This Master Subscription Agreement ("Agreement") is between Ilixir Technologies Pty Ltd (ABN 11 680 039 392, ACN 680 039 392), trading as Duely ("Duely"), and the Reporting Entity that accepts these terms ("Client", "Firm", or "Subscriber"). Duely provides AML/CTF compliance workflow and verification tools ("Platform" or "Services").

By accessing the Platform and accepting these terms electronically (including by clicking an "I agree" button or by continued use of the Platform), the Client agrees that this constitutes a binding agreement under the Electronic Transactions Act 1999 (Cth).

1. Description of Services

Duely offers a set of AML/CTF compliance tools, including identity verification, sanctions and PEP screening, risk assessment workflows, and audit trail record-keeping. The specific features accessible to the Client depend on the Subscription Tier selected by the Client.

1.1 Changes to the Services

(a) Duely may at any time modify, add, remove, or discontinue any feature, integration, or functionality of the Platform. Where a change materially reduces the functionality available to the Client during a paid term, Duely will, at the Client's election, either restore equivalent functionality or refund a pro-rata portion of the Fees for the affected period.

(b) Duely may make beta, preview, or experimental features available from time to time. Such features are provided "as is" and "as available", are not subject to any SLA, carry no warranty of any kind, and may be modified or withdrawn at any time without liability.

2. Limitation of Liability and Regulatory Role

Duely is a technology compliance tool. Duely is not a professional advisor, legal counsel, or accounting firm.

The Platform provides structured workflows to assist Reporting Entities in meeting obligations under the AML/CTF Act 2006 (Cth).
Final compliance responsibility, including all decision-making about risk ratings and Suspicious Matter Reports (SMRs), rests with the Client and the Client's appointed AML Compliance Officer (AMLCO).
The Platform's verification workflows are designed to support risk-based customer identification and verification against reliable and independent data and documents, as required by the AML/CTF Act and the AML/CTF Rules. Completing a workflow does not of itself establish that verification is sufficient for a particular customer. The Client's AMLCO must decide, for each customer, whether the verification carried out meets the Client's obligations and its AML/CTF program.
Identity opinions, verification results and screening results produced through the Platform are based on information supplied by third parties, including verification providers, data providers and government agencies, which Duely does not independently verify.
Use of the Platform does not guarantee a "Pass" from an AUSTRAC assessment and does not confer immunity from regulatory action, fines, or penalties under the AML/CTF Act.

2.1 Cap on Liability

(a) Subject to clause 2.1(c), the total aggregate liability of Duely to the Client for all claims arising under or in connection with this Agreement, whether in contract, tort (including negligence), under statute, in equity, or otherwise, is limited to the greater of:

the Fees paid by the Client to Duely under this Agreement in the twelve (12) months immediately preceding the first event giving rise to the claim; or
AU$100.

(b) To the maximum extent permitted by law, Duely is not liable to the Client for any:

loss of profit, revenue, savings, business, opportunity, goodwill, reputation, production, anticipated savings, or contract;
loss or corruption of data;
loss arising from the accuracy, completeness, availability or timeliness of information provided by a government agency, registry, data provider or verification provider;
regulatory fine, penalty, or enforcement cost imposed on the Client or any of its officers, employees, or agents;
indirect, consequential, special, incidental, exemplary, or punitive loss or damage,

however arising and whether or not Duely was advised of, or knew of, the possibility of that loss or damage.

(c) Nothing in this Agreement excludes, restricts, or modifies any right or remedy of the Client that cannot lawfully be excluded, restricted, or modified, including any consumer guarantee under the Australian Consumer Law. To the extent permitted by section 64A of the Australian Consumer Law, Duely's liability for failure to comply with a non-excludable consumer guarantee is limited, at Duely's election, to the re-supply of the Services or the cost of re-supplying the Services.

