These terms and conditions ("Agreement" or "Terms") govern the use of the financial management SaaS service ("Service") provided by NoCFO Oy ("NoCFO", Business ID 3149769-7). By using the Service, the Customer agrees to comply with these Terms and to act in accordance with applicable law and good practice. The Terms are accepted by logging into the Service.
This Agreement applies to the provision of the Service to the Customer. The Agreement enters into force when the Customer starts using the Service. The Agreement applies to all features and use of the Service unless otherwise agreed in writing between the parties.
Customer: A person or organization using the Service.
Service: The accounting and financial management SaaS service developed and maintained by NoCFO.
Company Account: The Customer account created when onboarding the Service.
User: A person authorized by the Customer to use the Service.
Parties: NoCFO and the Customer.
DPA: The Data Processing Agreement in Appendix 1 to this Agreement.
3.1 NoCFO is responsible for providing the Service in accordance with these Terms and may use subcontractors for this purpose.
3.2 NoCFO is entitled to further develop the Service and to change the content and features of the Service, in particular for technical development, improvement of information security, remedying of faults, adaptation to changed legal requirements, and adjustment of the range of services offered. NoCFO will notify the Customer in the Service of changes that materially and permanently impair the use of the Service. Interruptions or changes to the Service may occur due to development or maintenance work; NoCFO will endeavour to give advance notice of significant service interruptions where possible.
3.3 The right under Section 3.2 does not apply to the function for exporting and downloading the Customer's data.
3.4 NoCFO may suspend the Customer's access to the Service in whole or in part if the Customer is in default, wholly or partly, of a payment due, or if the Customer jeopardizes the operation, security, technical reliability, lawful use, or development of the Service, or materially breaches its contractual obligations. NoCFO will announce the suspension in advance in the Service. The function for exporting and downloading the Customer's data is exempt from suspension.
3.5 NoCFO's experts may provide guidance regarding the use of the Service and financial administration matters. The Customer is responsible for any actions taken on the basis of such guidance within or outside the Service.
3.6 NoCFO is entitled to process data stored in the Service, such as receipts, accounting vouchers, invoices, bank statement data, bank transactions, customer register information, and other financial data, for the purposes of analyzing, developing, automating, and improving the quality of the Service. Such processing is based on this Agreement and on Appendix 1 (DPA), which governs all processing of personal data carried out on behalf of the Customer.
3.7 NoCFO may discontinue the Service by notifying the Customer at least three (3) months before discontinuation.
4.1 The Customer has the right to use the Service in accordance with these Terms. The Customer must review the Terms before using the Service and ensure that use of the Service complies with applicable law and good practice.
4.2 The Customer is responsible for:
4.3 With regard to personal data stored in the Service, the Customer acts as the controller and NoCFO acts as the processor. Such processing is governed by Appendix 1 (DPA).
4.4 The Customer is responsible for ensuring that materials stored in the Service do not infringe third-party rights or violate applicable legislation.
4.5 The Customer is responsible for notifying NoCFO of any errors detected in the Service.
4.6 The Customer may use third-party services integrated into or offered through the Service, such as payment services, e-invoicing services, or other external interfaces. By using such services, the Customer accepts the applicable terms and conditions of the relevant third parties and is responsible for complying with them. NoCFO is not responsible for the content, operation, or availability of third-party services.
5.1 Current prices and payment methods are available on NoCFO's website.
5.2 NoCFO may change the pricing of service packages by notifying Customers in advance. Prices for transaction-based products and services, such as e-invoices and payroll services, may change regardless of the Customer's selected service package or billing period. Current pricing is always available on NoCFO's website.
5.3 If the Customer has saved a payment method to the Service through a third-party payment service provider, NoCFO has the right to charge transaction-based fees, such as fees arising from the use of e-invoices and other current and future transaction-based fees, directly to that payment method without a separate invoice. Saving a payment method is deemed to constitute the Customer's authorization for such charges.
5.4 Fees are charged either in advance or in arrears according to the selected service level.
5.5 The minimum monthly invoice amount is EUR 10. Smaller invoices may be charged quarterly. This minimum applies only to fees charged by invoice, not to transaction-based fees charged directly from a saved payment method.
5.6 Applicable VAT will be added to service prices. Late payment interest is determined in accordance with the Finnish Interest Act. When paying by invoice, the payment term is fourteen (14) days from the invoice date.
5.7 NoCFO does not provide refunds for partial billing periods, unused service time, or retroactive cancellations unless required by mandatory law.
5.8 Third-party payment service providers may be used for payment processing and for saving payment methods, whose terms and privacy practices apply to the saving and use of the payment method.
