Terms of Service

First Line Done Ltd · Effective date: 28 February 2026 · Privacy Policy

These Terms of Service ("Terms") constitute a legally binding agreement between First Line Done Ltd ("FLD", "we", "us") and the organisation that has registered for or is using the First Line Done platform ("Customer", "you"). By accessing or using the Service you confirm that you have authority to bind the Customer and agree to these Terms. If you do not agree, do not use the Service.

1. Definitions

The following defined terms apply throughout these Terms:

"Service" — the First Line Done software-as-a-service platform, accessible at app.firstlinedone.com, including all features, APIs, and supporting infrastructure.
"Documentation" — the user guides, API references, and technical docs published at firstlinedone.com/docs.
"Customer Data" — all data, files, content, or information uploaded to or generated within the Service by the Customer or its Authorised Users, including entity records, transaction data, due diligence cases, SAR/STR reports, and UBO structures.
"Authorised User" — an employee, contractor, or agent of the Customer who has been granted access credentials to the Service.
"Subscription Plan" — the Starter, Professional, or Enterprise tier selected by the Customer, as described at firstlinedone.com/pricing.
"Order Form" — a written or electronic agreement specifying the Subscription Plan, fees, and any special terms.
"Confidential Information" — any non-public information disclosed by one party to the other that is marked confidential or would reasonably be understood to be confidential given the nature of the disclosure.
"Intellectual Property Rights" — all patents, copyrights, trademarks, trade secrets, database rights, and other intellectual property rights.
"DPA" — the Data Processing Addendum incorporated into these Terms (see clause 10), which governs processing of personal data.

2. Description of Service

First Line Done is an AI-assisted compliance platform designed for financial institutions. The Service includes, depending on the Subscription Plan:

Compliance & Due Diligence — entity onboarding, KYC workflows, UBO discovery, risk scoring, and automated due diligence reports.
Transaction Monitoring — real-time and batch monitoring against configurable rule sets, alert management, and case lifecycle management.
SAR/STR Filing — Suspicious Activity Report and Suspicious Transaction Report drafting with AI-assisted narrative generation and multi-jurisdiction submission workflows (UK NCA, US FinCEN, goAML).
Sanctions & Adverse Media Screening — automated screening against OFAC SDN, HM Treasury, and other sanctions lists, with World-Check integration available on Enterprise.
Customer Communication — secure document request portal and correspondence tracking with templated outreach.
Policy Management — policy repository with version control and regulatory update tracking.
API Access — RESTful API for integration with your existing systems (Professional and Enterprise plans).

Important: The Service is a workflow and decision-support tool. It does not constitute legal, compliance, financial, or regulatory advice. The Customer remains solely responsible for its own compliance obligations, regulatory filings, and the decisions made using outputs of the Service.

3. Account Registration and Security

3.1 Registration

You must provide accurate, complete, and current information when creating an account. Accounts are issued to organisations, not individuals. Each organisation receives one isolated workspace (tenant).

3.2 Authorised Users

The Customer is responsible for managing Authorised User accounts, assigning appropriate roles (Compliance Manager, MLRO, Analyst, Viewer, API User), and ensuring each user complies with these Terms. Credentials must not be shared between individuals.

3.3 Account Security

You must promptly notify us at legal@firstlinedone.com of any actual or suspected unauthorised access to your account. You are responsible for all activity that occurs under your account credentials. We strongly recommend enabling multi-factor authentication (MFA), which is available on all plans.

3.4 Account Minimums

You must be a legal entity or sole trader operating as a financial institution, regulated firm, or compliance service provider. Individual consumer accounts are not permitted.

4. Subscription Plans and Payment

4.1 Plans

The Service is provided on a subscription basis. Current plans and pricing are available at firstlinedone.com/pricing. Enterprise customers negotiate a separate Order Form. Plan features and user/entity limits are described in the Documentation.

4.2 Trials

New accounts receive a 14-day free trial on the Starter plan. No payment details are required during the trial. At trial expiry, access reverts to read-only until a paid plan is activated. Trial data is retained for 30 days after trial expiry.

4.3 Billing

Fees are billed in advance on a monthly or annual cycle via Stripe. Annual subscriptions are discounted and paid in full at the start of the billing period. Fees are non-refundable except as required by law or as expressly stated in an Order Form.

4.4 Taxes

All fees are exclusive of VAT and any other applicable taxes, which will be added at the prevailing rate. If you are VAT-registered, you may provide your VAT number during checkout.

4.5 Late Payment

If a payment fails, we will retry up to three times over seven days. Accounts with outstanding balances will be downgraded to read-only access after a 7-day grace period. Accounts unpaid for more than 30 days may be suspended or terminated.

