COMPLII

Complii Terms of Service

ControlBox Corp.

These Terms of Service (“Terms”) govern access to and use of the Complii Platform (“Platform”) operated by ControlBox Corp. (“ControlBox”, “Complii”, “we”, “our”, or “us”).

By accessing or subscribing to the Platform, the customer (“Customer”, “Subscriber”, or “you”) agrees to be bound by these Terms.

1. Description of Service

Complii is a cloud-based compliance platform designed to assist organizations with Anti-Money Laundering (AML), sanctions screening, customer risk scoring, transaction monitoring, and case management workflows.

The Platform may include:

  • sanctions list screening
  • politically exposed person (PEP) screening
  • watchlist matching
  • customer risk scoring
  • transaction monitoring alerts
  • case management workflows
  • compliance reporting and audit logs
  • API-based integrations
  • optional AI-assisted match analysis

Complii is provided as a technology platform to assist compliance operations.

Complii does not provide legal advice or regulatory determinations, and the Platform does not replace the Customer’s compliance responsibilities.

2. Customer Responsibilities

The Customer is solely responsible for:

  • complying with all applicable laws and regulations
  • maintaining appropriate AML/KYC policies and procedures
  • reviewing alerts and matches generated by the Platform
  • making final compliance determinations
  • filing any required regulatory reports

Complii provides analytical tools and automated screening services only.

All compliance decisions remain the sole responsibility of the Customer.

3. Platform Infrastructure & Security

Complii is hosted within secure infrastructure environments designed to follow internationally recognized security and operational standards.

The underlying hosting infrastructure and operational controls operate within environments aligned with:

  • SOC 2 security controls
  • ISO 27001 information security standards
  • ISO 9001 quality management practices

These standards support the protection of data confidentiality, integrity, and availability.

ControlBox implements commercially reasonable technical and organizational measures to protect the Platform and customer data. However, no internet-based system can guarantee absolute security.

4. Platform Availability

ControlBox will make commercially reasonable efforts to maintain 99.7% monthly platform uptime, excluding:

  • scheduled maintenance
  • emergency maintenance
  • force majeure events
  • third-party infrastructure failures
  • internet or network outages outside ControlBox control
  • customer integration issues

Availability is measured on a monthly basis.

ControlBox does not guarantee uninterrupted service.

5. Data Protection & Privacy (GDPR)

ControlBox processes customer data solely for the purpose of delivering the Complii service.

Where applicable, ControlBox will process personal data in accordance with applicable data protection regulations including:

  • General Data Protection Regulation (GDPR)
  • applicable privacy and data protection laws

ControlBox acts as a data processor when processing personal data submitted by Customers through the Platform.

Customers remain responsible for ensuring that they have the appropriate legal basis to process personal data through the Platform.

6. Customer Data Ownership

All data submitted to the Platform by the Customer, including customer information, screening records, transaction data, and compliance records, remains the exclusive property of the Customer.

ControlBox does not claim ownership of Customer data.

Customers may export or download their data at any time, subject to reasonable technical limitations.

Upon termination of service, Customers may request export of their stored data in standard formats within a reasonable period.

ControlBox may retain backup copies for operational, legal, or compliance purposes as required by law.

7. Third-Party Data Sources

Complii may incorporate data from:

  • sanctions lists
  • regulatory watchlists
  • publicly available sources
  • third-party compliance data providers

ControlBox does not guarantee the completeness, accuracy, or timeliness of such data. ControlBox is not responsible for errors, omissions, or delays originating from third-party data sources.

8. AI Feature Disclaimer

Certain optional features may include AI-assisted analysis of potential screening matches. These AI outputs are intended to assist analysts and must not be treated as final determinations.

Customers remain responsible for reviewing and validating AI-generated recommendations.

ControlBox disclaims liability related to:

  • automated classifications
  • algorithmic outputs
  • AI-generated decisions

9. Acceptable Use

Customers may not use the Platform to:

  • violate any applicable laws or regulations
  • screen individuals without lawful authority
  • attempt to reverse engineer the Platform
  • disrupt or interfere with system operations
  • access or attempt to access other customers’ data

ControlBox reserves the right to suspend or terminate access for misuse.

10. No Warranty

The Platform is provided “AS IS” and “AS AVAILABLE.”

ControlBox makes no warranties, express or implied, including:

  • merchantability
  • fitness for a particular purpose
  • regulatory compliance guarantees
  • accuracy of screening results
  • completeness of risk analysis

ControlBox does not guarantee that the Platform will detect or prevent money laundering, fraud, or sanctions violations.

11. Limitation of Liability

To the maximum extent permitted by law, ControlBox shall not be liable for:

  • regulatory fines
  • compliance violations
  • loss of profits
  • business interruption
  • loss of data
  • reputational damage
  • indirect, incidental, or consequential damages

arising from use of the Platform.

In no event shall ControlBox’s total liability exceed the total fees paid by the Customer during the twelve (12) months preceding the claim.

12. Payment Terms

Access to the Platform requires payment of subscription fees.

Fees may be based on:

  • screening volume
  • subscription tier
  • optional add-on features
  • API usage

All fees are non-refundable unless otherwise agreed in writing.

Failure to pay fees may result in suspension of service.

13. Termination

ControlBox may suspend or terminate service if:

  • these Terms are violated
  • payments are overdue
  • required by law or regulatory authority

Customers may terminate the service according to the terms of their subscription agreement.

14. Indemnification

Customers agree to indemnify and hold harmless ControlBox from claims, liabilities, or damages arising from:

  • the Customer’s use of the Platform
  • compliance decisions made by the Customer
  • violations of applicable laws or regulations

15. Changes to Terms

ControlBox may update these Terms periodically.

Material changes will be communicated via the Platform or by email.

Continued use of the Platform constitutes acceptance of the updated Terms.

16. Governing Law

These Terms are governed by the laws of the State of Florida, United States. Any disputes shall be resolved in courts located in Miami-Dade County, Florida.

17. Entire Agreement

These Terms constitute the entire agreement governing use of the Complii Platform unless superseded by a signed written agreement.