Legal

Terms of Service

Effective date: March 15, 2026  ·  Last updated: July 23, 2026

Voldier™ is a billing and payment-verification platform — software classified under NACE Rev. 2 codes 62.01 (Computer programming) and 63.11 (Data processing). We are not a debt collection agency, a payment processor, or a financial institution. We do not transmit, hold, or facilitate the transfer of funds between any parties.

1. Acceptance of Terms

By accessing or using Voldier ("Service", "we", "us", or "our"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, do not use the Service.

Voldier is operated by VOLDIER LIMITED, a private company limited by shares organised under the laws of Ireland, registered with the Companies Registration Office (CRO number IE [pending]), Irish VAT number IE [pending], registered office in Dublin, Ireland ("Company").

2. Description of Service

Voldier provides a billing and payment-verification platform for small and medium-sized businesses — orchestrating billing notices, payment verification and matching, Invoice-On-Payment™ closure, and contract-driven billing under one operating layer. The Service is software classified under NACE Rev. 2 code 62.01 (Computer programming activities) and 63.11 (Data processing, hosting and related activities).

Voldier Limited:

  • Does not custody or hold customer funds at any time.
  • Does not initiate payments on behalf of customers.
  • Does not provide account servicing or banking services.
  • Is not a Payment Institution authorised under Directive (EU) 2015/2366 (PSD2).
  • Is not a credit institution authorised under Directive 2013/36/EU (CRD IV).
  • Is not an Electronic Money Institution under Directive 2009/110/EC.

The Service includes, but is not limited to:

  • Reading bank transaction data through licensed Account Information Service Providers (AISPs) authorised under PSD2 Art. 67, which you have authorised.
  • Automatically matching incoming SEPA credits to open invoices in your account.
  • Generating payment reminder emails and SMS messages to your customers on your behalf.
  • Syncing confirmed payments to supported accounting workflows.
  • Synchronising financial records from accounting systems and ERPs you connect — including obligations, recurring commitments, sales totals and aggregate payroll timing — to produce cash-position and forecasting signals (see Section 16).
  • Generating financial reports, aging summaries, and cash flow forecasts based on your data.

3. Bank Connectivity and Payment Data Processing

To provide payment reconciliation, you may authorise Voldier to access bank transaction data through licensed Account Information Service Providers (AISPs) under PSD2 (Directive (EU) 2015/2366), forward specific bank notification emails to a Voldier-provided address, or upload bank statement files you control. You acknowledge and agree that:

  • Account information services are read-only. Voldier is not a Payment Initiation Service Provider (PISP) and never initiates transfers, moves funds, or modifies your bank account.
  • The underlying AISP performs the regulated account information service under PSD2 Art. 67 and applies Strong Customer Authentication (SCA) per Regulation (EU) 2018/389.
  • We may receive and process structured transaction data, IBAN/BIC, payer names, amounts, value dates, references, and AISP access tokens needed to maintain the connection.
  • We extract and store only the structured payment data needed for reconciliation.
  • We do not share bank-connected or parsed payment data with third parties except our contracted GDPR Art. 28 processors, or as required by law.
  • You are responsible for ensuring you have the right under GDPR and applicable EU and member-state law to authorise the bank connection, email source, or statement files you configure.
  • Data synchronised from accounting systems, ERPs and connected automation platforms is governed by Section 16. Ownership of, and permitted use of, all data you provide is governed by Section 17.

4. Communications to Your Customers

When you use Voldier to send payment reminders via email or SMS to your customers ("End Recipients"), you agree that:

  • You have a pre-existing business relationship with each End Recipient and a valid lawful basis under GDPR Art. 6 to contact them about outstanding invoices.
  • All communications sent through the Service are factual, non-harassing, and accurately represent the amounts owed, consistent with the Unfair Commercial Practices Directive 2005/29/EC (UCPD), transposed in Ireland by the Consumer Protection Act 2007.
  • You will comply with all applicable EU and member-state laws governing commercial communications, including the ePrivacy Directive 2002/58/EC (and its national transpositions), GDPR Art. 21 (right to object to direct marketing), the EU Consumer Rights Directive 2011/83/EU, and per-country debt-recovery rules (in Ireland, the Consumer Credit Act 1995 and the Central Bank of Ireland Consumer Protection Code where applicable).
  • You will honour opt-out and STOP requests without undue delay and maintain suppression lists.
  • Voldier is acting solely as a message delivery service on your behalf. Voldier is not a debt-collection agency, does not own the debt, and does not act as an assignee or recovery agent.