2.2 Indemnification by the Client

The Client agrees to indemnify, defend, and hold harmless Duely, its officers, directors, employees, and agents from and against any claim, liability, damage, loss, and expense (including reasonable legal fees on a solicitor-and-own-client basis) arising out of or in connection with:

(a) the Client's use of the Platform in breach of this Agreement or applicable law;
(b) inaccurate, incomplete, or misleading data inputted by the Client or its users;
(c) the Client's failure to comply with its obligations under the AML/CTF Act 2006 (Cth), including tipping-off violations caused by the Client's personnel;
(d) any third-party claim arising from the Client's AML/CTF compliance decisions made using the Platform;
(e) the Client's failure to maintain appropriate consents and notifications under the Privacy Act 1988 (Cth) for the personal information it submits to the Platform;
(f) any AUSTRAC enforcement action, civil penalty proceeding, or remedial order brought against the Client;
(g) the Client's breach of clause 2A, and any amount Duely becomes liable to pay a government agency, registry, gateway or verification provider under Duely's agreements with them (including under any indemnity Duely has given them), and any claim, audit finding, cost or penalty asserted against Duely by any of them or by an individual, to the extent arising from the Client's use of the identity verification features or from any individual whose identity the Client asked Duely to check; and
(h) any misuse by the Client or its Authorised Users of identity information, identity opinions, verification results or screening results.

The indemnities in this clause 2.2 are not subject to the cap in clause 2.1. The Client's liability under each indemnity in this clause 2.2 is reduced to the extent that the relevant claim, liability, damage, loss, or expense was caused by Duely's negligence, wilful misconduct, or breach of this Agreement.

2.3 Warranty Disclaimer

(a) Except as expressly set out in this Agreement and to the maximum extent permitted by the Australian Consumer Law, Duely provides the Platform on an "AS IS" and "AS AVAILABLE" basis. Duely makes no warranties, express or implied, regarding the Platform's fitness for a particular purpose, merchantability, or non-infringement. The Client acknowledges that no compliance tool can guarantee regulatory outcomes. Without limiting clause 2.1, Duely's liability in respect of any identity check, verification result or screening result is limited, at Duely's election, to re-performing the check or refunding the fee charged for it.

(b) The Platform is not designed, intended, or authorised for use in any application where failure or error could result in death, personal injury, or serious financial, environmental, or property damage. The Client shall not use the Platform for any such application, and Duely disclaims all liability arising from any such use.

2.4 No Advisory or Client Relationship

Duely provides software tools only. Access to or use of the Platform (including any trial, evaluation, promotional, or beta tier) does not create any professional, advisory, fiduciary, agency, or client–adviser relationship between Duely and any user, and does not constitute compliance, legal, financial, or other professional advice. Each Firm and Reporting Entity remains solely responsible for its own compliance obligations, judgements, decisions, and outcomes, including all decisions about customer due diligence, risk ratings, and Suspicious Matter Reports. Nothing on the Platform or the Duely website should be relied upon as a substitute for advice from a qualified professional.

2A. Identity Verification Services

2A.1 What Duely provides. Where the Client uses the Platform's identity verification features, Duely provides an identity opinion: an assessment of an individual's identity or of an identity document formed from one or more checks, which may include document analysis, biometric liveness and face-match, matching against reliable and independent data sources, screening, and checks made through third-party or government verification services. An identity opinion is not a guarantee of identity, is not a government record, and does not disclose the underlying result of any third-party or government check. The Client remains responsible for its customer due diligence decisions.

2A.2 Client warranties. The Client warrants, and must ensure at all times while it uses the identity verification features, that it: (a) is a legal entity carrying on business in Australia and subject to Australian law, and has given Duely accurate details from which Duely can establish its identity; (b) is subject to the Privacy Act 1988 (Cth) or is a reporting entity under the AML/CTF Act 2006 (Cth), or otherwise agrees to comply with the Australian Privacy Principles as if it were an APP entity; (c) uses the identity verification features only for its own customer due diligence and not as agent for any other person; and (d) meets, and will continue to meet, any access or eligibility requirements published by the government agency or provider administering a verification service that Duely uses, as they apply to a client of an identity service provider. The Client must tell Duely promptly if any of these warranties stops being true, and must keep the business, contact and authorised-officer details it has given Duely accurate and current.

2A.3 Consent and notice. Before requesting any identity check the Client must ensure that the individual has been given the collection notice presented in the Platform and has given express consent in the form the Platform captures, and must keep records of that notice and consent. The Client must not request a check for an individual who has withdrawn consent, and acknowledges that consent given for a series of checks lapses after three months. The Client must present the collection notice and consent wording as provided in the Platform without alteration, must obtain consent from a parent or guardian where the individual is under 15 or otherwise lacks capacity, and must give Duely a copy of any consent record within five business days of a request so that Duely can meet its own obligations to its verification providers and the agencies administering them.

