Terms of Service

1. Acceptance of Terms

By accessing or using Spentio ("Service," "Platform," "we," "us," or "our"), operated by Spentio ("Company"), you ("User," "you," or "your") agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, you must not access or use the Service.

These Terms apply to all visitors, registered users, and any person or entity that accesses the Service in any capacity.

These Terms incorporate by reference our Privacy Policy and Cookie Policy, which describe how we collect, use, and protect your personal data.

We reserve the right to update these Terms in accordance with Section 18 below. Material changes will be communicated with at least 30 days' prior notice. Continued use of the Service after the effective date of changes constitutes acceptance of the modified Terms.

2. Definitions

For the purposes of these Terms:

• "AI Features" means the automated transaction parsing, categorization, analysis, and insight generation capabilities of the Service powered by artificial intelligence and machine learning.
• "Financial Data" means bank statements, transaction records, receipts, expense entries, and any other financial information you upload to or create within the Service.
• "Personal Data" has the meaning given under the EU General Data Protection Regulation (GDPR) or, for California residents, the California Consumer Privacy Act (CCPA), as applicable.
• "Premium Features" means features and functionality available only to paid subscribers, as described on our pricing page.
• "User Content" means all data, information, and materials you upload, submit, or generate through the Service.

3. Eligibility

To use our Service, you must:

• Be at least 18 years old, or the age of legal majority in your jurisdiction, whichever is higher
• Have the legal capacity to form a binding contract under applicable law
• Not be a person barred from using the Service under the laws of your country of residence or any other applicable jurisdiction
• Not be located in, or a resident of, any country subject to comprehensive sanctions by the European Union, the United States, or Switzerland
• Provide accurate, current, and complete registration information and maintain the accuracy of such information

If you are using the Service on behalf of a business, organization, or other legal entity, you represent and warrant that you have the authority to bind that entity to these Terms, and the term "you" shall refer to that entity.

4. Account Terms

4.1 Account Creation

You must create an account to use most features of the Service. You are responsible for:

• Maintaining the confidentiality of your account credentials and not sharing them with any third party
• All activities that occur under your account, whether or not authorized by you
• Notifying us immediately at security@spentioapp.com of any unauthorized access or security breach

4.2 Account Security

You must use a strong, unique password and enable two-factor authentication when available. We implement industry-standard security measures to protect your account, but we cannot guarantee absolute security. We are not liable for losses caused by unauthorized access to your account resulting from your failure to safeguard your credentials.

4.3 One Account Per Person

Each individual may maintain only one free account. Creating multiple accounts to abuse promotions, circumvent usage limits, or evade restrictions is prohibited and may result in termination of all associated accounts without refund.

4.4 Account Accuracy

You agree to provide truthful, accurate, and complete information when creating your account and to update such information promptly when it changes. We reserve the right to suspend accounts that contain materially inaccurate information.

5. Service Description & AI Disclosure

5.1 Expense Tracking

Spentio is a personal expense tracking tool that helps you manage, categorize, and analyze your spending. The Service is designed for informational and personal budgeting purposes only.

5.2 AI-Powered Features

The Service uses artificial intelligence and machine learning to:

• Parse and extract transaction data from uploaded bank statements
• Automatically categorize transactions based on merchant and description data
• Generate spending insights, trends, and summaries
• Provide informational comparisons of banking products and services

In accordance with the EU AI Act (Regulation (EU) 2024/1689), we disclose that these features are powered by automated processing. AI-generated outputs are probabilistic in nature and may contain inaccuracies, including but not limited to incorrect transaction amounts, dates, categories, or merchant attributions. You acknowledge that:

• AI outputs require your review and verification before reliance
• We do not guarantee the accuracy, completeness, or reliability of any AI-generated output
• You remain solely responsible for all financial decisions made using the Service
• AI features may be updated, modified, or deprecated at our discretion

5.3 Not Financial, Tax, or Legal Advice

Any banking product comparisons, spending insights, or financial information provided through the Service are for general informational purposes only. They do not constitute personalized financial advice, a recommendation to take any specific action, or an endorsement of any financial product or institution. You should consult a qualified financial advisor, tax professional, or attorney for advice specific to your situation.

