellectual property rights;
• breaches confidentiality obligations;
• breaches data protection laws;
• contains personal data without a lawful basis;
• contains confidential information without authority;
• contains malware or harmful code;
• is defamatory;
• is abusive, threatening or harassing;
• facilitates unlawful conduct;
• facilitates financial crime;
• facilitates sanctions evasion;
• facilitates cyber abuse;
• misrepresents legal, regulatory, corporate, payment, card, technical or compliance status;
• is irrelevant and operationally disruptive;
• is designed to manipulate platform outputs; or
• otherwise breaches the Terms, this Policy or applicable law.

4.2. False or misleading documents

The Client shall not upload, submit or rely on:

• forged documents;
• altered documents;
• expired documents represented as valid;
• documents obtained unlawfully;
• documents submitted without authority;
• documents containing false statements;
• documents concealing material facts;
• documents misrepresenting ownership, control, beneficial ownership, corporate structure, financial status, regulatory status, technical capability or compliance arrangements;
• documents that infringe third-party rights; or
• documents containing malicious code or hidden harmful content.

4.3. Personal data and sensitive information

The Client shall not provide personal data, special-category data, criminal-offence data or sensitive information unless:

• such information is necessary for the relevant Product or Service;
• the Client has a lawful basis for providing it;
• required notices have been given;
• required consents have been obtained where consent is relied upon;
• disclosure does not breach confidentiality or professional obligations; and
• disclosure complies with applicable data protection laws.

4.4. Excessive or unnecessary data

The Client shall not upload excessive, irrelevant, duplicated, unnecessary or disproportionate data where such data is not reasonably required for the relevant Product, Service, workspace, platform or provider process.

Synergik may reject, delete, quarantine, archive or disregard such data where it is unnecessary, excessive, operationally burdensome, unlawful, harmful or outside scope.

5.1. Account integrity

The Client shall not:

• create false accounts;
• create accounts using false information;
• impersonate another person;
• misrepresent authority;
• misrepresent company identity;
• misrepresent beneficial ownership;
• create accounts on behalf of persons without authority;
• create duplicate accounts to avoid restrictions;
• transfer accounts without Synergik’s consent;
• sell, rent, lease, sublicense or otherwise commercialise account access;
• allow unauthorised persons to use account credentials; or
• use any account for purposes outside the agreed business or professional use.

5.2. Credentials

The Client shall not:

• share credentials outside authorised platform functionality;
• use another person’s credentials;
• obtain credentials by deception;
• store credentials insecurely;
• bypass authentication controls;
• disable security features without authorisation;
• permit unauthorised access; or
• fail to notify Synergik promptly of suspected credential compromise.

5.3. Workspace misuse

The Client shall not use any workspace:

• as a general file-hosting service;
• as a repository for unrelated or unlawful materials;
• to store malicious files;
• to conceal unlawful documents;
• to share materials with unauthorised persons;
• to bypass provider onboarding;
• to misrepresent document status;
• to hide ownership, control or regulatory information;
• to interfere with another Client’s workspace; or
• to access, view, copy, download, change or delete another Client’s information.

5.4. Access permissions

The Client shall not grant excessive, unnecessary or inappropriate access rights.

The Client must promptly remove, suspend or restrict users who no longer require access, are no longer authorised, have changed role, have left the Client’s organisation, or present a legal, compliance, confidentiality, security or operational risk.

6.1. No unauthorised access

The Client shall not attempt to access, use, copy, alter, interfere with or obtain any system, account, workspace, data, document, API, provider integration, administrative interface, database, source code, log, network, server or infrastructure that the Client is not authorised to access.

6.2. No harmful technical activity

The Client shall not:

• upload malware;
• introduce viruses, worms, trojans, spyware, ransomware, logic bombs or harmful code;
• conduct denial-of-service or distributed denial-of-service activity;
• overload systems;
• interfere with platform operation;
• bypass rate limits;
• bypass usage restrictions;
• interfere with audit logs;
• disrupt provider integrations;
• compromise authentication mechanisms;
• exploit vulnerabilities;
• use hidden payloads or malicious files;
• intercept communications;
• exfiltrate data;
• modify platform behaviour without authorisation; or
• otherwise harm the security or integrity of the Synergik ecosystem.

6.3. No unauthorised testing

The Client shall not conduct or permit any penetration testing, vulnerability scanning, load testing, security probing, network scanning, scraping, crawling, stress testing, exploit testing, automated testing or similar activity against the Website, any Synergik Platform, workspace, provider integration or Synergik infrastructure without Synergik’s prior written authorisation.

Where Synergik provides pentesting or security-related services, testing may be performed only under an approved written scope, agreed rules of engagement and applicable Platform-Specific Terms.