5. Accounts and Security

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. You agree to:

  • Provide accurate and complete information when creating your account
  • Notify us immediately of any unauthorized access or security breach
  • Not share your credentials with unauthorized users

6. Subscription Plans and Billing

Voldier offers subscription-based plans. By subscribing to a paid plan, you agree to pay the applicable fees as described on our pricing page. All fees are quoted in EUR (€) and are exclusive of VAT. Voldier Limited is established in Ireland and is registered for Irish VAT (VAT number IE [pending]). EU B2B customers are subject to the reverse-charge mechanism under Article 196 of Council Directive 2006/112/EC. EU B2C customers are charged Irish VAT at the standard rate of 23% or destination-country VAT under the One-Stop Shop (OSS) scheme, as applicable. Customers outside the EU are billed at zero-rate where supported by local export rules. Subscriptions automatically renew at the end of each billing cycle unless cancelled beforehand. We reserve the right to modify pricing with 30 days' notice.

Consumer customers benefit from the statutory 14-day cooling-off right under the EU Consumer Rights Directive 2011/83/EU (transposed in Ireland by the European Union (Consumer Information, Cancellation and Other Rights) Regulations 2013, SI No. 484/2013) for distance contracts. By starting use of the Service within the cooling-off period, the consumer expressly requests early performance and accepts that the right of withdrawal lapses upon full performance.

You may cancel your subscription at any time. Cancellations take effect at the end of the current billing period. We do not provide refunds for partial months of service, except where required by mandatory consumer-protection law.

7. Prohibited Uses

You may not use the Service to:

  • Carry on third-party debt-recovery activities that require authorisation in your member state (for example, under the Irish Consumer Credit Act 1995, the UK FCA Consumer Credit sourcebook (CONC), or equivalent national regimes) without holding the required authorisation.
  • Send unsolicited commercial communications in breach of the ePrivacy Directive 2002/58/EC or harass any person, contrary to the UCPD 2005/29/EC.
  • Process personal data in breach of GDPR or applicable national data protection law.
  • Violate any EU regulation, member-state law, or applicable international sanctions (including EU restrictive measures under Council Regulations).
  • Reverse engineer, copy, or resell the Service, save to the extent permitted by Directive 2009/24/EC on the legal protection of computer programs.
  • Transmit malicious code or interfere with the Service's operation, contrary to Directive (EU) 2022/2555 (NIS2).

8. Disclaimer of Warranties

THE SERVICE IS PROVIDED "AS IS" WITHOUT WARRANTY OF ANY KIND. WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. WE DO NOT WARRANT THAT THE SERVICE WILL BE UNINTERRUPTED, ERROR-FREE, OR THAT EMAIL PARSING WILL ACHIEVE 100% ACCURACY.

AI Features Disclaimer: Voldier and its artificial intelligence features provide operational insights, data summaries, and automated proposals. These insights do not constitute certified financial, tax, or legal advice. The Merchant holds sole responsibility for reviewing and approving any AI-suggested proposals before execution. We do not guarantee the accuracy, completeness, or reliability of any AI-generated output.

9. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, VOLDIER LIMITED SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR ANY LOSS OF REVENUE OR PROFIT, ARISING OUT OF OR RELATED TO YOUR USE OF THE SERVICE. OUR TOTAL AGGREGATE LIABILITY SHALL NOT EXCEED THE AMOUNTS PAID BY YOU TO VOLDIER IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

Nothing in these Terms limits liability that cannot lawfully be excluded under the Irish Sale of Goods and Supply of Services Act 1980, the Consumer Rights Act 2022 (Ireland), Directive (EU) 2019/770 on digital content and digital services, Directive (EU) 2019/771 on the sale of goods, or any other mandatory consumer-protection provision. Liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, and for any liability that cannot lawfully be excluded, is not limited.

10. Indemnification

You agree to indemnify and hold harmless VOLDIER LIMITED from any claims, damages, or expenses (including reasonable legal costs) arising out of your use of the Service, your violation of these Terms, or your violation of any rights of a third party, including any breach of GDPR or applicable EU or member-state law for which you are responsible as Data Controller of End Recipient personal data.