Spentio is not a regulated financial services provider, bank, investment firm, or credit intermediary in any jurisdiction. We do not hold funds, process payments on your behalf, or have access to your bank accounts beyond the statement files you voluntarily upload.

5.4 Service Availability

We strive to maintain high availability but do not guarantee uninterrupted access. The Service may be temporarily unavailable due to maintenance, updates, or circumstances beyond our control. We will make reasonable efforts to provide advance notice of planned downtime.

6. Acceptable Use Policy

You agree NOT to:

• Violate any applicable local, national, or international laws or regulations
• Infringe upon the intellectual property, privacy, or other rights of any third party
• Upload malicious code, viruses, trojans, or any harmful or destructive data
• Attempt to gain unauthorized access to our systems, networks, or other users' accounts
• Use the Service for money laundering, terrorist financing, fraud, or any other illegal financial activity
• Upload fabricated, falsified, or deliberately misleading financial data
• Resell, sublicense, duplicate, or redistribute the Service or any part thereof without our prior written authorization
• Use automated scripts, bots, scrapers, or similar tools to access or extract data from the Service, except through our official API (if provided)
• Interfere with, disrupt, or place an unreasonable burden on the Service, its servers, or connected networks
• Impersonate any person or entity, or falsely represent your affiliation with any person or entity
• Harass, threaten, abuse, or harm other users or our personnel
• Circumvent, disable, or interfere with any security or access control features of the Service

Violation of this Acceptable Use Policy may result in immediate suspension or termination of your account, forfeiture of any prepaid subscription fees, and referral to appropriate law enforcement authorities where warranted.

7. Subscription & Billing

7.1 Free Tier

Spentio offers a free tier with limited functionality, including restricted AI parsing usage. Feature limitations and usage caps for the free tier are described on our pricing page. We reserve the right to modify free tier features with reasonable notice.

7.2 Premium Subscription

Premium subscriptions unlock additional features as described on our pricing page. By subscribing, you agree to pay the applicable fees. Subscription fees are:

• Billed in advance on a monthly or annual basis, as selected at purchase
• Stated in the currency displayed at checkout (EUR, USD, GBP, or CHF as applicable)
• Inclusive of applicable taxes (VAT/sales tax), which will be displayed separately at checkout where required by law
• Subject to change upon 30 days' prior written notice; price changes do not apply to the current billing cycle

7.3 Automatic Renewal

Subscriptions automatically renew at the end of each billing cycle at the then-current rate, unless you cancel before the renewal date. You may cancel at any time through your account settings (Settings → Subscription → Cancel). Cancellation takes effect at the end of the current billing period; you retain access to Premium Features until then.

7.4 Payment Processing

Payments are processed by Stripe, Inc. ("Stripe"), a PCI DSS Level 1 certified payment processor. We do not store your full credit card number on our servers. By subscribing, you agree to Stripe's Terms of Service.

7.5 Failed Payments

If a payment fails, we will attempt to process it again and notify you by email. If payment remains unsuccessful after a reasonable number of attempts, we may downgrade your account to the free tier. We will provide at least 7 days' notice before any downgrade.

7.6 Refunds

Refund rights depend on your jurisdiction and are subject to the provisions in Section 8 (EU Right of Withdrawal) below. Outside of statutory refund rights:

• Annual subscriptions: Pro-rated refund available within 30 days of initial purchase or renewal, upon request to support@spentioapp.com
• Monthly subscriptions: No refunds for partial billing periods
• In all cases, statutory consumer protection rights in your jurisdiction are unaffected

8. EU Right of Withdrawal

8.1 Right of Withdrawal

If you are a consumer in the European Union or European Economic Area, you have the right to withdraw from your subscription within 14 days of purchase without giving any reason.

To exercise your right of withdrawal, you must inform us of your decision by a clear statement (e.g., email to support@spentioapp.com). You may use the model withdrawal form available in Annex I(B) of Directive 2011/83/EU, but it is not obligatory.

8.2 Effects of Withdrawal

If you withdraw, we will reimburse all payments received from you without undue delay and no later than 14 days from the date we are informed of your withdrawal decision. The reimbursement will be made using the same payment method you used for the initial transaction, unless you expressly agree otherwise.

