These Terms & Conditions are effective from 4 March 2025
1.1 CLFNCE OÜ ("Cleo"), established in accordance with the laws of Estonia, with its registered office at Harju maakond, Tallinn, Kesklinna linnaosa, Järvevana tee 9, 11314, Estonia, Company ID No. 17165857, is the exclusive owner and operator of the cleo.finance application ("App").
1.2 As used in these Terms, "we", "our", and "us" refer to Cleo or any successor, subsidiary, affiliate, assign, or licensee of Cleo.
1.3 "Service(s)" refers to Your use of the App for any purpose whatsoever, including, but not limited to:
Subject to compliance with the terms and conditions set forth in these Terms, You may access the App via the interface made available by us to You for such purposes. You acknowledge and agree that You have relied on Your own judgment to choose, create, develop, and/or adapt Your trading strategies and orders and that You have not relied and will not rely on us, nor our agents, brokers, affiliates, directors, officers, representatives, or employees, with respect to any order, transaction, effectiveness of any trading strategies, or trading methods in any way.
1.4 "You" refers to the user of the App and its related Services, and as such, You have gained the right to use the App by respecting the applicable Terms and Conditions ("Terms") described in detail below.
1.5 These Terms set forth the terms and conditions that apply to Your use of the App and all Services offered by us.
1.6 By completing the registration process or by using the App, You agree to be bound by these Terms.
1.7 Please save or print and keep a copy of these Terms for Your records.
1.8 "Information" refers to any data processed or displayed within the App, including but not limited to:
1.9 Within the Services, we provide access to multiple asset classes, categorized as follows:
1.10 Regulatory Status: Cleo is a Software-as-a-Service (SaaS) platform that provides technology for research and execution of trading strategies. Cleo does not provide financial, investment, or brokerage services, does not execute trades on behalf of users, and does not hold or manage user funds. Users may connect their accounts on third-party trading platforms (e.g., Binance, ByBit, OKX) via API, but all transactions are executed by the third-party platform, and Cleo solely facilitates the technical infrastructure for trade automation and order placement. Cleo is not responsible for service disruptions, security risks, or policy changes imposed by third-party exchanges or trading platforms. Users acknowledge that their accounts on third-party platforms are subject to the terms of those services.
1.11 Compliance and Data Protection: Cleo complies with applicable European Union regulations, including GDPR, to protect user data and privacy. Users can review Cleo's Privacy Policy for further details on data collection and processing.
1.12 Restricted Jurisdictions: You may not use the Services if you are:
1.13 These Terms apply to all Customers of the Services, including, but not limited to, Customers who contribute Content, Information, and other materials or services, whether registered or otherwise.
2.1 In order to use the Services, you must first agree to these Terms. You may not use the Services if you do not accept the Terms.
2.2 You can accept the Terms by:
2.3 You may not use the Services and may not accept the Terms if:
2.4 By using the App and any Information, you agree to comply with and be bound by these Terms.
2.5 By registering to the App, You certify that all Information You provide during registration is accurate. You must maintain a valid e-mail address registered with Cleo at all times. If an email sent to You by Cleo bounces for any reason, Your account may be temporarily suspended until You provide a verifiable e-mail address.
3.1 Legal entities and entrepreneurs may not use the Services for any purpose without our express prior written consent.
3.2 By accessing the App or accepting these Terms, you represent and warrant that you:
3.3 Users from sanctioned countries or jurisdictions (as per EU and international laws) are strictly prohibited from using the Services. Cleo reserves the right to terminate accounts that violate applicable sanctions laws.
3.4 The Services are offered solely for your personal use and not for the benefit of any third party.
4.1 You agree and understand that You are responsible for maintaining the confidentiality of passwords associated with any Account You use to access the Services.
4.2 Accordingly, You agree that You will be solely responsible for all activities (including all statements and acts) that occur under Your Account.
4.3 If You become aware of any unauthorized use of Your password or of Your Account, You agree to notify us immediately.
4.4 You agree and understand that You are responsible for maintaining the confidentiality of Your password(s), which, together with Your login e-mail address, allows You to access certain portions of the App or Services.
4.5 By providing Cleo with Your e-mail address, You agree to receive all required notices and other correspondence electronically to that e-mail address. It is Your responsibility to update or change that address, as appropriate. If You become aware of any unauthorized use of Your registration Information, You agree to notify Cleo in writing immediately.