11. Governing Law and Dispute Resolution

These Terms are governed by the laws of Ireland, without regard to conflict-of-law principles. Disputes arising out of or in connection with these Terms shall be subject to the exclusive jurisdiction of the courts of Ireland, in particular the Commercial Court (Dublin) for B2B disputes meeting the relevant threshold. By mutual written agreement, the parties may instead refer a dispute to arbitration under the Rules of Arbitration of the International Chamber of Commerce (ICC), with seat and venue in Dublin and proceedings in English.

For consumers (within the meaning of Directive 2011/83/EU), mandatory non-waivable consumer-protection provisions of the EU/EEA member state in which the consumer is habitually resident continue to apply in addition to these Terms (Article 6 of Regulation (EC) No 593/2008 — "Rome I"). Where local mandatory law conflicts with these Terms, the more consumer-favourable provision prevails.

EU consumers may also use the European Commission's Online Dispute Resolution (ODR) platform: ec.europa.eu/consumers/odr.

12. Changes to Terms

We may update these Terms from time to time. We will notify you via email or in-app notification at least 14 days before material changes take effect. Continued use of the Service after the effective date constitutes acceptance of the updated Terms.

13. Subscriptions, Plan Changes & Billing

13.1 Billing Cycle. Subscriptions to Voldier plans are billed monthly or annually depending on the selected plan. The cycle begins on the subscription activation date.

13.2 Upgrade (switching to a higher plan). When the user requests a change to a higher-priced plan, the change is scheduled to take effect at the start of the next billing cycle. The user retains all features of the current plan until the end of the current cycle. The new plan price will be charged at the beginning of the new cycle.

13.3 Downgrade (switching to a lower plan). When the user requests a change to a lower-priced plan, the change takes effect immediately. Features exclusive to the higher plan become unavailable at the time of the change. No credits, refunds, or compensation are issued for the remaining days of the current billing cycle.

13.4 Proration. No proration applies in any plan change scenario. No partial charges are made and no credits are issued for incomplete periods.

13.5 Cancellation of Scheduled Changes. A scheduled upgrade may be cancelled at any time before the new billing cycle begins, at no cost.

13.6 Subscription Cancellation. Upon cancelling a subscription, the user retains access to the subscribed plan until the end of the current billing cycle. No refunds are issued for the remaining period.

14. Payment Processing Addendum

14.1 Custody of Funds and Regulatory Scope

Voldier is software. It is not a credit institution under Directive 2013/36/EU (CRD IV), not a Payment Institution under Directive (EU) 2015/2366 (PSD2), not an Electronic Money Institution under Directive 2009/110/EC, and not a payment processor. When you, your customers, or any third party initiates a payment through a processor connected to Voldier, the funds are held, transmitted, and disbursed exclusively by the licensed payment service provider. Voldier never receives, holds, commingles, or controls customer funds.

The list of integrated payment service providers (PSPs) may change over time. Voldier integrates only with PSPs authorised in the European Economic Area, the United Kingdom, or other jurisdictions recognised under EU passporting or equivalence arrangements. PSPs ring-fence client funds in safeguarded accounts pursuant to PSD2 Art. 10 (or, where applicable, hold electronic money under EMD2 Art. 7). Such safeguarding is provided by the PSP and is not a guarantee by Voldier.

Voldier is not an agent of any PSP or safeguarding credit institution. Your financial relationship with each PSP is direct and is governed by that PSP's terms of service, which you must accept separately to enable payment-processing features. The disclaimers in this Addendum apply to the PSP actually used for the transaction in question.

14.2 Chargebacks, SEPA Direct Debit Returns, and Disputes

Chargebacks, card-scheme disputes, SEPA Direct Debit returns and "no-questions-asked" refunds (within 8 weeks under the SEPA SDD Rulebook), SEPA Credit Transfer recalls, TARGET2 reversals, and similar financial events are governed by the rules of the card schemes (Visa, Mastercard, and other accepted brands), the European Payments Council SEPA Rulebooks, the European Central Bank TARGET2 rules, the relevant banking network, and the PSP's terms of service.

Such disputes are resolved directly between the merchant and the PSP. Voldier does not adjudicate, arbitrate, or guarantee the outcome of financial disputes and is not a party to such disputes. On request, Voldier may provide technical evidence (reconciliation logs, message delivery receipts, invoice metadata, audit trails) at no charge to support the merchant's case.