2A.4 Use of results. The Client must use identity opinions, verification results and screening results only to verify, or contribute to verifying, the identity of its customers and for its AML/CTF obligations. The Client must not: (a) attempt to derive, infer or record the underlying result of any third-party or government verification check; (b) use information collected for an identity check to build a profile of an individual, to offer or market goods or services, to enable anyone else to do so, or for market research; (c) use identity information, opinions or results to update, validate or enrich any other data or database; (d) disclose identity opinions or results except as the law requires or permits; or (e) rely on an identity opinion as the only evidence of a person's identity in any legal proceeding.

2A.4A Who may be checked. The Client may request an identity check only in respect of a person who is, or is proposing to become, a customer of the Client (or a beneficial owner, controller, agent or associated party of such a customer) for the purpose of the Client's customer due diligence under the AML/CTF Act 2006 (Cth). The Client must not use the identity verification features to screen its own employees or contractors, for tenancy, credit, marketing or any other purpose, or in respect of any person with whom it has no such relationship.

2A.5 Alternative process. The Client must maintain a process for verifying the identity of an individual whose identity cannot be verified through the Platform, and must not take adverse action against an individual solely because a check could not be completed.

2A.6 Availability. Third-party and government verification services are provided to Duely on an "as is, as available" basis with no service levels. Duely may suspend or withdraw identity verification features immediately if a government agency, gateway or verification provider suspends, restricts or withdraws access or changes its terms, or if Duely reasonably believes the Client is in breach of this clause 2A. Duely may also withdraw the identity verification features, or any check type, on fourteen (14) days' notice. No service credits, refunds or damages are payable for the unavailability, suspension or withdrawal of a third-party or government verification service beyond, where a fee was charged, re-performing the check or refunding that fee. Clause 7 does not apply to third-party or government verification services.

2A.7 Audit and cooperation. The Client acknowledges that Duely's use of third-party and government verification services is subject to audit by the agencies and providers administering them, and agrees to cooperate with any such audit, including by giving reasonable access to its records, systems and, where an agency requires it, premises relating to identity checks requested through the Platform, and to keep its contact details current with Duely.

2A.8 Third-party benefit. All disclaimers, exclusions, limitations of liability and indemnities in this Agreement are also for the benefit of each government agency and each gateway or verification provider whose services Duely uses to deliver the identity verification features, and may be enforced directly by them or by Duely on their behalf.

2A.9 Fees. Identity checks that use a third-party or government verification service may be charged per document per attempt at the rate shown in the Platform, whether or not the check returns a match, in addition to subscription Fees. Clause 5.1(d) applies to changes in the underlying provider or government charge. Fees for a check are payable whether or not the Client's user requested it in error.

2A.10 Location of users. The Client must ensure that identity checks are requested only by Authorised Users located in Australia or New Zealand, unless Duely has agreed otherwise in writing. Duely may need to notify a government agency before any person outside Australia or New Zealand may request checks, and may refuse or delay such a request.

2A.11 Access, training and credentials. The Client must limit access to identity information, identity opinions and screening results to Authorised Users who need it for the Client's customer due diligence and have been trained in handling personal information; keep credentials confidential; and is responsible for every identity check requested using its users' credentials, whether or not authorised.

2A.12 Security incidents. The Client must notify Duely at [email protected] immediately, and in any event within 24 hours, if it knows or suspects that a credential has been compromised, that the identity verification features have been accessed or used without authority, or that identity information obtained through the Platform has been lost, accessed, modified or disclosed without authority, and must give Duely the information and cooperation it reasonably requests. Where such an incident arises from the acts or omissions of the Client or its users, the Client bears the reasonable costs of investigation, notification and remediation that Duely incurs, including any amount Duely must pay to a verification provider or government agency.

2A.13 Statements about the service. The Client must not: (a) state or imply that Duely, the Platform or any identity check is approved, endorsed, accredited or certified by any government agency; (b) make any public statement about Duely's access to or use of any government verification service; (c) use the name, logo or trade marks of Duely or of any of Duely's verification providers or the agencies administering them, in any customer-facing or marketing material without Duely's prior written consent; or (d) describe an identity opinion to its customers or anyone else as a government or provider result.

2A.14 Single point of contact. Duely is the sole point of contact for any issue relating to identity checks requested through the Platform. The Client must not contact Duely's verification providers or the agencies administering government verification services about such checks, and must refer any query, complaint or request from an individual about an identity check to Duely and cooperate in resolving it.

