Acceptable Use Policy

Last updated: June 2026

This Acceptable Use Policy (“AUP”) governs your use of the ClearFact platform, operated by Creobyte Ltd (trading as ClearFact), company number 17228907.

1. Purpose

This policy exists to protect ClearFact users, third parties, and the integrity of our platform. By using ClearFact you agree to comply with this policy. Violation may result in immediate suspension or termination of your account.

2. Permitted Use

ClearFact is provided exclusively for:

  • Managing client relationships and cases in the context of regulated financial advice and mortgage broking
  • Collecting, storing, and processing client documentation and fact-find information
  • Communicating with clients in connection with regulated financial services
  • Administrative and operational management of your adviser practice

3. Prohibited Use

You must not use ClearFact to:

Illegal or harmful activity

  • Process personal data without a lawful basis under UK GDPR
  • Engage in any activity that violates UK law or FCA regulations
  • Facilitate money laundering, fraud, or financial crime
  • Process data relating to individuals under 16 years of age without appropriate safeguards

Data misuse

  • Upload personal data belonging to individuals who have not been informed of its use within ClearFact
  • Share account credentials with unauthorised individuals
  • Attempt to access data belonging to other ClearFact customers
  • Export or copy client data for purposes outside your regulated advisory activities
  • Use client data for marketing purposes without explicit consent

Technical abuse

  • Attempt to reverse engineer, decompile, or copy any part of the platform
  • Introduce malware, viruses, or malicious code
  • Conduct load testing, penetration testing, or vulnerability scanning without our prior written consent
  • Use automated scripts or bots to access the platform outside of authorised API integrations
  • Attempt to circumvent any security or authentication mechanism

Reputational harm

  • Use ClearFact in any way that damages or could damage the reputation of Creobyte Ltd
  • Misrepresent your firm’s FCA authorisation status within the platform

4. Client Data Standards

As a Data Controller for your clients’ personal data, you are responsible for:

  • Providing clients with appropriate privacy notices that reference ClearFact as a data processor
  • Obtaining all necessary consents before uploading sensitive personal data
  • Ensuring client data uploaded is accurate, relevant, and not excessive for the purpose
  • Actioning client data subject requests promptly using the tools provided in the platform

5. Reporting

If you become aware of any misuse of the ClearFact platform, or suspect a security incident, please report it immediately to [email protected].

6. Enforcement

We reserve the right to:

  • Suspend or terminate accounts found to be in breach of this policy
  • Report illegal activity to relevant authorities including the FCA, ICO, and law enforcement
  • Seek damages for breaches that cause harm to Creobyte Ltd or third parties

7. Contact

Creobyte Ltd (trading as ClearFact)

71-75 Shelton Street, Covent Garden, London, WC2H 9JQ

Company number: 17228907

Email: [email protected]