Refunds are initiated by the merchant from the PSP balance. If the PSP withholds funds, freezes an account, imposes a reserve, or applies anti-fraud measures pursuant to its AML5/AML6 obligations (Directive (EU) 2018/843 and the AML Regulation (EU) 2024/1624), Voldier has no ability to reverse those decisions.

14.3 Card Surcharging and Convenience Fees

Under Article 62(4) of PSD2 (Directive (EU) 2015/2366), as transposed in Ireland by the European Union (Payment Services) Regulations 2018 (SI No. 6/2018), surcharging is prohibited for consumer card payments using payment instruments subject to the Interchange Fee Regulation (Regulation (EU) 2015/751), namely consumer debit and consumer credit cards. Surcharging may remain permissible for commercial cards and three-party schemes outside the IFR scope, subject to national-law exceptions and PSP terms.

Voldier does not enable surcharging by default. The feature is opt-in and configured by the merchant. By enabling surcharging or convenience fees, you represent and warrant that you have verified PSD2, IFR and national-law compliance and you indemnify Voldier from any resulting liability.

14.4 Acceptable Use Policy — Prohibited Industries

You may not use Voldier or the connected PSPs to invoice, collect, or accept funds for the following industries or activities (which mirror the restricted-business lists of our upstream PSPs and reflect EU regulatory requirements):

  • Controlled substances, including cannabis products outside the medicinal frameworks authorised at member-state level.
  • Firearms, ammunition, explosives, and weapons accessories sold outside the channels licensed under Directive (EU) 2021/555 on the control of acquisition and possession of weapons.
  • Adult content, pornography, escort and companionship services.
  • Unlicensed gambling or betting services contrary to applicable national gambling regulators (for example, the Gambling Regulatory Authority of Ireland under the Gambling Regulation Act 2024).
  • Multi-level marketing schemes and pyramid schemes prohibited under Annex I of the Unfair Commercial Practices Directive 2005/29/EC.
  • Unregulated crypto-asset exchanges, unauthorised crypto-asset issuers contrary to Regulation (EU) 2023/1114 (MiCA), and offerings of unregistered transferable securities under the Prospectus Regulation (EU) 2017/1129.
  • Third-party debt-recovery services requiring authorisation in the relevant member state, where the user does not hold such authorisation.
  • Unauthorised consumer lending, unauthorised payment services, or unauthorised electronic money issuance.
  • Tobacco, vape, and e-cigarette products sold to minors contrary to the Tobacco Products Directive 2014/40/EU.
  • Goods or services prohibited under EU restrictive measures (sanctions) administered under Council Regulations, or under the EU dual-use export-control regime (Regulation (EU) 2021/821).
  • Any activity unlawful in the merchant's or end-customer's jurisdiction.

Use for any prohibited activity results in immediate suspension, account termination without refund, and a report to the upstream PSP, which may independently freeze funds in accordance with its own terms of service and AML obligations.

14.5 Third-Party Referrals and Affiliate Disclosure

Clarification — payment trust mechanism. The payment trust mechanism is a Voldier-operated B2B payment-reputation product (not a third party). It surfaces the merchant's payment-track record built from the Service's reconciliation data. It is not a consumer credit-reference agency under the Consumer Credit Directive 2008/48/EC or the Irish Consumer Credit Act 1995, does not issue consumer credit decisions, and does not provide credit-scoring services to lenders for consumer-credit transactions. Use by counterparties is supplementary and does not replace any verification required by law (including AML customer due diligence).

When Voldier surfaces offers from independent third parties (accounts-receivable financing partners, working-capital providers, payment service providers, accounting platforms, or other independent businesses):

  • The offer originates from the independent third party. Voldier acts solely as a marketing referrer / affiliate. We are not the lender, originator, issuer, broker, or fiduciary.
  • Voldier may receive compensation from the third party on a per-click, per-application, per-funded-facility, or revenue-share basis. Commercial communications comply with the Unfair Commercial Practices Directive 2005/29/EC (UCPD), the Irish Consumer Protection Act 2007, and the EASA self-regulatory codes on online behavioural advertising and influencer marketing.
  • Approval, underwriting, rates, fees, and terms of any third-party product are determined exclusively by the third party. Voldier does not guarantee approval or any specific term, rate, or limit.
  • Submission of an application to a referred partner causes your application data to be transmitted to that partner; from that point on, the partner's privacy policy governs that data. See our Privacy Policy.
  • You may opt out of referral surfaces in account settings or by contacting privacy@voldier.com.