8.3 Early Access Consent

If you request to begin using Premium Features immediately (before the 14-day withdrawal period expires), you acknowledge that you will lose your right of withdrawal once the digital content has been fully provided, provided that you gave your prior express consent and acknowledged the loss of withdrawal right.

9. Intellectual Property

9.1 Our Property

The Service, including all software, algorithms, AI models, user interfaces, designs, text, graphics, logos, and documentation, is owned by or licensed to Spentio and is protected by international copyright, trademark, patent, trade secret, and other intellectual property laws. The Spentio name, logo, and all related names, marks, and slogans are trademarks of the Company.

9.2 License to Use

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, non-sublicensable, revocable license to access and use the Service for your personal or internal business expense tracking purposes.

9.3 Restrictions

Except as expressly permitted by applicable law, you may not:

• Copy, modify, adapt, or create derivative works based on the Service
• Reverse engineer, decompile, disassemble, or otherwise attempt to discover the source code or algorithms of the Service
• Remove, obscure, or alter any proprietary notices, labels, or marks
• Use our trademarks, trade names, or branding without prior written permission
• Use the Service to build a competing product or service

Nothing in this section restricts your rights under applicable mandatory law, including EU Directive 2009/24/EC on the legal protection of computer programs (which permits decompilation for interoperability under certain conditions).

10. User Content & Data

10.1 Ownership of Your Data

You retain all ownership rights in the Financial Data and User Content you upload to or create within the Service. We claim no ownership over your data.

10.2 License to Process

By using the Service, you grant us a limited, non-exclusive, worldwide license to process, store, and display your User Content solely for the purposes of:

• Providing, maintaining, and improving the Service
• Generating AI-powered insights, categorizations, and analysis for your use
• Producing aggregated, anonymized analytics that cannot identify individual users

This license terminates when you delete your User Content or your account, subject to reasonable backup retention periods as described in our Privacy Policy.

10.3 Data Processing (GDPR)

Where we process your Personal Data, we do so in accordance with our Privacy Policy and applicable data protection law, including the GDPR. For the purposes of the GDPR, we act as the data controller for Personal Data processed through the Service. The legal bases for our processing include performance of this contract, your consent (where required), our legitimate interests, and compliance with legal obligations.

10.4 Data Accuracy

You are responsible for the accuracy and legality of data you upload. AI-assisted categorization and parsing are provided as convenience features; you should verify their accuracy. We are not responsible for errors, omissions, or consequences resulting from incorrect or incomplete data, whether entered by you or generated by our AI Features.

10.5 Data Portability & Export

You may export your data at any time through the Service in standard, machine-readable formats (e.g., CSV, PDF). This right exists independently of and in addition to your data portability rights under Article 20 of the GDPR.

10.6 Data Deletion

Upon account deletion, we will delete your User Content and Personal Data in accordance with our Privacy Policy. Certain data may be retained where required by law (e.g., tax and accounting record-keeping obligations) or for the establishment, exercise, or defense of legal claims. Aggregated, anonymized data that cannot identify you may be retained indefinitely.

10.7 International Data Transfers

Your data may be processed on servers located in the European Union (Microsoft Azure EU regions). Where data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, including EU Standard Contractual Clauses or adequacy decisions by the European Commission, as detailed in our Privacy Policy.

11. Third-Party Services

The Service integrates with or may link to third-party services, including but not limited to:

• Authentication providers (e.g., Google Sign-In)
• Payment processors (Stripe)
• Cloud infrastructure providers (Microsoft Azure)
• AI model providers for transaction processing

Your use of third-party services is governed by their respective terms of service and privacy policies, which we encourage you to review. We are not responsible for the availability, accuracy, content, or practices of third-party services. Links to third-party websites or services do not constitute our endorsement.

We select third-party providers with care and require them to maintain appropriate security and data protection standards. However, we cannot guarantee the conduct of third parties and are not liable for their acts or omissions.

12. Disclaimers

To the fullest extent permitted by law, we disclaim all warranties, including but not limited to:

• Implied warranties of merchantability, fitness for a particular purpose, and non-infringement
• Warranties regarding the accuracy, reliability, completeness, or timeliness of AI-generated outputs
• Warranties that the Service will be uninterrupted, error-free, secure, or free of viruses or harmful components
• Warranties regarding the accuracy of transaction categorization, spending analysis, or banking product comparisons

EU consumers: If you are a consumer in the EU/EEA, this disclaimer does not affect your mandatory statutory warranty rights under Directive (EU) 2019/770 on digital content and digital services, including your right to a conforming product and remedies for non-conformity.