5.1 Information in the App, including any posts made by advertisers or users, is not verified by Cleo. Cleo cannot and does not warrant the completeness or accuracy of the Information or its usefulness for any particular purpose. Accordingly, You acknowledge that this App, in particular if You connect the App to the services provided by third parties as set out in Article 12 of these Terms, may not contain complete, accurate, and/or true information.
5.2 In the case of connecting to services provided by third parties, You must enter so-called API keys, which consist of a public key and a secret key (hereinafter referred to as the "API keys"). By entering the API keys, You have the possibility to grant us certain rights. For the functionality of the Application, it is advisable to give us the right to read account data and the right to trade in order to use the Application in its entirety. If You make available to us the rights to deposit and/or withdraw funds, we will not use those rights and will not be liable for any use or abuse of those rights if You have made them available to another user or other third party.
5.3 In the case of connection with the services provided by third parties referred to in clause 5.2 above, You will be asked to enter Your API keys for trading accounts. You acknowledge that the API keys are sensitive information and that it is technically possible for the holders of Your API keys to copy or replicate trades on Your account without Your knowledge. If You have the right to withdraw and/or deposit funds, there is a risk that Your account could be accessed or funds withdrawn without Your knowledge. Cleo will store API keys in an encrypted format in accordance with its Privacy Policy but will not be liable for any loss if You give Your API keys to third parties or if third parties acquire such API keys in an unauthorized manner.
5.4 You shall indemnify and hold us harmless from all claims and all liabilities, costs, proceedings, damages, and expenses awarded against or incurred by us as a result of or in connection with Your breach of the Terms or any third party's intellectual property or similar rights.
5.5 The Content and Information, including all intellectual property related to and all rights, title, and interest in the App, is the property of Cleo and is protected by copyright laws. All improvements, modifications, and derivative works thereof, as between You and us, shall remain the sole property of Cleo. Any copying, distribution, storage, or transmission of any kind, or any sort of commercial use of the Information, is strictly prohibited without Cleo's prior written permission.
5.6 If You become aware of any violation of our (or our third-party service providers') proprietary rights in the App, You will immediately notify us in writing.
5.7 In the case of displaying a value within any of Your accounts, the processing of results statistics for better use of the Application rounds the value to two decimal places. The result statistics may not show the actual balance of Your accounts. This does not apply to displaying a value within any of Your accounts when processing Digital Asset outcome statistics, where values may be rounded up to eight decimal places. The outcome statistics may not reflect the actual balance of Your accounts.
6.1 Among other things, You can use the Services and the App to design trading strategies ("Trading Strategy"). Your Trading Strategy will be automatically converted into a complex trading algorithm ("Trading Algorithm") that, if available, can be backtested against historical data. You acknowledge and agree that while designing the Trading Strategy, You have relied on Your own judgment and have read the disclaimer set out in Article 25.4 of these Terms.
6.2 Original and non-infringing Trading Strategies that are both fully developed and uniquely provided by You in the App, or that are created by us for You in connection with a separate professional services engagement, shall be and remain Your property. You acknowledge, however, that it cannot be excluded that someone else in the future may design a similar or identical Trading Strategy, and You agree not to make any claims or allegations against any such future Trading Strategies that would be designed independently without reference to Your Trading Strategy.
6.3 By creating and submitting a Trading Strategy, You grant us a worldwide, royalty-free, and non-exclusive license for the term of the Services to use, reproduce, adapt, modify, and publish the Trading Strategy through the Services.
6.4 You also acknowledge and agree that we own all legal rights, title, and interest in and to the Trading Algorithm, including any intellectual property rights (such as copyrights and trademarks) that subsist in the Trading Algorithm.
7.1 To place an order, enter into a transaction, or sign up for certain of our other Services, You must register for an account on the Services ("Account"). You must provide accurate and complete information and keep Your Account information updated.
7.2 You are solely responsible for all activity that occurs under Your Account and for keeping Your Account password secure. You may never use another person's user account or registration information for the Services without permission.
7.3 You must notify us immediately of any change in Your eligibility to use the Services (including changes to or revocation of any licenses), breaches of security, or unauthorized use of Your Account. You shall have the ability to delete Your Account either directly or through a request to one of our employees or affiliates.