4.6 Plan Changes

Upgrades take effect immediately; the difference is pro-rated to your next billing date. Downgrades take effect at the end of the current billing period.

5. Acceptable Use Policy

You agree not to, and will not permit Authorised Users to:

Use the Service for any purpose that is unlawful, fraudulent, or in violation of any applicable regulation, including anti-money laundering legislation.
Attempt to gain unauthorised access to any other tenant's data, systems, or accounts.
Reverse-engineer, decompile, or disassemble any part of the Service.
Use automated scrapers, bots, or crawlers to extract data from the Service except via the official API.
Introduce malware, ransomware, or any other malicious code into the platform.
Use the Service to conduct screening or generate SAR filings for entities in which you have an undisclosed conflict of interest.
Resell, sublicense, or make the Service available to third parties without our written consent.
Upload Customer Data that infringes third-party Intellectual Property Rights or applicable data protection law.
Exceed any API rate limits (100 requests/minute standard, 200 requests/minute burst) without prior written agreement.
Use the Service to file knowingly false or misleading SARs or conduct tipping-off in violation of POCA 2002 or equivalent legislation.

We reserve the right to suspend access immediately and without notice if we have reasonable grounds to believe your use is in material breach of this clause.

6. Customer Data and Ownership

6.1 Ownership

As between the parties, the Customer retains all right, title, and interest in and to Customer Data. You grant FLD a limited, non-exclusive, worldwide licence to store, process, and use Customer Data solely as necessary to provide the Service and as described in the DPA.

6.2 Data Quality

You are responsible for the accuracy, legality, and completeness of all Customer Data. FLD is not responsible for errors resulting from inaccurate data supplied by the Customer.

6.3 Data Export

You may export Customer Data at any time via the Service's export functionality. Upon termination, we will make Customer Data available for export for 30 days. After that period, we will delete it in accordance with the DPA.

6.4 Aggregate Analytics

FLD may use anonymised and aggregated data derived from Customer Data to improve the Service, provided such data cannot reasonably be used to identify the Customer or any individual. This does not constitute a transfer of Customer Data.

7. Intellectual Property Rights

7.1 FLD IP

All Intellectual Property Rights in the Service, platform, software, models, algorithms, documentation, and all derivative works thereof vest in and remain with FLD. These Terms do not transfer any ownership rights to the Customer.

7.2 Licence to Use

Subject to these Terms and payment of applicable fees, FLD grants the Customer a limited, non-exclusive, non-transferable, revocable licence to access and use the Service during the subscription term for the Customer's internal compliance operations.

7.3 Feedback

If the Customer provides feedback, suggestions, or ideas about the Service, FLD may use such feedback without restriction or compensation. The Customer irrevocably assigns all rights in such feedback to FLD.

8. Confidentiality

Each party agrees to maintain the other's Confidential Information in strict confidence using at least the same degree of care it uses for its own confidential information (but no less than reasonable care), and not to disclose it to any third party without prior written consent except:

to employees or contractors who need to know it for the purposes of this agreement and are bound by confidentiality obligations at least as protective as these Terms;
as required by law, regulation, or court order (in which case the disclosing party will, where lawful, give the other reasonable prior written notice); or
in connection with enforcing rights under these Terms.

Confidentiality obligations survive termination of these Terms for five (5) years, except for trade secrets which are protected indefinitely.

9. Service Availability

FLD targets 99.5% monthly uptime, excluding scheduled maintenance windows (notified at least 48 hours in advance) and circumstances beyond our reasonable control. Real-time service status is published at status.firstlinedone.com. Planned maintenance is performed outside peak hours (06:00–22:00 GMT).

Uptime credits for Service failures are available to Professional and Enterprise customers as set out in the relevant Order Form. Credits are the sole and exclusive remedy for downtime.

10. Data Processing and GDPR

FLD acts as a data processor in respect of personal data contained within Customer Data, and the Customer acts as the data controller. FLD acts as adata controller in respect of account and billing data for the institution.

Our Data Processing Addendum (DPA), which meets the requirements of the UK GDPR and EU GDPR (as applicable), is incorporated into and forms part of these Terms. The DPA is available at firstlinedone.com/privacy#dpa and governs how we process personal data on your behalf.

Where you upload personal data about your customers, employees, or other individuals, you warrant that you have a valid legal basis under applicable data protection law to provide that data to FLD for processing within the Service.

11. Warranties and Disclaimers

11.1 FLD Warranties

FLD warrants that: (a) it has the right to provide the Service; (b) it will provide the Service with reasonable skill and care; (c) the Service will materially conform to the Documentation; and (d) it maintains appropriate technical and organisational security measures.

11.2 Customer Warranties

The Customer warrants that: (a) it has authority to enter into these Terms; (b) Customer Data does not infringe any third-party rights or applicable law; (c) it is a regulated or compliance-focused entity and not a consumer; and (d) it will use the Service only for lawful purposes.