13. Limitation of Liability

Our total aggregate liability for all claims arising from or relating to these Terms or the Service, whether in contract, tort (including negligence), strict liability, or any other legal theory, shall not exceed the greater of:

• The total amount you paid to us in the 12 months immediately preceding the event giving rise to the claim, or
• One hundred euros (€100)

Nothing in these Terms excludes or limits our liability for:

• Death or personal injury caused by our negligence
• Fraud or fraudulent misrepresentation
• Any liability that cannot be excluded or limited under applicable mandatory law
• Gross negligence or willful misconduct (in jurisdictions where such exclusion is prohibited)

EU consumers: If you are a consumer in the EU/EEA, this limitation does not affect your mandatory statutory rights, including rights under consumer protection laws of your country of residence.

14. Indemnification

To the extent permitted by applicable law, you agree to indemnify, defend, and hold harmless Spentio, its officers, directors, employees, agents, and affiliates from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or related to:

• Your use of the Service in violation of these Terms
• Your violation of any applicable law or regulation
• Your violation of any third-party rights, including intellectual property or privacy rights
• Any User Content you upload that is inaccurate, unlawful, or infringing

EU consumers: This indemnification clause applies only to the extent permitted by the consumer protection laws of your country of residence. In some EU member states, blanket indemnification clauses may be considered unfair contract terms and will not be enforced against consumers.

15. Termination

15.1 Termination by You

You may close your account at any time through Settings → Account → Delete Account, or by emailing support@spentioapp.com. We will process account deletion requests within 30 days. Upon deletion, your data will be removed in accordance with our Privacy Policy and Section 10.6 above.

15.2 Termination by Us

We may suspend or terminate your account if you:

• Materially violate these Terms or our Acceptable Use Policy
• Engage in fraudulent, abusive, or illegal activity
• Fail to pay subscription fees after reasonable notice and opportunity to cure
• Have been inactive for 12 or more consecutive months (free accounts only, with 30 days' email notice prior to deletion)

Except in cases of serious or repeated violations, fraud, or where prohibited by law, we will provide you with reasonable notice and an opportunity to cure the breach before terminating your account.

15.3 Effect of Termination

Upon termination, your right to access and use the Service ceases immediately (or at the end of your current billing period, if applicable). You may request a copy of your data before account deletion. Provisions that by their nature should survive termination shall survive, including but not limited to: intellectual property, limitation of liability, indemnification, dispute resolution, and governing law.

16. Dispute Resolution

16.1 Informal Resolution

Before initiating any formal legal proceedings, you agree to contact us at legal@spentioapp.com to attempt to resolve any dispute informally. Both parties agree to negotiate in good faith for a period of at least 60 days before pursuing formal remedies.

16.2 Governing Law

These Terms shall be governed by and construed in accordance with the laws of Switzerland, without regard to its conflict of law provisions.

16.3 Jurisdiction

Subject to mandatory consumer protection provisions below, any disputes arising out of or relating to these Terms or the Service shall be submitted to the exclusive jurisdiction of the courts of Zurich, Switzerland.

16.4 EU Consumer Rights

If you are a consumer in the EU/EEA, you have the right to bring legal proceedings in the courts of your country of habitual residence. Nothing in these Terms deprives you of the protection afforded by the mandatory provisions of the consumer protection laws of your country of residence, in accordance with Article 6(2) of Regulation (EC) No 593/2008 (Rome I).

You may also submit complaints through the European Commission's Online Dispute Resolution (ODR) platform at https://ec.europa.eu/consumers/odr. We are not obligated to participate in alternative dispute resolution proceedings unless required by applicable law in your jurisdiction.

16.5 US Dispute Resolution

For users in the United States: Any dispute not resolved informally shall be resolved by binding arbitration administered by the American Arbitration Association ("AAA") in accordance with its Consumer Arbitration Rules. Arbitration shall take place in the county of your residence or, at your election, by telephone or videoconference. Each party shall bear its own costs; arbitration fees shall be split as provided by AAA rules.