6.1 All intellectual property rights relating to the Service and all related materials, software, user interfaces, databases, models, documentation, and other content belong exclusively to NoCFO or its licensors. The Customer is granted only a limited right to use the Service in accordance with these Terms.
6.2 The Customer may not copy, modify, reproduce, sell, rent, sublicense, transfer, publish, translate, reverse engineer, decompile, or otherwise attempt to derive the source code of the Service unless permitted by mandatory law.
7.1 "Confidential Information" means all information designated as confidential or that should reasonably be understood to be confidential by its nature.
7.2 Both Parties shall keep confidential all Confidential Information received in connection with the Agreement and shall not disclose such information to third parties or use it for purposes other than those permitted under the Agreement without the other Party's prior written consent.
7.3 The Parties shall ensure that their employees and representatives comply with these confidentiality obligations.
7.4 Unless otherwise agreed, all Confidential Information and related documents remain the property of the original owner.
7.5 Information is not considered Confidential Information if it was already known to the receiving Party before the Agreement, is publicly available, or has been lawfully obtained from a third party without confidentiality obligations.
7.6 This confidentiality obligation does not restrict NoCFO's right to process data stored in the Service by the Customer to the extent permitted under this Agreement and Appendix 1 (DPA) for purposes of providing, maintaining, analyzing, developing, and automating the Service.
8.1 In the event of slightly negligent breach of a material contractual obligation, NoCFO is liable for foreseeable damage typical of this type of contract, limited to the fees paid by the Customer during the three (3) months preceding the damaging event, excluding VAT. Material contractual obligations are those obligations whose fulfilment makes the proper performance of the Agreement possible in the first place and on whose observance the Customer may rely.
8.2 In all other respects, NoCFO's liability for slight negligence is excluded.
8.3 For loss of data, NoCFO is liable only up to the amount of the effort that would have been required for recovery had the Customer maintained proper and regular backups of the data. The Customer is responsible for regularly backing up its data.
8.4 NoCFO is not liable for damages caused by third-party services or by the Customer's own actions.
8.5 The above limitations of liability also apply to the personal liability of NoCFO's legal representatives, employees, and agents.
8.6 Liability for intent and gross negligence, for damage arising from injury to life, body, or health, under the German Product Liability Act (Produkthaftungsgesetz), and arising from the assumption of a guarantee or a procurement risk remains unaffected.
9.1 The Agreement is concluded for an indefinite term and remains in force until terminated by one of the Parties.
9.2 Either Party may terminate the Agreement in writing with one (1) month's notice. The Customer may also specify a later date of termination. Fees are charged until termination takes effect.
9.3 The end of a paid subscription does not terminate the Agreement as long as the Customer continues using the Service under a free version.
9.4 Until termination takes effect, the Customer may download the data stored in the Service at any time using the Service's export function.
9.5 Deletion of the Company Account is a separate action by the Customer and does not constitute termination of the Agreement. Before deletion, NoCFO informs the Customer in the Service of its consequences and of the export function; deletion is carried out only after the Customer's express confirmation. Upon deletion of the Company Account, the Customer's data stored in the Service is removed. Otherwise, NoCFO deletes the Customer's data after termination of the Agreement.
9.6 The statutory retention obligations under §§ 238, 257 of the German Commercial Code (HGB) and §§ 145 to 147 of the German Fiscal Code (AO) apply to the Customer. The Customer is obliged to export the documents subject to retention before termination of the Agreement and to retain them in a manner compliant with the GoBD. NoCFO owes no retention of these documents after termination of the Agreement.
10.1 This Agreement shall be governed by the laws of Finland.
10.2 Any disputes arising from this Agreement shall be resolved in the competent courts of Finland.
11.1 Force majeure means any circumstance or event beyond a Party's reasonable control that prevents or materially hinders the fulfilment of obligations under this Agreement and could not reasonably have been foreseen or avoided.
11.2 Examples include war, natural disasters, fire, pandemics, large-scale network, telecommunications or power outages, governmental actions, or similar exceptional events.
11.3 If NoCFO is prevented from fulfilling its obligations due to force majeure, NoCFO shall be released from liability for the duration and extent of the force majeure event.
11.4 NoCFO shall notify the Customer of the force majeure event and its estimated duration as soon as reasonably possible.
11.5 If the force majeure event continues for more than three (3) months, the Customer may terminate the Agreement with immediate effect by written notice.
12.1 Both Parties shall comply with applicable data protection legislation.
12.2 NoCFO acts as the controller with respect to its own customer and user data in accordance with its Privacy Policy available on NoCFO's website.
12.3 The Customer acts as the controller with respect to personal data stored in the Service, and NoCFO acts as the processor. Such processing is governed by Appendix 1 (DPA).