14.6 Fee Schedule and Pricing Disclosure

Subscription fees for Voldier are described on the pricing page and are quoted exclusive of VAT (see §6). Payment-processing fees — for example, card-scheme processing fees, SEPA Direct Debit at-cost charges, SEPA Instant transaction fees, and account-verification charges — are determined by the upstream PSP and may be passed through to the merchant with or without markup, as disclosed in the merchant dashboard before activation of any paid feature. Continued use of a paid feature constitutes acceptance of the disclosed fees.

Voldier may modify subscription or processing-fee markups upon at least thirty (30) days' prior notice via in-app message and email. The merchant may cancel the subscription before the effective date of the change without penalty.

What Voldier will never promise. Voldier does not hold itself out as a credit institution, payment institution, or electronic money institution, does not guarantee any depositor protection scheme to the merchant or its customers, does not promise "instant and free" settlement or withdrawal, and does not guarantee rates or approval for third-party financial products. Any marketing copy suggesting otherwise should be reported to legal@voldier.com.

15. End-Customer Payment Behavior Score (Bureau Crediticio)

VOLDIER LIMITED computes an internal "payment behavior score" for each of the Merchant's end-customers ("End Customers") derived from invoice and payment records the Merchant uploads, synchronises, or generates on the Service. This section governs the data-protection obligations of both parties for End Customer data.

15.1 Customer Data Processing Authorization

The Merchant represents and warrants that: (a) the Merchant has obtained all necessary consents and provided all necessary notices to its End Customers to enable the processing of End Customer personal data described in this Agreement, including specifically the computation of a payment-behavior score from invoice and payment records; (b) the Merchant has a lawful basis under applicable data-protection law (including, where applicable, GDPR Art 6) for sharing End Customer data with VOLDIER LIMITED; and (c) the Merchant's own privacy notice to End Customers discloses that payment-related personal data may be processed by third-party service providers, including VOLDIER LIMITED, for the purposes of internal payment-behavior scoring and billing-notice delivery.

15.2 Joint Controller Status (GDPR Art 26)

Where the processing of End Customer personal data falls within the scope of the EU General Data Protection Regulation (Regulation (EU) 2016/679, "GDPR") or the UK Data Protection Act 2018, the Merchant and VOLDIER LIMITED are joint controllers within the meaning of Article 26 GDPR for the limited purpose of computing and maintaining the payment-behavior score. The Merchant retains sole responsibility for: (i) collecting and maintaining a lawful basis for the initial customer relationship; (ii) responding to End Customer rights requests at first instance; and (iii) notifying End Customers of any material change in processing purpose. VOLDIER LIMITED retains sole responsibility for: (i) the technical operation of the scoring algorithm; (ii) maintaining the consent ledger and audit trail; and (iii) implementing technical and organisational measures appropriate to the risk.

15.3 Data Subject Rights Requests

If the Merchant receives a request from an End Customer relating to the payment-behavior score (including, without limitation, access (Art 15), rectification (Art 16), erasure (Art 17), withdrawal of consent (Art 7(3)), or human review of automated decisions (Art 22(3))), the Merchant shall either: (a) forward the request to privacy@voldier.com within five (5) business days; or (b) handle the request directly under the Merchant's own legal process, notifying VOLDIER LIMITED of the resolution within thirty (30) days. VOLDIER LIMITED commits to respond to any forwarded request within the timeframes mandated by applicable law (typically thirty (30) days under GDPR).

15.4 Profile Creation from Merchant Records (Art 14)

Where VOLDIER LIMITED creates an End Customer profile based on data imported from the Merchant's accounting, billing, or CRM systems (via ERP synchronisation, API upload, manual entry, or any other means), the Merchant acknowledges that VOLDIER LIMITED will not independently notify the End Customer of this processing under GDPR Art 14. The Merchant is responsible for ensuring its own privacy notice to End Customers covers this transfer, including: (i) the identity of VOLDIER LIMITED as a joint controller; (ii) the purposes and legal basis of the processing; (iii) the categories of personal data shared; (iv) the End Customer's rights and how to exercise them; and (v) the retention period applicable to the payment-behavior score (seven (7) years post-last-activity, per VOLDIER LIMITED's Data Retention Policy).