2A.15 Records. The Client must keep records of the identity checks it requests, the individuals concerned, the notices given and consents obtained, and the decisions it made, for at least seven (7) years, and must provide them to Duely within five business days of a request made for the purpose of an audit, complaint or regulatory inquiry.

2A.16 Regulator and agency inquiries. If a regulator, government agency, verification provider or individual raises an inquiry, audit finding, complaint or claim with Duely that relates to an identity check requested by the Client, the Client must give Duely all information and assistance reasonably required, and must reimburse Duely's reasonable costs of responding to the extent the matter arises from the Client's use of the identity verification features.

2A.17 Duely's right to decline or withdraw. Duely may decline to enable, or may withdraw, the identity verification features for a Client without liability if the Client does not meet or ceases to meet clause 2A.2, if a government agency or verification provider objects to or restricts the Client's use, or if Duely reasonably suspects misuse. Duely may verify the Client's identity and standing, including against public registers, before enabling the features and from time to time afterwards.

3. Data Ownership and Licensing

Client Data: The Firm retains full ownership of all Customer and Matter data inputted into the Platform. Duely is granted a limited, non-exclusive, non-transferable licence solely to host, process, and transmit that data as needed to provide the Services.
Intellectual Property: AML/CTF Program content generated by the Firm using Duely's wizards or workflows is the exclusive property of the Firm. Duely retains all intellectual property rights in the Platform itself, including its features, codebase, UI/UX, methodologies, templates, algorithms, configurations, and workflows.

4. Tipping-Off and Confidentiality (s123 AML/CTF Act)

Duely takes the tipping-off offence (s123 of the AML/CTF Act) seriously. The Platform provides Role-Based Access Controls (RBAC) to support internal data compartmentalisation. The Client acknowledges that ultimate responsibility for ensuring users do not breach tipping-off laws rests with the Firm and the Firm's designated AMLCO. The Client warrants that it has implemented internal policies, controls, and training so that personnel understand and comply with s123. Duely accepts no liability for tipping-off violations caused by any user of the Firm.

4A. Confidentiality

Each party agrees to treat as confidential all non-public information received from the other party during this Agreement, including business information, pricing, technical data, and Platform internals ("Confidential Information"). Neither party shall disclose the other's Confidential Information to any third party without prior written consent, except:

as required by law, regulation, or court order;
to professional advisors bound by confidentiality obligations; or
to employees or contractors who need access to perform obligations under this Agreement and are bound by equivalent confidentiality terms.

This obligation survives termination of this Agreement for a period of three (3) years.

5. Subscriptions, Fees, and Suspension

Fees are billed in advance based on the selected tier and billing cycle.
Duely may suspend Platform access (i) for non-payment after a 7-day grace period, (ii) immediately for any breach of the Acceptable Use Policy, (iii) immediately where Duely reasonably believes continued access poses a security risk to the Platform or to other Subscribers, (iv) where required by law or regulator direction, or (v) immediately in respect of the identity verification features where clause 2A.6 applies. During suspension, the Firm's data will be preserved securely.
Duely may also suspend access for any other material breach of this Agreement that the Client fails to cure within seven (7) days of written notice.

5.1 Fee Changes

(a) Duely may change the Fees for any Subscription Tier with effect from the next renewal of the Client's Subscription, by giving the Client at least thirty (30) days' written notice (which may be delivered by email or by in-Portal notice) before the renewal date.

(b) For Clients on monthly billing cycles, Duely may change the Fees with effect from the next billing cycle by giving at least thirty (30) days' written notice.

(c) If the Client does not accept a Fee change, the Client may terminate the Subscription with effect from the date the Fee change would take effect by giving written notice to Duely before that date. Continued use of the Platform after the effective date of the Fee change constitutes acceptance of the new Fees.

(d) Despite (a) and (b), Duely may pass through any increase in third-party pass-through costs (including identity verification, registry data, payment processing, or hosting costs) on shorter notice, capped at the actual increase.

5.2 Term and Renewal

(a) Each Subscription automatically renews for successive periods equal to the initial term (monthly or annual) at the then-current Fees, unless either party gives written notice of non-renewal at least thirty (30) days before the end of the current term.

(b) The Client acknowledges that the Subscription will be charged automatically to the payment method on file on each renewal date.