8.1 You agree to use the Services only for purposes that are permitted by
8.2 You agree that You will not engage in any activity that interferes with or disrupts the Services.
8.3 You will keep all information provided to You through the Service as private and confidential and will not share such information with anyone without the permission of the person who provided it to You.
8.4 You agree to use the Services for personal use only. Users may not use the Services or any Content contained in the Services for any commercial endeavors, nor may they use any information obtained from the Services to contact, advertise to, solicit, or sell to any other user or request money from the user without their prior explicit consent.
8.5 You shall not use the Services to infringe upon the privacy rights, property rights, intellectual property rights, or any other rights of any person.
8.6 You shall not post any Content that contains video, audio, photographs, images, or any personal data of another person without their permission, or any Content that contains restricted or password-protected access pages, or hidden pages or images (those not linked to or from another accessible page).
8.7 You shall not access or attempt to access the Services through automated or robotic means, including but not limited to denial-of-service attacks. This restriction does not apply to legitimate search engine activity that does not place an unreasonable burden on the Services.
8.8 You may not, when using the Services:
8.9 We reserve the right, in our sole discretion, to investigate and take any legal action against anyone who violates this section of the Terms, including terminating or suspending the Account of such violators. Violators agree to compensate us for any expenses and costs incurred in connection with the investigation and prosecution of such activities.
8.10 You are responsible for all activity conducted under Your Account in connection with the Services.
9.1 We may display advertisements within the App, including promotions for third-party brokers, exchanges, proprietary trading firms, or other partners. Some of these advertisements may be linked to affiliate programs, through which we may earn commissions.
9.2 These advertisements may be based on user activity, content engagement, or trading preferences within the App. We do not share Your personal information with third-party advertisers. However, we may use elements of Your personal information, such as geographic location or general trading behavior, to optimize ad targeting without directly exposing identifiable personal data.
9.3 We reserve the right to monitor and manage all advertisements, public postings, and promotional content to ensure compliance with our content guidelines, which may change from time to time at our discretion.
9.4 In consideration for granting You access to and use of the Services, You agree that we may display such advertisements, including but not limited to partner promotions. Clicking on these advertisements may, in some cases, result in Cleo earning a commission from the third-party provider.
9.5 We do not endorse, guarantee, or take responsibility for any third-party services, products, or offers advertised within the App. Any interaction, transaction, or agreement You enter into with these third parties is solely between You and them, and Cleo is not liable for any loss or damage arising from such interactions.
10.1 You acknowledge and agree that we (or our licensees) own all legal rights, title, and interest in and to the Services, including any intellectual property rights (such as copyrights, trademarks, patents, and trade secrets) associated with the Services.
10.2 You agree not to copy, modify, transmit, create derivative works from, distribute, publicly display, sell, sublicense, or otherwise reproduce any copyrighted material, trademarks, trade names, service marks, patents, or other intellectual property accessible through the Services without our prior written consent or, where applicable, the consent of the intellectual property owner.
10.3 You agree not to remove, obscure, or otherwise alter any proprietary notices, copyright disclaimers, trademark symbols, or other intellectual property rights notices appearing on any Content within the App.
10.4 Any Information, software, or materials downloaded or obtained through the use of the App is done at Your own discretion and risk. You are solely responsible for any damage to Your computer system, trading devices, or loss of data resulting from such downloads. If You are in doubt, please consult an appropriate professional before downloading or using any materials.
11.1 The Services may include hyperlinks, embedded content, or references to external websites, platforms, or resources operated by third parties over which we have no control.
11.2 You acknowledge and agree that we do not endorse, verify, or take responsibility for the availability, security, legality, accuracy, or reliability of such external sites, resources, or any content, products, or services available from them.
11.3 You understand that by accessing external links, You may encounter content that is offensive, indecent, misleading, or objectionable, which may or may not be labeled as explicit. You further acknowledge that:
11.4 By using any external links, You assume all risks associated with third-party sites, including the possibility of encountering fraudulent services, scams, or malicious software. Cleo is not liable for any damages, financial losses, or security breaches resulting from Your interactions with external websites.
12.1 The App may allow You to connect and integrate with third-party services, including but not limited to trading platforms, exchanges, brokers, and proprietary trading firms (“Third-Party Services”). These services are provided entirely by third parties and are not verified or controlled by Cleo.