6.4. No circumvention

The Client shall not circumvent or attempt to circumvent:

• access controls;
• authentication controls;
• rate limits;
• usage limits;
• payment controls;
• content restrictions;
• provider restrictions;
• compliance checks;
• document release controls;
• role permissions;
• workspace segmentation;
• API restrictions;
• audit logs; or
• any other technical, legal, operational, security or compliance control.

7.1. No unauthorised automated access

The Client shall not use bots, scripts, crawlers, scrapers, automated agents, extraction tools, bulk-download tools, data-mining tools or similar mechanisms to access, copy, query, download, extract, index, monitor or interact with the Synergik ecosystem unless expressly authorised by Synergik.

7.2. No unauthorised data extraction

The Client shall not extract, copy, compile, reuse or commercialise platform data, templates, workflows, questionnaires, prompts, outputs, document logic, user-interface elements, metadata, audit logs, provider information or other Synergik materials except as expressly permitted under the Terms.

7.3. No competing use

The Client shall not use the Synergik ecosystem, Synergik IP, workflows, documents, templates, platform structure, document logic, reports, outputs, questions, forms or service model to develop, train, support, benchmark, market or operate any competing product, platform, software, workflow, document generator, advisory tool or service.

8.1. Permitted use only

The Client may use Products, Services and Deliverables only for the specific Client, entity, project, jurisdiction, purpose, matter and scope for which they were provided.

8.2. Prohibited uses

The Client shall not use any Product, Service or Deliverable:

• for unlawful purposes;
• outside the agreed scope;
• to mislead regulators or providers;
• to misrepresent compliance status;
• to conceal risk;
• to fabricate governance, compliance, financial, technical or regulatory arrangements;
• to support unlawful regulated activity;
• to support fraudulent filings;
• to support unlawful public offerings;
• to support deceptive marketing;
• for another entity, project, token, product, jurisdiction or matter outside scope;
• for resale or unauthorised redistribution;
• as a substitute for professional advice where professional advice is required;
• as final where the document is marked draft, preliminary, generated, incomplete or pending review;
• to remove or conceal Synergik notices or provider notices; or
• in any manner inconsistent with the Terms, the applicable Service Order or applicable law.

8.3. No misrepresentation of review status

The Client shall not represent that a Deliverable is lawyer-reviewed, professionally approved, regulator-approved, provider-approved, compliant, certified, final, submission-ready or authority-ready unless such status has been expressly confirmed by Synergik or the relevant Professional Service Provider.

8.4. No unauthorised external distribution

The Client shall not publish, distribute, resell, sublicense, share publicly, upload to public repositories, post online or make available to third parties any Synergik materials, templates, workflows, questionnaires, reports, comments, guidance, internal notes or Deliverables, except to the extent expressly permitted by the Terms, a Service Order or Synergik’s written consent.

9.1. Cooperation

The Client shall cooperate with Synergik, Professional Service Providers, regulated providers and third-party providers in relation to onboarding, verification, compliance, KYC, KYB, AML, sanctions, fraud, risk, security, payment, card, professional and provider checks.

9.2. Information requests

The Client shall respond promptly, accurately and completely to any request for information, documents, confirmations or explanations reasonably required for legal, compliance, provider, professional, security, billing or operational purposes.

9.3. Ongoing updates

The Client shall promptly notify Synergik of changes affecting:

• legal identity;
• company registration;
• registered office;
• tax status;
• ownership;
• beneficial ownership;
• control;
• directors, managers or officers;
• business model;
• products or services;
• jurisdiction of operation;
• licences or authorisations;
• regulatory status;
• AML, sanctions, fraud or financial crime risk;
• provider status;
• payment or transaction profile;
• security arrangements; or
• any other information material to a Product, Service, account, workspace or provider process.

10.1. No payment abuse

The Client shall not use the Synergik ecosystem, any provider integration or any related Product or Service for payment abuse, card abuse, chargeback abuse, money mule activity, unauthorised payment activity, transaction laundering, illegal remittance, fraudulent merchant activity, concealed beneficial ownership, prohibited business activity or any other unlawful payment-related conduct.

10.2. No circumvention of provider controls

The Client shall not attempt to circumvent, avoid, mislead or interfere with the onboarding, transaction monitoring, risk assessment, sanctions screening, AML screening, fraud monitoring, reserve requirements, card rules, transaction limits, business restrictions or compliance controls of any provider.

10.3. No misleading payment or card information

The Client shall not provide false, incomplete or misleading information to any payment provider, card issuer, bank, processor, acquirer, electronic money institution or other financial-sector provider.