12.4 NoCFO has the right to process personal data stored in the Service by the Customer in accordance with this Agreement and Appendix 1 (DPA) for purposes of providing, maintaining, analyzing, developing, and automating the Service.
13.1 NoCFO may amend these Terms. The amended Terms will be displayed to the Customer in the Service and take effect from the point at which the Customer expressly accepts them in the Service.
13.2 If the Customer does not accept the amended Terms, either Party may terminate the Agreement in accordance with Section 9.
13.3 Changes to fees are governed exclusively by Section 5.
Claims of the Customer against NoCFO become time-barred twelve (12) months from the statutory commencement of the limitation period. This does not apply to claims based on intent or gross negligence, claims arising from injury to life, body, or health, claims under the German Product Liability Act, or claims arising from the assumption of a guarantee or a procurement risk; for these, the statutory limitation periods apply.
15.1 The Customer may not assign the Agreement without NoCFO's prior written consent.
15.2 NoCFO may assign the Agreement to a third party.
16.1 The Service includes an AI-powered assistant ("Luca"), through which Users may retrieve information about data stored in the Service concerning their company, discuss such data, and initiate actions within the Service. Luca is available as both a text-based and a voice-based feature.
16.2 Luca is an AI system. Its outputs are generated automatically and may be erroneous, incomplete, or inaccurate.
16.3 The User is responsible for how they use information generated by Luca. The User must verify the correctness of actions proposed or performed by Luca before making further use of them.
16.4 Liability is governed by Section 8.
16.5 No tax or legal advice. Luca is a technical function of the Service and does not provide tax advice, legal advice, or audit services. Outputs generated by Luca are automatically produced general information and do not constitute advice relating to an individual case. They are not a recommendation and not a basis for the Customer's tax or legal decisions.
16.6 NoCFO is not authorized to provide assistance in tax matters within the meaning of § 1 of the German Tax Advisory Act (StBerG) and does not provide any such service. The Customer acknowledges that the assessment of tax and legal matters is reserved to persons authorized for that purpose, in particular tax advisors (Steuerberater), lawyers, and auditors. The Customer is obliged to have tax-relevant or legally relevant matters reviewed by an authorized person before making a decision.
16.7 The Customer remains solely responsible for the accuracy and completeness of its accounting, its tax returns, and its other statutory filings. This applies regardless of whether the underlying information was produced, proposed, or processed by Luca.
This appendix forms part of the Terms of Service of the NoCFO Service and supplements the Agreement regarding the processing of personal data between the Customer (controller) and NoCFO Oy (processor). The processing is based on the Agreement between the Customer and NoCFO.
NoCFO processes personal data on behalf of the Customer for the purpose of providing, maintaining, developing, analyzing, and automating the Service. Processing includes the technical processing of financial administration documents and data stored in the Service.
Personal data processed on behalf of the Customer may include, for example:
The Customer is responsible for ensuring that the data has been collected lawfully and that the Customer has the right to transfer it to NoCFO for processing.
NoCFO undertakes to process personal data:
NoCFO ensures that personal data is processed only by persons who are bound by a statutory or contractual confidentiality obligation.
NoCFO does not permit authorities to access the data without a lawful order, such as a court order.
NoCFO shall notify the Customer of personal data breaches without undue delay so that the Customer can fulfil its statutory notification obligations.
Upon request, NoCFO shall provide the Customer with reasonable information or evidence regarding the security of the Service so that the Customer can assess NoCFO's compliance with its obligations under this appendix.
NoCFO has the right to process Customer materials, including vouchers, receipts, bank statements, bank transactions, and other financial data, for the purpose of analyzing and developing the Service, implementing automation, and improving quality.
Development-related processing may include, for example:
The Customer's personal data is not used to train AI models. NoCFO may use anonymized or aggregated data that does not relate to an identifiable person to improve the Service.
Processing does not include using personal data for marketing purposes or disclosing data to third parties for any purpose other than what is necessary for providing the Service.
NoCFO may use subprocessors for the processing of personal data in accordance with this appendix. NoCFO maintains an up-to-date list of its subprocessors, which is available to the Customer upon request.
Subprocessors operate under NoCFO's supervision and only in accordance with this appendix. Personal data may be transferred outside the EU/EEA only where necessary for providing the Service and where the transfers comply with applicable data protection legislation.
The Customer is responsible for ensuring that:
The Customer acknowledges that NoCFO acts as a processor of personal data in accordance with the Agreement and this appendix.
NoCFO implements appropriate technical and organizational measures to protect personal data. Information security is assessed and updated regularly.
