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Fair Usage Policy

Last Updated: 29 September 2026 | Version 2.1

This Fair Usage Policy ("FUP") sets out the limits and expectations for use of the duely platform. It is designed to maintain reliable platform performance for all Subscribers (Firms) and to prevent abuse that could degrade our systems.

1. Scope

This FUP applies to every duely subscription, including any features marketed as "Unlimited". "Unlimited" refers to typical human usage by legal, accounting, and professional services firms in the normal course of AML/CTF compliance workflows, subject to the limits set out below.

2. Platform Capacity

duely has one subscription. Its capacity is set by the customer slots and users your Firm holds:

  • Users: three authenticated personnel are included. Extra users are added and removed month to month.
  • Included customer slots: thirty customer slots are included per subscription year, counted from your subscription date. A customer occupies a slot when activated (draft customers do not) and keeps it until your subscription anniversary, whether or not its engagements conclude earlier. A customer is active while it has an open engagement and becomes inactive automatically when its last engagement is concluded. A customer that returns for a new engagement within the same subscription year returns to the slot it held.
  • Flex customer slots: additional customer capacity purchased at the published monthly rate. A flex slot is released for reuse when the last engagement of the customer occupying it is concluded. A Firm may remove an empty flex slot at any time; the removal takes effect at the start of the next billing cycle.
  • Annual re-count: on each subscription anniversary, the customers a Firm still actively manages are allocated to its included slots first, and flex slots no longer required are cancelled automatically.
  • Counting rule: an individual occupies one customer slot. A company, trust, partnership, SMSF or other entity with up to six relevant individuals occupies one slot, and each further group of up to six relevant individuals occupies one more. A relevant individual is a person the Firm must maintain in duely for CDD, verification or screening (for example a director, trustee, beneficial owner or controller), not a contact person. An entity slot covers only the relevant individuals of that entity; individuals who are not must each be recorded as their own customer.
  • Storage: document storage (for example, identity documents, evidence packs, trust deeds) is subject to a fair-use quota displayed in your subscription dashboard.

Current capacity, usage and your subscription anniversary are displayed in your subscription dashboard.

Attempting to bypass these limits via technical manipulation is a breach of this policy and of the Master Subscription Agreement.

3. Post-Launch API Access and Rate Limiting

API access is on the roadmap and is not generally available. Where it is released, and a Subscriber is granted access:

  • API access is rate-limited. Standard limits are published in our developer documentation and dynamically enforced.
  • Bulk automated polling that exceeds limits may result in temporary IP or token-based throttling (for example, HTTP 429). Continued abuse may result in permanent revocation of API keys.

4. Prohibited Usage and Abuse

The duely platform is built to support standard compliance checks. The following constitute "Abuse" under this FUP:

  • Automated scraping. Using macros, bots, or browser automation tools (other than officially supported API integrations) to extract reports, scrape data, or mass-generate Evidence Packs.
  • Bulk harvesting / verification. Conducting automated mass uploads of identity assets or screening requests outside normal matter workflows (for example, running an entire historical database through verification overnight without prior authorisation).
  • Entity consolidation. Sharing one duely tenant or account across multiple distinct Reporting Entities (ABNs / ACNs) to avoid paying for multiple subscriptions. Each distinct corporate entity with its own AML/CTF obligations under the Act must maintain a separate duely subscription.
  • Slot misrepresentation. Creating or structuring customer records so that individuals who are not genuinely relevant individuals of a single entity (for example, grouping unrelated individual customers under one company, trust or other entity record) are counted against fewer slots than they would otherwise occupy. duely may re-count slots on the true representation of the customer relationship, and the Firm must purchase additional slots commensurate with that count.

5. Enforcement

If duely determines, in its reasonable discretion, that your usage breaches this Fair Usage Policy, duely may:

  1. Issue a formal warning to the Firm's Administrator or AMLCO.
  2. Temporarily throttle or restrict access to the offending functionality.
  3. Require the Firm to purchase customer slots or users commensurate with its usage, with consent where reasonably required by law.
  4. In cases of severe or repeated abuse, suspend or terminate the Subscription in accordance with the Master Subscription Agreement.

6. Governing Law

This Fair Usage Policy is governed by the laws of New South Wales, Australia.