15.5 Score Use Limitations

The payment-behavior score is computed solely from data within the Merchant's own account ("closed-loop scoring"). VOLDIER LIMITED does NOT today aggregate End Customer data across merchants, share the score with credit-reference agencies, or sell the data to third parties. Any future cross-merchant query feature will require a separate explicit consent (purpose: cross_creditor_data_sharing) from each affected End Customer and a separate authorisation from the Merchant before activation.

See also §14.5 (Third-Party Referrals and Affiliate Disclosure) for a non-technical overview of the payment trust mechanism.

15.6 Plain-Language Customer Notice (Recommended)

VOLDIER LIMITED provides a plain-language summary of the payment-behavior score at voldier.com/legal/privacy. The Merchant is encouraged (but not required) to link to or reproduce this summary in its own End Customer communications to support clarity under GDPR Art 12(1) ("clear and plain language").

16. Connected Systems and Financial Data Synchronisation

In addition to the account information services described in Section 3, you may authorise Voldier to synchronise financial records from accounting systems, enterprise resource planning ("ERP") systems, and connected automation platforms. This Section governs that synchronisation.

16.1 Connection Methods

Synchronisation may occur through: (a) direct cloud APIs of supported accounting platforms, authorised by you via OAuth or equivalent; (b) Agent-On-Sync™, an on-premise connector installed within infrastructure you control, used to reach desktop and legacy ERP systems; and (c) automation platforms and webhooks you configure (including, without limitation, Zapier, n8n and Make). Each connection is established only with your authorisation and may be revoked by you at any time from your account settings, after which synchronisation stops.

16.2 Categories of Synchronised Data

Depending on the connections you enable and the scopes you grant, Voldier may read, and where you enable write-back may write, the following categories:

  • Chart of accounts, ledger account identifiers and account balances
  • Customer and supplier records, invoices, bills and credit documents
  • Outstanding obligations and recurring commitments, including trade payables and scheduled expenses
  • Sales totals by period
  • VAT and other tax-liability balances
  • Payroll data, strictly limited as set out in Section 16.3
  • Journal entries and payment records that Voldier creates on your instruction

16.3 Payroll Data Limitation

Where you connect a system containing payroll information, Voldier extracts only aggregate payroll totals and scheduled pay dates, for the sole purpose of projecting cash requirements. Voldier does not request, and does not persist, employee-level remuneration, employee names or identifiers, national insurance or social security numbers, benefit elections, trade-union membership, or any other individual employee record. Where a connected system exposes such fields as part of a broader response, they are discarded at ingestion and are not written to storage. This limitation is a design constraint of the Service, not solely a policy commitment, and is intended to keep employee personal data — including any special category data within the meaning of GDPR Art. 9 — outside the scope of the processing.

16.4 Purpose Limitation

Data synchronised under this Section is used to compute your cash position, produce forecasts and observer signals, generate agent proposals, and operate the billing and reconciliation features you enable, in accordance with the purpose limitation principle of GDPR Art. 5(1)(b). Consistent with the AI Features Disclaimer in Section 8, proposals generated from this data are advisory and require your review and approval before execution. Voldier does not take any action producing legal effects or similarly significant effects without your approval, within the meaning of GDPR Art. 22.

16.5 Your Authorisations and Responsibilities

You represent and warrant that you have the authority to authorise each connection you configure and to permit the extraction and, where enabled, the writing of the data categories above; that you hold a lawful basis under GDPR Art. 6 and have provided any notices and obtained any consents required under applicable EU and member-state law with respect to that data, including any personnel data covered by Section 16.3 and any applicable works-council or employee-representative consultation; and that you will maintain the security of any host on which Agent-On-Sync™ is installed, including operating-system patching, network controls and physical access.

16.6 Write-Back and Accounting Responsibility

Where you enable write-back, Voldier creates records in your accounting system — including invoices, payment applications and journal entries — according to the account mappings you configure. You remain solely responsible for the accounting treatment of those records, for the account mappings you select, and for review by your accountant, bookkeeper or tax adviser. Voldier does not provide accounting, audit or tax advice, does not determine the correct revenue-recognition or VAT treatment for your business, and is not responsible for the consequences of an incorrect mapping you configure or approve. You may disable write-back at any time.