5.3 Termination

(a) By Duely for convenience: Duely may terminate this Agreement or any Subscription for convenience by giving the Client at least sixty (60) days' written notice. On such termination, Duely will refund any prepaid Fees pro-rata for the unused remainder of the then-current term.

(b) By the Client for convenience: The Client may cancel the Subscription at any time via the billing portal in the Platform. Cancellation takes effect at the end of the then-current billing period in accordance with the Refund and Cancellation Policy. No pro-rata refund is payable on cancellation by the Client outside the 14-day cooling-off period set out in that policy.

(c) By either party for cause: Either party may terminate this Agreement immediately by written notice if the other party (i) commits a material breach that is not remediable, (ii) commits a material breach that is remediable and fails to remedy it within fourteen (14) days of written notice, or (iii) becomes insolvent, bankrupt, or subject to external administration.

(d) By Duely for AUP breach: Duely may terminate immediately for any breach of the Acceptable Use Policy. No refund is payable on termination under this clause.

5.4 Payment Terms

(a) Invoices are payable within fourteen (14) days of issue.
(b) Overdue amounts accrue interest at the Reserve Bank of Australia cash rate plus four percent (4%) per annum, calculated daily and compounded monthly, until paid.
(c) Duely may recover all reasonable costs of collection, including legal fees and debt-collection agency fees.
(d) All Fees are stated exclusive of GST, which the Client is liable to pay where applicable.

5A. Trial Terms

If Duely offers a trial, evaluation or promotional period, the following apply during that period:

All terms of this Agreement apply, including limitation of liability and acceptable use obligations.
Duely may limit features, storage, or support during the trial period.
Duely may modify, restrict, or terminate a trial at any time with reasonable notice and without liability.
No refunds apply to trial periods. On trial expiry, access to paid features will be suspended unless a paid Subscription is activated.

6. Audit Vault and Data Retention

Duely maintains tamper-evident evidence packs and matter records (content-hashed at creation and recorded in an append-only audit log) for the active duration of the Subscription, to assist the Firm in its 7-year record-keeping obligations.
Data Export and Termination: On expiration or termination of a Subscription, the Firm has a 90-day export window to download all data, including evidence packs, matter records, and audit logs.
After 90 days following expiration, all Client data is permanently deleted in accordance with the retention schedule in the Privacy Policy, except records that Duely must keep under law or under its agreements with government or third-party verification services (which are held by Duely in minimised form and do not form part of the Client's export). An optional Certificate of Data Destruction is available to Enterprise-tier Clients on request at that time.
Biometric images captured for a face match are retained as set out in the Privacy Policy retention schedule; the face-match and liveness result, provider reference and image hash are retained with the verification record.

7. Service Level Agreements (SLA)

Uptime: Duely targets a 99.5% monthly uptime, excluding planned maintenance, force majeure, and third-party-service failures.
Maintenance: Planned maintenance windows will be communicated to Firms at least 48 hours in advance.
Support response targets:
- Standard/Starter Tier: next business day.
- Professional Tier: 4 business hours.
- Enterprise Tier: 1 business hour.
The SLA is a service target and not a warranty. Service credits (if any) are the Client's sole and exclusive remedy for failure to meet the SLA.

8. General Provisions

8.1 Changes to Terms

Duely may update this Agreement from time to time. Material changes will be notified to the Administrator email on file at least thirty (30) days before they take effect and may require re-acceptance on next sign-in. Continued use of the Platform after the effective date of a change constitutes acceptance.

8.2 Force Majeure

Neither party is liable for any failure or delay in performing obligations under this Agreement to the extent caused by circumstances beyond its reasonable control, including natural disasters, pandemic, government actions, war, terrorism, power failures, internet outages, or failures of third-party service providers. The affected party shall promptly notify the other and use reasonable efforts to mitigate the impact.

8.2A Third-Party Services

The Platform integrates with third-party and government services, including identity verification, screening, payment, and registry providers. Duely is not liable for any failure, delay, error, downtime, change in functionality or pricing, or discontinuation of any third-party service, and may modify or replace any third-party integration on reasonable notice to the Client.

8.3 Dispute Resolution

Any dispute arising out of or in connection with this Agreement shall be resolved as follows:

Negotiation: The parties shall first attempt to resolve the dispute through good-faith negotiation between senior representatives within thirty (30) days of written notice.
Mediation: If negotiation fails, the parties agree to submit the dispute to mediation administered by the Australian Disputes Centre (ADC) in Sydney, New South Wales, before commencing litigation.
Litigation: If mediation fails to resolve the dispute within sixty (60) days, either party may commence proceedings in the courts of New South Wales, Australia.