12.2 By connecting the App to Third-Party Services, You acknowledge and agree that:
12.3 Your Responsibilities When Connecting Third-Party Services:
12.4 We reserve the right to restrict, modify, or discontinue the ability to connect with certain Third-Party Services at any time without prior notice, particularly if compliance, security, or business risks arise.
13.1 In addition to the free Services provided in the App, certain Services require payment. If You choose to access these premium features, the following additional terms apply.
13.2 You acknowledge and agree that the initial price may change if You upgrade, downgrade, or modify Your subscription plan. Any price changes will be communicated to You in advance, and You will have the opportunity to accept or decline the modification before proceeding.
13.3 By registering for a paid membership and providing payment details (e.g., credit card, digital wallet, or other accepted payment methods), You authorize us to charge You for the selected Services. It is Your sole obligation to provide accurate and complete payment information and to update Your Account if any changes occur.
13.4 If payment cannot be processed for any reason, we reserve the right to suspend or terminate Your access to paid features, either temporarily or permanently, until payment is successfully processed.
13.5 Payment processing is handled by third-party providers, and we assume no responsibility for their services, errors, security, or processing delays.
13.6 If You cancel Your Account or subscription, all membership payments are non-refundable. This means:
13.7 Each party is responsible for its own tax obligations related to its income and activities associated with the Services. If required, You agree to cover any applicable taxes associated with Your use of paid features.
13.8 Any payouts, profit-sharing, or rewards are provided at Cleo's sole discretion and subject to applicable taxes and regulations. Cleo does not hold user funds and is not responsible for third-party payment failures.
14.1 We grant You a worldwide, royalty-free, non-assignable, and non-exclusive license to access and use the Services for the duration and scope designated by these Terms. This license is solely intended to enable You to use and benefit from the Services in accordance with these Terms.
14.2 Unless we have explicitly authorized You in writing, You may not:
15.1 You retain full copyright and intellectual property rights over any Content that You submit, post, or display within the App. However, if You post Content in areas of Your profile that are publicly accessible ("Public Profile"), You grant us a worldwide, royalty-free, non-exclusive license for the term of the Services to:
15.2 You acknowledge and agree that, to provide and improve the Services, we may:
16.1 We do not guarantee that any Content will be made available within the App or through the Services. We reserve the right, at our sole discretion, to:
16.2 You acknowledge that we are not responsible for lost or deleted Content, and we have no obligation to store, maintain, or provide copies of any Content.
17.1 The Services may allow You to connect, link, or interact with third-party websites, platforms, or services on the Internet. Likewise, third-party services may contain links to Cleo's Services.
17.2 By accessing third-party websites or services, You acknowledge and agree that:
17.3 Disclaimers & Limitations of Liability:
18.1 We respect intellectual property rights and expect our users to do the same. If You believe that any Information, Content, or material within the Services infringes on copyrighted work, please notify us immediately by providing the following:
18.2 Upon receiving a valid copyright infringement claim, we reserve the right to remove or disable access to the allegedly infringing material and take any further actions necessary to comply with applicable laws.
19.1 If You believe that any Information, Content, or other material distributed through the Services constitutes impersonation infringement, particularly if another user is:
19.2 Please notify us immediately with the following:
19.3 We reserve the right to:
20.1 We reserve the right, at our sole discretion, to change, modify, add, or remove portions of these Terms at any time for any reason, including but not limited to:
20.2 We will make the updated Terms available at https://cleo.finance/terms/new and within the App at least one (1) month prior to their effective date.
20.3 If the modifications include material changes that significantly affect user rights, we will provide a notice through the App.
20.4 Acceptance of Changes:
21.1 We may, at our sole discretion, terminate, suspend, or restrict Your access to all or part of the Services at any time, with or without notice, for any reason, including but not limited to:
21.2 No Refunds: Upon termination, You will not be entitled to any refunds for unused fees, subscriptions, or in-app purchases.
21.3 No Disclosure Obligation: We are not required to disclose the reason for the termination or suspension of Your Account. In some cases, we may be legally prohibited from providing such details.
21.4 Service Modifications & Limitations:
21.5 No Liability for Service Interruptions:
21.6 User-Initiated Termination:
21.7 Survival of Certain Terms:
22.1 You understand and agree that You use the App and Services at Your own risk.
22.2 The Services are provided “as is” and “as available”, without any warranties, express or implied, including but not limited to warranties of title, non-infringement, merchantability, or fitness for a particular purpose, except where such warranties cannot be lawfully excluded.
