Acceptable Use Policy

Last Updated: 03 August 2026

1. Scope

This Acceptable Use Policy ("AUP") applies to every customer of the VerbaFlo Platform and to every user the customer authorises. It forms part of the Platform Terms of Service. Where a customer permits a third party to configure or operate the Platform on its behalf, the customer remains responsible for that party’s compliance with this AUP.

Capitalised terms have the meaning given in the Platform Terms of Service.

2. Prohibited uses

You must not use the Platform, and must not configure or permit it to be used, to:

2.1 Infer the emotions of your workers. Deploy any feature that infers or purports to infer the emotional state of your employees, contractors, agents or job applicants, including from voice characteristics such as tone, pitch or speech patterns. This applies regardless of whether the person has consented.

2.2 Score people socially. Evaluate, classify or rank individuals based on social behaviour, or on personal characteristics unrelated to the service being provided, where the resulting score is used to their detriment in a context unrelated to the one in which the data was generated.

2.3 Assess creditworthiness. Evaluate the creditworthiness of a natural person, establish a credit score, or predict an individual’s likelihood or capacity to make a payment, whether described as credit assessment, affordability, arrears risk, engagement scoring or otherwise.

2.4 Exploit vulnerability. Use techniques that exploit a person’s age, disability, or economic or social situation to distort their behaviour in a way that causes or is likely to cause significant harm.

2.5 Use deceptive or manipulative techniques that materially distort a person’s behaviour and impair their ability to make an informed decision.

2.6 Conceal the AI. Disable, remove, obscure, delay or override any disclosure that a conversation is AI-operated, or any marking applied to AI-generated audio or text. You must not instruct or configure the Platform to deny that it is an AI system, or to present itself as a specific named human being.

2.7 Operate unlawfully. Use the Platform in breach of applicable law, including data protection, consumer protection, debt collection, housing, tenancy, equality or telecommunications law.

2.8 Misuse debt collection features. Use the Platform to contact individuals at unreasonable frequency or hour, to make threats, to misstate the legal consequences of non-payment, or in a manner amounting to harassment.

2.9 Target children. Direct the Platform’s conversational features at individuals you know or ought reasonably to know are under 18, other than in the ordinary course of a legitimate application process where a lawful basis exists and appropriate safeguards are applied.

3. Restriction on high-risk use

3.1 The Platform is provided for the intended purpose set out in the Platform Terms of Service and in the Documentation. It is not intended for, and must not be modified, configured or repurposed for, any use listed in Annex III of Regulation (EU) 2024/1689 (the EU AI Act), including the evaluation of creditworthiness of natural persons, the monitoring or evaluation of workers for the purpose of employment decisions, or decisions on access to essential private or public services.

3.2 If you wish to use the Platform for any such purpose, you must first obtain our written agreement and enter into a high-risk addendum. Absent that addendum, any such use is a material breach of the Platform Terms of Service.

3.3 You acknowledge that if you modify the intended purpose of the Platform so that the resulting system falls within Annex III, you become the provider of that high-risk AI system and assume the corresponding obligations under the EU AI Act.

4. Human oversight

4.1 You must keep a competent person in the loop for any decision with a legal or significant effect on an individual, including: granting or refusing a tenancy or application; escalating arrears or commencing recovery action; resolving a complaint; and any matter flagged as involving safeguarding, vulnerability or risk of harm.

4.2 You must assign responsibility for oversight of the Platform to identified individuals, ensure they have the competence and authority to intervene or stop the system, and ensure they understand the Platform’s limitations.

4.3 You must not represent to any person that a decision was taken by a human where it was not.

4.4 AI literacy. You must take measures to ensure that your staff and any other person operating the Platform on your behalf have a sufficient level of AI literacy, taking into account their technical knowledge, experience and training and the context in which the Platform is used, as required by Article 4 of Regulation (EU) 2024/1689. We make training materials and documentation available to support this.

5. Transparency obligations

5.1 We design the Platform to inform people that they are interacting with an AI system, and to mark AI-generated audio and text. You must not defeat those measures.

5.2 Where you use any feature that recognises emotion or categorises people using biometric data, you are responsible for informing the people exposed to it and for having a lawful basis for that processing.

5.3 Where you use the Platform to generate content that is published to the public on a matter of public interest, you are responsible for disclosing that the content is artificially generated, unless you have applied human editorial review and hold editorial responsibility for it.

6. Data

6.1 You must have a lawful basis for the personal data you process through the Platform, and must provide the notices required by data protection law to the individuals concerned.

6.2 You must not upload special category data, payment card data or government identity documents to the Platform except through a feature we have expressly designated for that purpose.

6.3 You must not use the Platform’s outputs, or data obtained through the Platform, to train, fine-tune, benchmark or evaluate a competing AI system.

7. Consequences of breach

7.1 If we reasonably believe you are in breach of this AUP, we may suspend or restrict access to the Platform or to a specific feature, in whole or in part, with or without notice where the circumstances require.

7.2 Where a breach relates to a practice prohibited by Article 5 of the EU AI Act, or presents a risk of harm to individuals, we may suspend immediately and without notice.

7.3 We will restore access when we are satisfied that the breach has been remedied. Suspension under this section does not relieve you of your payment obligations and does not limit any other remedy available to us.

8. Reporting misuse

8.1 If you believe the Platform is being used in breach of this AUP, tell us at contact@verbaflo.ai. We investigate every report.

8.2 Incident notification. You must notify us without undue delay, and in any event within 48 hours, if you become aware of any malfunction of the Platform, or any output or interaction, that has caused or could reasonably cause harm to an individual, a breach of applicable law, or a complaint to a regulator. This is in addition to any personal data breach notification obligation under the data processing agreement between us.