11.1. Synergik IP

The Client shall not copy, reproduce, distribute, publish, resell, sublicense, modify, reverse engineer, decompile, disassemble, extract, compile, create derivative works from, or commercially exploit Synergik IP, except as expressly permitted under the Terms.

11.2. Templates and workflows

The Client shall not extract, compile, replicate, publish, distribute, resell, train systems on, or build competing materials from Synergik templates, questionnaires, clause libraries, workflows, document logic, report structures, training materials, prompts, automation rules, interface designs or methodologies.

11.3. Third-party IP

The Client shall not use the Synergik ecosystem to infringe or misappropriate third-party intellectual property rights, confidential information, trade secrets, database rights, copyright, trade marks, design rights or other proprietary rights.

12.1. Professional communications

The Client shall communicate with Synergik, Synergik Parties, Professional Service Providers, providers and other users in a professional, lawful and non-abusive manner.

12.2. Prohibited communications

The Client shall not send, upload, transmit or cause to be transmitted:

• abusive communications;
• threatening communications;
• defamatory communications;
• fraudulent communications;
• misleading communications;
• unlawful marketing;
• spam;
• phishing messages;
• malware links;
• impersonation messages;
• social-engineering attempts;
• communications intended to pressure a Professional Service Provider into breaching professional duties;
• communications intended to mislead providers or authorities; or
• communications that otherwise breach this Policy.

13.1. Client responsibility

The Client is responsible for any external tool, software, plugin, browser extension, file-sharing system, email system, cloud storage system, device, network or third-party service used by the Client in connection with the Synergik ecosystem.

13.2. No unauthorised export

The Client shall not export, sync, transmit or disclose Client Content, Synergik materials, Deliverables, Confidential Information or personal data to external systems in a manner that breaches the Terms, applicable law, confidentiality obligations, professional obligations, provider terms or data protection requirements.

13.3. No unsafe integrations

The Client shall not connect or attempt to connect unauthorised applications, scripts, bots, plugins, integrations, APIs or automated tools to the Synergik ecosystem without Synergik’s prior written consent.

14.1. Synergik’s enforcement rights

Where Synergik reasonably considers that the Client has breached this Policy, Synergik may, without limitation:

• issue a warning;
• request corrective action;
• request information;
• remove or restrict Client Content;
• quarantine files;
• reject documents;
• suspend a user;
• restrict a workspace;
• suspend an account;
• suspend or terminate Products or Services;
• refuse further access;
• withhold Deliverables;
• disable integrations;
• notify providers;
• notify Professional Service Providers;
• notify competent authorities where required or appropriate;
• preserve records and evidence;
• recover losses and costs;
• claim indemnity;
• seek injunctive relief; and
• exercise any other right or remedy available under the Terms or applicable law.

14.2. No refund for breach

The Client shall not be entitled to any refund, credit or reimbursement where Synergik refuses, restricts, suspends, terminates, delays or cancels any account, workspace, Product, Service, provider arrangement or Deliverable due to breach of this Policy, except where mandatory law requires otherwise.

14.3. Reporting

Synergik may report unlawful, suspicious, harmful or prohibited conduct to regulators, competent authorities, law-enforcement agencies, providers, Professional Service Providers, payment providers, card issuers, banks, hosting providers, security providers or other relevant persons where Synergik considers such reporting required or appropriate.

14.4. Preservation of evidence

Synergik may preserve account records, workspace records, Client Content, communications, audit logs, technical logs, payment records, provider records and other evidence where necessary for legal, regulatory, compliance, security, dispute-resolution, enforcement or provider purposes.

The Client shall indemnify Synergik, Synergik Parties, Professional Service Providers, regulated providers, third-party providers, officers, directors, employees, contractors and representatives against all losses, damages, liabilities, claims, fines, penalties, costs and expenses arising out of or in connection with:

• breach of this Policy;
• unlawful use of the Synergik ecosystem;
• misuse of Products, Services or Deliverables;
• unlawful, inaccurate, misleading or infringing Client Content;
• unauthorised account access caused by the Client;
• breach of intellectual property rights;
• breach of confidentiality;
• breach of data protection laws;
• breach of sanctions, AML, anti-fraud or financial-crime laws;
• misleading submissions to authorities or providers;
• unauthorised security testing;
• misuse of automated access;
• misuse of provider integrations;
• breach by authorised users; and
• third-party claims arising from the Client’s conduct.

This Policy shall survive suspension, termination, account closure, completion of Services, expiry of any Service Order and cessation of access to the Synergik ecosystem to the extent necessary to give effect to lawful-use obligations, confidentiality obligations, intellectual property restrictions, data protection obligations, compliance obligations, liability provisions, indemnities, evidence preservation and accrued rights.