22.3 We do not guarantee the accuracy, completeness, or timeliness of any Information available in the App. Content may contain delays, omissions, or inaccuracies, and Cleo does not endorse, verify, or take responsibility for any user profile, advice, opinion, or statement displayed in the Services. Any reliance on such content is at Your own risk.
22.4 Any AI-generated trading suggestions, signals, or automations within Cleo's Services are for informational purposes only. Cleo makes no guarantees regarding their accuracy, effectiveness, or profitability, and You accept full responsibility for all trading decisions made based on AI-driven tools.
23.1 You acknowledge and agree that Cleo, including its officers, directors, employees, agents, third-party content providers, and licensors, shall not be liable for any direct, indirect, incidental, consequential, special, punitive, or exemplary damages, including but not limited to personal injury, lost profits, lost data, financial loss, or reputational harm, arising from:
23.2 If Your account is terminated or suspended, You are not entitled to any refunds for unused fees, subscriptions, or in-app purchases. If the Services are discontinued, Cleo is not liable for any compensation to users.
23.3 To the fullest extent permitted by law, Cleo's liability shall not exceed the total amount You paid to Cleo for the Services in the three (3) months preceding the incident giving rise to the claim. Under no circumstances shall Cleo's liability exceed USD 10,000.
23.4 Subject to Articles 22.1 - 23.3 and to the maximum extent permitted by applicable law, our liability for damage incurred by You as a result of or in connection with the Services shall be limited to direct damages, as outlined in this Article. Nothing in these Terms shall exclude or limit our liability where it would be unlawful to do so under applicable law.
24.1 To the maximum extent permitted by law, You agree to indemnify, defend, and hold harmless Cleo and its officers, employees, directors, partners, licensors, and affiliates from any claims, liabilities, damages, costs, and legal expenses, including reasonable attorneys' fees, arising from:
24.2 You shall cooperate fully in defending any such claim. Cleo reserves the right to assume exclusive legal defense at its own expense.
25.1 No Investment, Financial, or Legal Advice:
By using the App, You acknowledge and agree that:
25.2 High-Risk Trading Warning:
Trading in financial markets, including forex, stocks, commodities, and digital assets (cryptocurrencies), carries significant risk and is not suitable for all investors. You acknowledge that:
25.3 Trading in Digital Assets & Cryptocurrencies:
25.4 Regulatory Compliance & Legal Risk:
25.5 Final Acknowledgment of Risk:
By using the App or Services, You expressly acknowledge that:
26.1 These Terms and Your relationship with Cleo under these Terms or in connection with the Services shall be governed by and construed in accordance with the laws of Estonia. You agree that, for any dispute arising from or in connection with these Terms, You will:
26.2 If any term of these Terms is held to be illegal, invalid, or unenforceable, the validity and enforceability of the remaining provisions shall remain in full force and effect. The invalid provision shall be replaced by a valid and enforceable term that best reflects the original intent. Failure by either party to exercise any right or remedy under these Terms does not constitute a waiver of that right or remedy.
26.3 If You are a consumer, You may also have the right to request alternative dispute resolution (ADR) from a competent consumer dispute resolution body in Estonia.
26.4 Any and all disputes arising out of or connected to the Services shall be resolved individually. No claim may be consolidated or joined with another party's claims. You waive any right to bring or participate in a class action lawsuit against Cleo.
26.5 Neither You nor Cleo shall be held liable for any failure to perform obligations under these Terms due to causes beyond reasonable control, including but not limited to:
If such an event occurs, the affected party must notify the other party as soon as reasonably possible.
26.6 If You choose to access the App from outside Estonia, You do so on Your own initiative and at Your own risk. You are solely responsible for ensuring compliance with any applicable local laws.
26.7 These Terms are provided in English. The English version of the Terms shall govern Your relationship with Cleo. If a translation is provided in another language, the English version prevails in case of conflict.
26.8 These Terms constitute the entire legal agreement between You and Cleo and supersede all prior agreements relating to the Services. Any previous agreements, representations, or understandings are fully replaced by these Terms.
26.9 If any provision of these Terms is found to be unenforceable or invalid, that provision shall be limited or eliminated to the minimum extent necessary, so that these Terms otherwise remain in full force and effect and fully enforceable.
27.1 Should You have any questions or comments relating to the Terms, please contact us at the following e-mail address: terms@cleo.finance.