NoCFO deletes the personal data processed on behalf of the Customer after termination of the Agreement, or returns it at the Customer's choice. The Customer may retrieve the data itself using the Service's export function until termination takes effect. If the Customer deletes the Company Account, the data is removed upon deletion.
The statutory retention obligations under §§ 238, 257 HGB and §§ 145 to 147 AO apply to the Customer. NoCFO recommends that the Customer ensure that all necessary materials have been stored before deleting the Company Account.
This appendix supplements the Agreement and remains valid for as long as the Agreement remains in force.
The AI assistant included in the Service ("Luca") processes data stored by the Customer in the Service in order to enable the assistant's functionality. The data processed may include financial administration documents, transactions, customer register data, and other information stored by the Customer in the Service. In addition, Luca processes messages and voice commands sent by the User to the assistant in order to provide the assistant's functionality.
Data is stored within the EU/EEA. Data processing may occur outside the EU/EEA in compliance with applicable data protection legislation.
Luca uses a third-party AI service, which acts as NoCFO's subprocessor in accordance with Section 5. The AI service provider does not use the data it processes for its own purposes, such as training its models.
This appendix applies only to the payment functionality offered in the NoCFO Service, through which the Customer may initiate payment orders using licensed payment services provided by third parties. This appendix supplements NoCFO's Terms of Service and takes precedence to the extent it concerns payment functionality.
1.1 NoCFO provides the Customer with a technical software solution that allows the Customer to initiate payments through licensed payment services provided by third parties.
1.2 NoCFO is not a payment service provider or a payment institution within the meaning of the German Payment Services Supervision Act (ZAG) and does not provide payment services within the meaning of § 1 (1) ZAG. NoCFO is not an obliged entity within the meaning of § 2 of the German Money Laundering Act (GwG). NoCFO does not take possession of, hold, or forward any funds belonging to the Customer or to third parties.
1.3 NoCFO provides the Customer solely with a technical software solution through which the Customer may transmit payment orders to licensed payment service providers. NoCFO is not a party to the payment transaction between the Customer and the payment recipient.
2.1 Payments are executed on the basis of the contractual relationship between the Customer and the Customer's bank or other licensed payment service provider.
2.2 The Customer is responsible for verifying the final status of each payment from its own bank.
The payment initiation service may be provided in cooperation with Salt Edge Limited and its licensed payment institution partner.
Salt Edge and its partner are responsible for the technical execution of the payment order and for providing the payment service.
NoCFO may also offer the Customer the possibility to initiate payments from a Holvi account provided by Holvi Payment Services Oy through a separate integration.
Payments related to the Holvi account are executed on the basis of the contractual relationship between Holvi and the owner of the Holvi account; NoCFO is not a party to that contractual relationship or payment transaction.
In connection with the Holvi integration, NoCFO acts solely as a technical service provider that transmits payment orders given by the Holvi account owner or a user authorized by the account owner to Holvi. All payments initiated from a Holvi account through NoCFO are deemed to have been initiated by the Holvi account owner.
The Holvi account owner may grant other users the right to initiate payments from the Holvi account. The Holvi account owner is solely and fully responsible for granting access rights, their scope and validity, and all payments and other actions carried out on the basis of such access rights. NoCFO is not responsible for granting, monitoring, or revoking access rights, nor for payments made on the basis of such rights.
3.1 The Customer is responsible for all payment information entered by it, for the accuracy of such information, and for ensuring that the payment order is lawful and that the Customer has the right to make the relevant payment.
3.2 A payment order is initiated only after the Customer has expressly consented to the execution of the payment and accepted the third-party terms of service and privacy policy applicable to the payment initiation service (Salt Edge).
3.3 A payment order cannot be cancelled or modified through NoCFO after the Customer has approved the payment.
3.4 NoCFO does not process payment refunds. Any refunds must be handled between the Customer and the bank or payment recipient.
4.1 The Customer is responsible for the lawfulness of its own operations, including compliance with the obligations applicable to it under the German Money Laundering Act (GwG).
4.2 NoCFO does not perform customer identification, transaction monitoring, or suspicious activity reporting on behalf of the Customer.
4.3 NoCFO may suspend the payment functionality if there are reasonable grounds to suspect misuse or unlawful use, or if a participating payment service provider so requires.
5.1 Liability is governed by Section 8 of the Terms of Service.
5.2 NoCFO is not liable for the execution, delay, interruption, or failure of payments, nor for the actions of banks, payment service providers, or other third parties.
NoCFO has the right to suspend the payment functionality in whole or in part without liability for compensation if a third party related to the payment functionality is prevented from providing its service, if regulations change, if an information security or misuse risk arises, or if continuing the service is not reasonably possible.