11.3 Disclaimer

EXCEPT AS EXPRESSLY SET OUT ABOVE, THE SERVICE IS PROVIDED "AS IS". FLD MAKES NO WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, OR NON-INFRINGEMENT. THE SERVICE IS A DECISION-SUPPORT TOOL ONLY AND DOES NOT CONSTITUTE LEGAL, REGULATORY, OR COMPLIANCE ADVICE. FLD DOES NOT WARRANT THAT THE SERVICE WILL BE ERROR-FREE, UNINTERRUPTED, OR THAT AI-GENERATED OUTPUTS WILL BE ACCURATE OR COMPLETE.

12. Limitation of Liability

12.1 Cap

Each party's total aggregate liability to the other in any 12-month period arising out of or in connection with these Terms (whether in contract, tort, statute, or otherwise) shall not exceed the total fees paid or payable by the Customer in the three (3) months immediately preceding the event giving rise to the claim.

12.2 Excluded Losses

Neither party shall be liable for indirect, consequential, incidental, punitive, or special losses, or loss of profits, revenue, goodwill, data, or business opportunity, even if advised of the possibility of such losses.

12.3 Exceptions

Nothing in these Terms limits liability for: (a) death or personal injury caused by negligence; (b) fraud or fraudulent misrepresentation; (c) any matter that cannot be excluded by law; or (d) indemnification obligations under clause 13.

13. Indemnification

Each party ("Indemnifying Party") will defend, indemnify, and hold harmless the other party and its officers, directors, and employees ("Indemnified Party") from and against any third-party claims, damages, and costs (including reasonable legal fees) arising from:

FLD's indemnity: any allegation that the Service (excluding Customer Data) infringes any third-party Intellectual Property Right.
Customer's indemnity: (a) the Customer's use of the Service in breach of these Terms; (b) Customer Data infringing third-party rights or applicable law; or (c) any regulatory action arising from the Customer's compliance decisions.

14. Term and Termination

14.1 Term

These Terms commence on the date the Customer creates an account or signs an Order Form and continue until terminated.

14.2 Termination by Customer

Monthly subscribers may cancel at any time via the billing portal; access continues until the end of the current billing period. Annual subscribers may terminate on written notice to legal@firstlinedone.com; fees for the remainder of the annual term are non-refundable.

14.3 Termination for Cause

Either party may terminate immediately on written notice if: (a) the other is in material breach and has not remedied the breach within 30 days of written notice; (b) the other becomes insolvent or enters administration; or (c) the other commits an act of fraud or wilful misconduct.

14.4 Effect of Termination

On termination: (a) all licences granted to the Customer immediately cease; (b) the Customer must cease using the Service; (c) Customer Data remains available for export for 30 days, after which it will be securely deleted; (d) clauses that by their nature should survive (including confidentiality, IP, liability, and governing law) will survive termination.

15. Force Majeure

Neither party will be liable for delays or failures in performance resulting from causes beyond its reasonable control, including acts of God, war, terrorism, government action, widespread internet outages, or pandemic events, provided the affected party: (a) notifies the other promptly; and (b) uses reasonable efforts to mitigate the impact.

16. Changes to Terms

We may update these Terms from time to time. We will notify you by email and by posting a notice in the Service at least 30 days before material changes take effect. Continued use of the Service after the effective date constitutes acceptance. If you do not agree with the updated Terms, you may terminate in accordance with clause 14.2.

17. Governing Law and Disputes

These Terms and any dispute or claim arising out of them shall be governed by and construed in accordance with the laws of England and Wales. The parties submit to the exclusive jurisdiction of the courts of England and Wales, except that either party may seek emergency injunctive relief in any court of competent jurisdiction.

18. General

Entire agreement. These Terms (together with any Order Form and the DPA) constitute the entire agreement between the parties and supersede all prior discussions or representations.
Severability. If any provision is found unenforceable, it will be modified to the minimum extent necessary, and the remainder of these Terms will continue in full force.
Waiver. Failure to enforce any right does not constitute a waiver of that right.
Assignment. The Customer may not assign these Terms without FLD's prior written consent. FLD may assign these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets.
Notices. Legal notices to FLD must be sent to legal@firstlinedone.com. Notices to the Customer will be sent to the email address registered on the account.
No third-party rights. These Terms do not confer any rights on third parties under the Contracts (Rights of Third Parties) Act 1999.
Relationship. The parties are independent contractors. Nothing creates a partnership, joint venture, agency, or employment relationship.

19. Contact

For questions about these Terms, please contact us at:

First Line Done Ltd
First Line Done Ltd, [Registered Address], United Kingdom
Email: legal@firstlinedone.com