Class Action Waiver: To the maximum extent permitted by applicable law, you and Spentio agree that disputes will be resolved on an individual basis and that neither party will join or consolidate claims with those of other users or participate as a member of a class in any class action proceeding. If this waiver is found unenforceable in any jurisdiction, the entirety of this arbitration clause shall be void in that jurisdiction.

Small Claims Exception: Either party may bring an individual action in small claims court for disputes within its jurisdiction, provided the action remains in that court and is individual in nature.

16.6 Time Limitation

Any claim arising out of or related to these Terms must be filed within one (1) year after the cause of action arose, unless a longer period is required by mandatory applicable law. Claims filed after this period are permanently barred.

17. International Users & Regional Provisions

17.1 European Union & EEA

If you are a consumer in the EU/EEA, the mandatory consumer protection laws of your country of residence apply to the extent they provide a higher level of protection than these Terms. Your rights under the GDPR, the Consumer Rights Directive (2011/83/EU), the Digital Content Directive (2019/770), the Unfair Contract Terms Directive (93/13/EEC), and applicable national implementing legislation are not affected by these Terms.

17.2 United Kingdom

If you are a consumer in the United Kingdom, the Consumer Rights Act 2015 and UK GDPR apply. Your statutory rights are not affected by these Terms.

17.3 United States

If you are a resident of California, you have rights under the California Consumer Privacy Act (CCPA/CPRA) as described in our Privacy Policy, including the right to know, delete, and opt out of the sale of personal information. We do not sell your personal information. Additional state-specific privacy rights may apply depending on your state of residence (e.g., Colorado, Connecticut, Virginia, Utah).

17.4 Switzerland

If you are a resident of Switzerland, the Swiss Federal Act on Data Protection (nDSG/nLPD) applies in addition to these Terms. Your rights under the Swiss Code of Obligations regarding unfair contract terms are not affected.

18. Changes to Terms

We may modify these Terms from time to time. For material changes, we will provide notice through one or more of the following methods:

• Email notification to the address associated with your account
• Prominent in-app notification within the Service
• Updated "Last Updated" date at the top of this page

Material changes take effect no earlier than 30 days after notice is provided, unless a longer notice period is required by applicable law. Non-material changes (such as typographical corrections) may take effect immediately.

If you do not agree with the modified Terms, you must stop using the Service before the effective date. Continued use of the Service after the effective date constitutes your acceptance of the modified Terms.

EU consumers: In accordance with applicable EU consumer protection law, you will be given the option to expressly accept or reject material changes. If required by your local law, failure to reject shall not constitute acceptance.

19. General Provisions

19.1 Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it valid and enforceable, or if modification is not possible, severed. The remaining provisions shall continue in full force and effect.

19.2 Entire Agreement

These Terms, together with our Privacy Policy and Cookie Policy, constitute the entire agreement between you and Spentio regarding your use of the Service, and supersede all prior and contemporaneous agreements, communications, and proposals, whether oral or written.

19.3 Assignment

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations under these Terms to an affiliate or in connection with a merger, acquisition, reorganization, or sale of all or substantially all of our assets, provided that the assignee agrees to be bound by these Terms. Any assignment in violation of this section is void.

19.4 No Waiver

Our failure or delay in exercising any right or enforcing any provision of these Terms shall not constitute a waiver of that right or provision. Any waiver must be in writing and signed by us.

19.5 Force Majeure

Neither party shall be liable for any failure or delay in performing its obligations under these Terms due to circumstances beyond its reasonable control, including but not limited to natural disasters, pandemics, acts of government, war, terrorism, civil unrest, power or internet outages, cyberattacks, or failures of third-party service providers. The affected party shall use reasonable efforts to mitigate the impact and resume performance as soon as practicable.

19.6 Notices

All notices under these Terms shall be sent to the email address associated with your account (for notices to you) or to legal@spentioapp.com (for notices to us). Notices are deemed received when sent to the correct email address.

19.7 Accessibility

We are committed to making our Service accessible to all users. If you experience accessibility issues, please contact support@spentioapp.com.

20. Contact Information

For questions, concerns, or notices regarding these Terms:

We aim to respond to all inquiries within 5 business days. For data protection requests under the GDPR, we will respond within 30 days as required by law.