16.7 Synchronisation Frequency and Data Freshness

Synchronisation is periodic and depends on the availability of the connected system, its API rate limits, and, for on-premise connections, the availability of the host and its network. Figures presented in the Service therefore reflect the state as of the last successful synchronisation and may not reflect real-time balances or obligations. Voldier surfaces the time of last synchronisation alongside derived figures. You should not rely solely on a derived figure for an irreversible financial decision without confirming against the source system or your bank.

17. Data Ownership, Anonymised Data, and AI Processing

"Customer Data" means all data you submit to the Service or that the Service collects from systems you connect, including account information data under Section 3, End Customer records under Section 15, and synchronised financial records under Section 16.

17.1 Ownership

As between you and VOLDIER LIMITED, you retain all right, title and interest in and to Customer Data. VOLDIER LIMITED acquires no ownership interest in Customer Data by virtue of these Terms. This allocation of rights is without prejudice to the controller and processor roles determined under GDPR, which are set out in Section 15 and in the applicable data processing agreement.

17.2 Licence to Operate the Service

You grant VOLDIER LIMITED a worldwide, non-exclusive, royalty-free licence to host, store, process, transmit, display and create derivative works of Customer Data solely as necessary to provide, maintain, secure and support the Service for you, and to comply with law. This licence terminates when your account is deleted, subject to the retention periods stated in the Data Retention Policy and to any retention required by law.

17.3 Anonymised and Aggregated Data

VOLDIER LIMITED may create "Anonymised Data": data derived from Customer Data that has been irreversibly stripped of any identifier of you, your End Customers, your personnel and any other individual, such that the data subject is no longer identifiable by any means reasonably likely to be used, and therefore constitutes anonymous information within the meaning of GDPR Recital 26. VOLDIER LIMITED may use Anonymised Data to operate, secure, improve and develop the Service and new products and features, and to produce benchmarks and industry statistics. VOLDIER LIMITED will not disclose Anonymised Data in any form that identifies you, any End Customer or any individual, and will apply minimum-cohort thresholds so that published statistics cannot be attributed to a single participant. This subsection survives termination.

This subsection does not authorise cross-merchant End Customer scoring. The restrictions in Section 15.5 continue to apply in full, and any cross-merchant query feature remains subject to the separate consent and authorisation required by that Section.

17.4 No Model Training on Customer Data

VOLDIER LIMITED does not use Customer Data to train, fine-tune, or otherwise modify the parameters of any artificial-intelligence model. The models that power the Service are operated for inference only. VOLDIER LIMITED does not train models on behalf of third parties using Customer Data, and does not licence Customer Data, or any model derived from it, to third parties for their independent use. Should VOLDIER LIMITED ever intend to change this practice, it will give at least thirty (30) days' prior notice by email and in-app message, and the change will apply only to merchants who affirmatively opt in.

17.5 Where and How AI Processing Occurs

The artificial-intelligence features of the Service run on infrastructure operated by or for VOLDIER LIMITED. Customer Data is not transmitted to third-party model providers, for inference or for any other purpose. The context supplied to a model in order to produce a result is limited to the minimum information required for that specific result; the Service does not transmit bulk Customer Data to a model, and derived figures are computed by deterministic means wherever the calculation permits it. If VOLDIER LIMITED ever intends to route Customer Data to a third-party model provider, it will give at least thirty (30) days' prior notice by email and in-app message, will identify the provider on its subprocessors page as a GDPR Art. 28 processor, and you may cancel your subscription before the change takes effect without penalty.

17.6 No Sale or Onward Transfer

VOLDIER LIMITED does not sell Customer Data or End Customer personal data, and does not make it available to any third party for that third party's own purposes, including advertising or profiling. Third-party referrals described in Section 14.5 are initiated by you, are opt-out, and are governed by that Section. Disclosures to contracted GDPR Art. 28 processors are governed by the Privacy Policy and the subprocessors page.

18. Contact

For questions about these Terms, contact legal@voldier.com. For data protection matters, contact our Data Protection Officer at dpo@voldier.com.

VOLDIER LIMITED  ·  Dublin, Ireland  ·  CRO IE [pending]  ·  VAT IE [pending]