Nothing in this clause prevents either party from seeking urgent injunctive or equitable relief from a court of competent jurisdiction.

8.4 Assignment

Neither party may assign or transfer this Agreement or any rights or obligations under it without the prior written consent of the other party, except that Duely may assign this Agreement to a successor entity in connection with a merger, acquisition, restructure, or sale of all or substantially all of its assets, provided that the successor agrees to be bound by the terms of this Agreement.

8.5 Severability

If any provision of this Agreement is found by a court of competent jurisdiction to be invalid, illegal, or unenforceable, the remaining provisions continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving the parties' original intent.

8.6 Entire Agreement and Order of Precedence

This Agreement, together with the Data Processing Agreement (DPA), Privacy Policy, Acceptable Use Policy (AUP), Fair Usage Policy (FUP), and Regulatory Disclaimer, constitutes the entire agreement between the parties and supersedes any prior representations or agreements relating to its subject matter. In the event of conflict between these documents, the following order of precedence applies:

Data Processing Agreement (DPA)
Master Subscription Agreement (MSA)
Regulatory Disclaimer
Privacy Policy
Acceptable Use Policy (AUP)
Fair Usage Policy (FUP)

8.7 Governing Law

This Agreement is governed by the laws of New South Wales, Australia. The parties submit to the non-exclusive jurisdiction of the courts of New South Wales.

8.8 Survival

Clauses 2 (Limitation of Liability and Regulatory Role), 2.1 (Cap on Liability), 2.2 (Indemnification by the Client), 2.3 (Warranty Disclaimer), 2A (Identity Verification Services), 3 (Data Ownership and Licensing), 4 (Tipping-Off and Confidentiality), 4A (Confidentiality), 5 (for amounts then owing), 5.4 (Payment Terms), 6 (Audit Vault and Data Retention), 8.3 (Dispute Resolution), 8.7 (Governing Law), 8.8 (Survival), 8.9 (Notices), 8.10 (Publicity), and 8.11 (Restrictions) survive termination or expiration of this Agreement.

8.9 Notices

Any notice under this Agreement must be in writing and is given when:

(a) sent by email to [email protected] (to Duely) or to the Administrator email on file (to the Client), with delivery confirmation; or
(b) delivered by registered post to the registered office of Ilixir Technologies Pty Ltd as recorded on the ASIC register.

A notice sent after 5:00pm Sydney time is deemed received the next business day.

8.10 Publicity

The Client grants Duely a non-exclusive, royalty-free licence to use the Client's name and logo in Duely's customer lists, website, and marketing materials, identifying the Client as a customer of Duely. The Client may revoke this licence at any time by written notice to [email protected].

8.11 Restrictions

The Client must not, and must not permit any third party to:

(a) resell, sublicense, or make the Platform available to any person other than Authorised Users of the Client;
(b) use the Platform to build, train, or benchmark a competing product or service;
(c) reverse-engineer, decompile, disassemble, or attempt to derive the source code, structure, or algorithms of the Platform, except to the minimum extent permitted by law;
(d) remove, obscure, or alter any proprietary notice on the Platform; or
(e) use the Platform in any manner that could damage, disable, overburden, or impair the Platform or interfere with any other party's use.

8.12 Definitions

In this Agreement, capitalised terms have the meanings given to them where first used. The following defined terms apply throughout:

"Authorised User" means an individual employee or contractor of the Client whom the Client has authorised to access the Platform under the Client's Subscription.
"Fees" means the subscription and usage fees payable by the Client for the Services.
"Platform" or "Services" means the Duely software-as-a-service platform and any associated tools, integrations, and documentation made available by Duely.
"Subscription" means the Client's then-current subscription to the Platform.
"identity check" means a verification, screening or document check requested through the Platform in respect of an individual or entity.
"identity opinion" has the meaning given in clause 2A.1.
"collection notice" means the notice presented in the Platform to an individual before an identity check that uses their personal information.
"verification provider" means a third party, gateway or government service through which Duely obtains identity, document, biometric or screening results.
"Subscription Tier" means the tier of Service selected by the Client (for example, Starter, Professional, Enterprise).

Master Subscription Agreement (MSA) / Terms of Service